This is the accessible text file for GAO report number GAO-06-20 
entitled 'Immigration Benefits: Improvements Needed to Address Backlogs 
and Ensure Quality of Adjudications' which was released on December 21, 
2005. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as part 
of a longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

November 2005: 

Immigration Benefits: 

Improvements Needed to Address Backlogs and Ensure Quality of 
Adjudications: 

GAO-06-20: 

GAO Highlights: 

Highlights of GAO-06-20, a report to Congressional Requestors:  

Why GAO Did This Study: 

Long-standing backlogs of immigration benefit applications result in 
delays for immigrants, their families, and prospective employers who 
participate in the legal immigration process. In response to a 
statutory mandate to eliminate the backlog, the U.S. Citizenship and 
Immigration Services (USCIS) set a goal of September 30, 2006, to 
eliminate the backlog and adjudicate all applications within 6 months. 
This report examines (1) the status of the backlog, (2) actions to 
achieve backlog elimination and prevent future backlogs, (3) the 
likelihood of eliminating the backlog by the deadline, and (4) USCIS’s 
quality assurance programs to achieve consistency of decisions while 
eliminating its backlog. 

What GAO Found: 

By June 2005, USCIS estimated it had reduced its backlog from a peak of 
3.8 million cases to about 1.2 million. However, this estimate is not a 
measure of the number of pending cases older than 6 months—the 
definition of backlog used by the Immigration Services and 
Infrastructure Improvements Act of 2000. USCIS’s current data systems 
cannot provide precise data on the age of all application types. A 
proposed technology transformation offers an opportunity to develop a 
case management system with this capability. 

USCIS has reduced its backlog mainly by increasing and realigning 
staff. To prevent future backlogs, USCIS will rely on additional 
staffing reallocation and technology transformation. However, the 
technology plan is in the early planning stages, and USCIS has not 
finalized its estimated cost or identified the gains it could yield. 

Despite progress, it is unlikely that USCIS will completely eliminate 
the backlog by the 2006 deadline. While it met fiscal year 2006 targets 
for half of the 15 backlogged application types, USCIS may have 
difficulty eliminating its backlog for two complex application types 
that constitute nearly three-quarters of the backlog. A backlog may 
also remain in offices where the volume of cases exceeds adjudicator 
staff capacity. Other factors, such as lengthy background checks, could 
also hinder USCIS’s ability to achieve and maintain its backlog 
elimination goals. USCIS officials noted that its current plan is 
premised on current legislation and would be affected by proposed 
legislative changes that could impose additional demands on the agency. 

Aside from regular supervisory review, USCIS operates two programs to 
ensure the quality of its postadjudication decisions, yet neither 
program provides a systematic and inclusive review of all application 
types. One program reviews adjudicators’ compliance with standard 
processes for two application types, and the other evaluates compliance 
with standard processes and the reasonableness of decisions rendered, 
but only for selected applications processed in four centers. 

Benefit Applications Received, Completed, and Backlogged, March 2003-
June 2005: 

[See PDF for image] 

[End of figure] 

What GAO Recommends: 

GAO recommends that USCIS (1) ensure that its technology improvement 
efforts support the ability to generate information on the actual age 
of individual applications, (2) identify and articulate in its plans 
the benefits it expects to realize from its investment in technology 
transformation, and (3) develop a comprehensive quality assurance 
program that applies to all types of benefit applications and that 
addresses adjudication processes and reasonableness of decisions. 

We provided a draft of this report to USCIS for review. USCIS agreed 
with our findings and recommendations. 

www.gao.gov/cgi-bin/getrpt?GAO-06-20. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Paul L. Jones at (202) 
512-8777 or JonesPL@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

USCIS Estimated a Backlog of About 1.2 Million Unadjudicated 
Applications as of June 30, 2005: 

USCIS Has Undertaken Several Short-and Longer-Term Actions to Eliminate 
Its Backlog: 

Despite Progress, USCIS Seems Unlikely to Eliminate the Backlog for All 
Application Types in Every Office by September 30, 2006: 

USCIS Lacks a Comprehensive Approach to Postadjudication Quality 
Assurance: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: USCIS Organizational Structure: 

Appendix III: Information Technology Systems: 

Appendix IV: District Office Application for Naturalization (N-400) 
Processing Quality Checklist: 

Appendix V: Adjustment of Status (I-485) Processing Quality Assurance 
Checklist: 

Appendix VI: Service Center Checklists Used for Reviewing Quality 
Assurance of Petitions for a Nonimmigrant Worker: 

Appendix VII: Comments from the Department of Homeland Security: 

Appendix VIII: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Applications and Petitions USCIS Focused On for Backlog 
Elimination: 

Table 2: Workload Targets by Application Type and Fiscal Years 2004, 
2005, and 2006: 

Table 3: Backlog Elimination Expenditures for Fiscal Years 2002 through 
2005 (in thousands of dollars): 

Table 4: Months of Receipts Pending as of June 2005 Compared with 
Targets by Application Type for Fiscal Years 2004, 2005, and 2006: 

Table 5: Summary of Background Checks Required for Selected Benefit 
Applications: 

Table 6: General Preferences for Immigration Visas and Allocation 
Limits for Fiscal Year 2005: 

Figures: 

Figure 1: Steps Involved in Adjudicating Applications for 
Naturalization (Form N-400): 

Figure 2: Steps Involved in Adjudicating Family-based Applications for 
Adjustment of Status to Lawful Permanent Resident (Form I-485): 

Figure 3: Allocation of USCIS's Backlog Elimination Funds, Fiscal Years 
2002 through 2005: 

Figure 4: Adjudicator Staff Distribution Compared with USCIS's Proposed 
Redistribution: 

Figure 5: Numbers of Applications Received, Completed, and Backlogged, 
March 2003 through June 2005: 

Figure 6: Pending Workload and Workload Targets for Applications for 
Completing Adjustment of Status to Lawful Permanent Resident (Form I- 
485): 

Figure 7: Pending Workload and Workload Targets for Completing 
Applications for Naturalization (Form N-400): 

Figure 8: Projected Workload in Hours, by Region, July 2005 through 
September 2006 Compared with Distribution of Available Adjudicator 
Hours as of June 2005: 

Figure 9: Processing Accuracy Rates for the Naturalization Quality 
Procedures for Cases Reviewed in Selected Offices and Centers, Fiscal 
Years 2004 and 2005, First and Second Quarters: 

Abbreviations: 

CFR: Code of Federal Regulations: 

CIO: Chief Information Officer: 

CIS: Citizenship and Immigration Services: 

CLAIMS: Computer Linked Application Information Management System: 

DHS: Department of Homeland Security: 

DHS-IG: Department of Homeland Security Inspector General: 

FBI: Federal Bureau of Investigation: 

FDNS: Office of Fraud Detection and National Security: 

ICE: Immigration and Customs Enforcement: 

IBIS: Interagency Border Inspection System: 

INS: Immigration and Naturalization Service: 

LIFE: Legal Immigration Family Equity: 

MNS: Mission Needs Statement: 

NACARA: Nicaraguan Adjustment and Central American Relief Act: 

NOID: Notice of Intent to Deny: 

RFE: Request for Evidence: 

USCIS: United States Citizenship and Immigration Service: 

United States Government Accountability Office: 

Washington, DC 20548: 

November 21, 2005: 

The Honorable F. James Sensenbrenner, Jr.: 
Chairman, Committee on the Judiciary: 
House of Representatives: 

The Honorable John Conyers, Jr.: 
Ranking Minority Member, Committee on the Judiciary: 
House of Representatives: 

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

In fiscal year 2004 nearly 6 million applications were filed by those 
seeking an immigration benefit--permission for an alien to live in and 
in some cases work either permanently or on a temporary basis in the 
United States or to become a citizen. Most immigration benefits can be 
classified into one of two major categories, family-based and 
employment-based. Family-based requests for benefits are filed by U.S. 
citizens or permanent resident aliens to establish their relationships 
to certain alien relatives such as spouses, parents, children, or 
siblings who wish to immigrate to the United States. Employment-based 
petitions include petitions filed by employers for aliens to come to 
the United States temporarily to perform services or labor or to 
receive training and for alien workers to become permanent residents in 
the United States. Petitions can be filed on behalf of aliens outside 
of the United States who wish to enter the country and on behalf of 
aliens already in the United States who wish to change from one 
immigration status to another, such as from a visitor to a temporary 
worker. The United States Citizenship and Immigration Services (USCIS), 
within the Department of Homeland Security (DHS), collects fees for 
processing most types of applications and petitions.[Footnote 1] 

In the past we have reported that some applications and petitions-- 
benefit applications--have taken 2 years or longer to process, 
resulting in backlogs of pending applications.[Footnote 2] Recurring 
backlogs of benefit applications have been a long-standing problem for 
the former Immigration and Naturalization Service (INS) whose benefit 
adjudication functions are now the responsibility of USCIS. USCIS 
inherited this backlog problem which has created hardships for 
immigrants, their families, and prospective employers seeking immigrant 
workers. Families are kept apart and businesses are denied the 
expertise of skilled workers when applicants are subjected to long 
application-processing wait times. Moreover, critics have suggested 
that large backlogs of benefit applications create incentives for 
individuals and businesses to circumvent established legal procedures. 

In past years, INS allocated a portion of its appropriation to agency 
initiatives to reduce the backlog of pending benefit applications. The 
funds for this effort included $176 million in fiscal year 1999, $124 
million in fiscal year 2000, and $35 million in fiscal year 2001, in 
addition to the fees it was authorized to collect for processing 
benefit applications.[Footnote 3] Further, in October 2000, the 
Immigration Services and Infrastructure Improvements Act of 2000 
mandated INS to develop a plan to eliminate its backlog of benefit 
applications.[Footnote 4] The act defines backlog as the period of time 
in excess of 180 days (6 months) that an immigration benefit 
application has been pending before the agency--that is, the backlog 
consists of applications that have not been adjudicated within 6 months 
of filing. Beginning in fiscal year 2002, the administration sought and 
received appropriations sufficient to fund a 5-year, $500 million 
initiative to obtain a universal 6-month processing standard for all 
immigration benefit applications and petitions.[Footnote 5] At the end 
of 2003, USCIS still had over 6 million immigration benefit 
applications awaiting adjudication--which included about 3.7 million 
applications reported as backlog. In March 2002 USCIS published a plan 
(which was updated in June 2004) to eliminate its backlog by the end of 
fiscal year 2006. USCIS officials noted that this plan is based on the 
assumption that the agency will continue to operate under current laws 
and that if any new legislation, such as a proposed guest worker 
program, is enacted before the end of fiscal year 2006 without 
provisions for resources to carry out new responsibilities, the 
agency's ability to eliminate the backlog could be compromised. In 
addition to presenting strategies for backlog elimination, the plan 
acknowledged the importance of balancing its focus on reducing the 
backlog with its efforts to ensure adjudicative quality, stating that 
it is imperative that the integrity of the process not be compromised 
by efforts to stimulate productivity. 

You asked us to review USCIS's implementation of its backlog 
elimination efforts, including the current status and size of the 
backlog, and the agency's actions and plans to address the backlog 
while ensuring consistent and high-quality adjudication decisions. This 
report addresses the following questions: 

* What is the current status of USCIS's backlog of unadjudicated 
applications for immigration benefits? 

* What actions has USCIS taken to eliminate the backlog by September 
30, 2006, and prevent future backlogs? 

* Is USCIS likely to eliminate the backlog by September 30, 2006? 

* How does USCIS ensure the quality and consistency of adjudicator 
decisions while eliminating the backlog? 

To determine the status of USCIS's backlog, we interviewed agency 
officials and reviewed USCIS's backlog elimination plans and updates 
along with the agency's supporting analyses and compared them with the 
statutory definition of backlog in the Immigration Services and 
Infrastructure Improvements Act of 2000. To identify actions USCIS has 
taken to eliminate the backlog, we interviewed USCIS officials in 
headquarters and 10 field offices that were selected generally on the 
basis of workload volume, staffing levels, and backlog levels. Because 
we selected a nonprobability sample of field offices to visit, the 
results from our interviews with USCIS officials in these offices 
cannot be generalized to USCIS offices nationwide.[Footnote 6] Where 
possible, we corroborated their responses with agency data that we 
assessed for reliability and determined were sufficiently reliable for 
our purposes. We also collected information on USCIS's efforts to 
prevent future backlogs from USCIS's planning documents on staffing, 
budget, and information technology modernization. To estimate the 
likelihood that USCIS would eliminate the backlog on time, we tracked 
and compared the agency's progress in reducing its workload with the 
targets USCIS established and identified factors that could affect 
USCIS's ability to complete all applications within 6 months or less. 
To determine how USCIS ensures the quality and consistency of 
adjudicator decisions, we examined USCIS's two quality assurance 
programs and resulting outcomes, and we reviewed the findings and 
recommendations of an independent study of USCIS's quality assurance 
programs. We conducted our review from September 2004 through September 
2005 in accordance with generally accepted government auditing 
standards. 

Results in Brief: 

As of June 30, 2005, USCIS estimated that it had about 1.2 million 
cases in its backlog, down from a peak of about 3.8 million in January 
2004. However, because USCIS's operational definition of backlog 
differs from the definition in the Immigration Services and 
Infrastructure Improvements Act of 2000, its count is not a precise 
reflection of the number of cases that have been pending for more than 
6 months. The agency defines its backlog as the number of pending 
applications (i.e., the number of applications awaiting adjudication) 
in excess of the number of applications received in the most recent 6 
months. Under this method of estimating the backlog, USCIS could 
theoretically have applications pending for more than 6 months and not 
have a backlog. According to USCIS, it cannot readily determine the 
number of applications that have been pending for more than 6 months 
from the data management systems it is currently using to manage its 
backlog elimination efforts. However, USCIS has identified the 
technology improvements necessary to develop this capability. Since 
fiscal year 2002, the agency has invested about 2 percent ($10.5 
million) of its funds allocated for backlog elimination for technology 
improvements. Among the critical elements of USCIS's planned technology 
modernization efforts is a new case management system that should 
provide the agency with the capability to produce management reports on 
the age of all pending benefit applications. However, this information 
technology modernization effort is still in the early stages of 
planning, and USCIS does not expect these systems to be fully deployed 
before fiscal year 2010. Until USCIS develops this capability, it 
cannot assure Congress that it has successfully eliminated the backlog 
under the statutory definition. 

USCIS has made progress in reducing its backlog of benefit applications 
primarily by increasing and realigning staff, focusing its efforts on 
adjudicating petitions for alien relatives who can immigrate 
immediately, streamlining the adjudication process, experimenting with 
pilot processes to expedite application adjudication, and adopting best 
practices identified from those pilots. Since fiscal year 2002, USCIS 
has committed about 70 percent of its backlog reduction funds to 
employing about 1,100 temporary adjudicator staff and authorizing 
overtime. USCIS has also moved benefit application files from field 
offices with excess workloads to offices with no excess work. In 
addition, USCIS has begun to implement longer-term strategies to 
eliminate the backlog, including reallocating staff among offices. For 
example, USCIS officials told us that staff have been detailed from 
overstaffed offices in the central and western regions to understaffed 
offices in the eastern region. Further, USCIS has set aside those 
applications for which a benefit is not available and eliminated these 
applications from its count of backlogged cases.[Footnote 7] 

In an effort to streamline the adjudication process, USCIS has revised 
its guidance and proposed changes to its regulations. For example, 
USCIS revised its guidance to help ensure that adjudicators do not 
issue unnecessarily broad requests for additional evidence and has 
proposed changes to regulations to give adjudicators the discretion to 
shorten the time applicants are allowed to respond to the request, 
depending on the nature of the request. Finally, USCIS plans to adopt 
successful practices from pilot project experiments. For example, in 
April 2005, USCIS began using certain successful practices that 
facilitate processing applications for adjustment of status within 90 
days at three district offices that did not have a backlog of these 
types of applications. 

In addition to its efforts to reduce the backlog by September 30, 2006, 
the agency has developed a staffing allocation model and is planning a 
major transformation of its information technology systems to prevent 
future backlogs. According to the model, USCIS must fill positions that 
are currently vacant and better balance the number of adjudicator staff 
among the field office locations. In addition, USCIS has proposed 
transformation of its information technology environment, among other 
things, to support the prevention of future backlogs by upgrading its 
information technology infrastructure, providing better data management 
support, and developing new business processes. The preliminary 
estimated cost of this effort is about $1.4 billion over the next 5 
years. USCIS is investigating a number of funding strategies. The 
agency has not yet articulated the potential productivity gains this 
technology transformation plan could yield, such as efficiencies 
realized from moving from a manual paper-driven process to a paperless 
adjudication environment. Such information could be useful to both 
USCIS and Congress in making informed decisions about the appropriate 
level of investment in technology upgrades. 

Although USCIS has made progress in reducing its backlog of benefit 
applications, it seems unlikely that USCIS will meet its backlog 
elimination goal--to reduce the number of benefit applications to a 
level that is equal to 6-months' worth of work by September 30, 2006-- 
in every office and for every application type. USCIS has set 
increasingly more stringent processing targets to address its September 
2006 goal. USCIS met its 2004 targets, and, as of June 30, 2005, had 
made progress toward meeting its targets for fiscal year 2005 for most 
application types. However, USCIS may have difficulty achieving the 
more ambitious targets it set for fiscal year 2006 for applications for 
both naturalization and adjustment of status to lawful permanent 
resident, the two complex application types that constitute nearly 
three-quarters of the backlog. USCIS must reduce its workload from 15 
months' worth of pending applications for adjustment of status and from 
10 months' worth of pending applications for naturalization to 6 
months' worth for both application types by the end of fiscal year 
2006. The agency's progress through June 2005 and the more ambitious 
targets that must be achieved for these two application types raise 
doubts about USCIS's ability to meet its target. Our analyses indicate 
that to eliminate the backlog for these two application types, USCIS 
would need to nearly double its productivity. Specifically, based on 
USCIS's projections, the agency must complete about 69 percent more 
applications for adjustment of status, and about 124 percent more 
applications for naturalization in the last 15 months of its plan than 
it did during the most recent 15 months (April 1, 2004, through June 
30, 2005) if it hopes to eliminate the backlog of these two application 
types by September 30, 2006. In addition, although USCIS officials said 
that the agency currently has more staff hours available than needed to 
meet its projected workload in certain offices, in other offices the 
volume of applications exceeds adjudicator staff capacity and the 
backlog may remain. Other factors beyond the agency's control could 
also prevent some applications from being adjudicated within 6 months. 
For example, extensive background checks may delay completion of some 
applications beyond the 6-month target. Moreover, USCIS officials noted 
that its current plan is premised on current legislation and would be 
affected by proposed legislative changes that could impose additional 
demands on the agency. 

USCIS operates two postadjudication programs to ensure the quality and 
consistency of adjudicator decisions. First, USCIS's Performance 
Management Division administers an agencywide quality assurance program 
to review adjudicator compliance with standard processes for 
adjudicating applications for naturalization and for adjustment of 
status to lawful permanent resident and to check that completed 
naturalization cases have been accurately recorded in its case 
management systems. The other quality assurance program, administered 
by USCIS's Service Center Operations Division, is designed to evaluate 
both compliance with standard processes and consistency in decision 
making for select applications processed exclusively by service 
centers.[Footnote 8] Each of these two programs is intended to provide 
some measure of quality assurance to the USCIS adjudicative process. 
However, together these programs do not include all application types 
and do not evaluate compliance with standard operating procedures and 
the reasonableness of the adjudicator's decision. The Performance 
Management Division program currently reviews compliance with standard 
operating procedures for only 2 of 15 application types in the backlog 
elimination plan and does not evaluate the reasonableness of the final 
adjudicative decision. In contrast the Service Center Operations 
Division's approach evaluates the reasonableness of adjudicative 
decisions (i.e., whether the same decision would have been made by 
another adjudicator given the evidence provided) as well as measuring 
compliance with standard operating procedures, but thus far has focused 
its attention on only four application types, each for a fixed period 
of time. Information collected from these programs is not comparable, 
so they cannot provide USCIS with a complete picture of the quality of 
its adjudications. In addition to these two programs, USCIS also checks 
quality through supervisory reviews of case files at the local office 
level. However, these reviews are not uniform or consistently performed 
across all local offices. 

We recommend that USCIS determine and report the size of its backlog in 
a manner consistent with the definition in the Immigration Services and 
Infrastructure Improvements Act of 2000 as soon as practicable under 
its technology transformation plans. USCIS plans indicate that its case 
management system will have the capability to generate management 
reports based on the age of individual benefit applications. To help 
USCIS and Congress to make sound decisions regarding resource 
allocation, including staffing allocation and investment in technology 
transformation, we are recommending that USCIS identify and articulate 
in its plans the benefits it expects to realize from its substantial 
investment in technology transformation. To improve the quality 
assurance program, we recommend that USCIS develop a program that 
addresses adjudication processes and outcomes that can be applied to 
all types of benefit applications. 

The Department of Homeland Security agreed with our recommendations and 
identified steps it was planning or had begun in response. These 
include developing the capability to monitor the actual age of benefit 
applications, identifying methods to increase productivity through 
streamlining processes and taking advantage of information technology 
improvements, and developing a comprehensive quality assurance program. 

Background: 

The United States Citizenship and Immigration Services, within the 
Department of Homeland Security, delivers services to aliens and 
adjudicates their eligibility for various immigration benefits, 
including naturalization, adjustment of status to lawful permanent 
resident, employment authorization, and asylum. USCIS carries out its 
service function through a network of field offices consisting of a 
National Benefits Center, which serves as a central processing hub for 
certain benefit applications and utilizes secured depositories in 
Chicago, Illinois, and Los Angeles, California, to collect 
fees;[Footnote 9] 4 service centers, which generally adjudicate 
applications that do not require interviews with the applicants; 78 
district and local offices; 31 international offices and 8 asylum 
offices, which generally adjudicate applications that require 
interviews; and 129 application support centers, which collect and 
process biometric information. Appendix II contains a detailed 
discussion of USCIS's organizational structure. USCIS's application- 
processing procedures vary by application type and by office. Figures 1 
and 2 depict the agency's process for adjudicating naturalization and 
adjustment of status applications--its two most common and complex 
application types. 

Figure 1: Steps Involved in Adjudicating Applications for 
Naturalization (Form N-400): 

[See PDF for image] 

[End of figure] 

Figure 2: Steps Involved in Adjudicating Family-based Applications for 
Adjustment of Status to Lawful Permanent Resident (Form I-485): 

[See PDF for image] 

[End of figure] 

In general, the following tasks are involved in application processing: 
(1) collect and deposit application fees and issue receipts to 
applicants; (2) create or request existing alien files; (3) enter 
applicant data into an automated system; (4) take applicants' 
fingerprints and send them to the Federal Bureau of Investigation (FBI) 
for a criminal history check, including a criminal history check based 
on the applicant's name (if required by the type of application); (5) 
review application, and other supporting documents, such as FBI 
fingerprint check results, marriage certificates, or court dispositions 
of an arrest; (6) interview applicants (if required by the type of 
application); (7) administer naturalization tests (for those applying 
for naturalization); (8) approve or deny cases; (9) notify applicants 
of USCIS's decisions; or (10) issue a Notice to Appear placing 
applicant in removal proceedings; and (11) update USCIS's automated 
systems. 

Although USCIS processes about 50 types of immigration benefit 
applications, its backlog elimination efforts have focused on the 15 
application types that make up about 94 percent of its workload. Table 
1 lists these 15 application types and their purposes. 

Table 1: Applications and Petitions USCIS Focused On for Backlog 
Elimination: 

Form number: I-485; 
Application type: Adjustment of status; 
Purpose: Application for permanent resident status. 

Form number: I-129; 
Application type: Nonimmigrant worker[A]; 
Purpose: Employer petition for a nonimmigrant worker. 

Form number: I-539; 
Application type: Extend/change nonimmigrant status; 
Purpose: Petition to extend stay as a nonimmigrant or to change status. 

Form number: I-90; 
Application type: Replace/renew permanent resident card; 
Purpose: Application to renew or replace permanent resident card in the 
event of an obsolete card; lost, stolen, mutilated, or destroyed card; 
or name change. 

Form number: I-130; 
Application type: Petition for alien relative; 
Purpose: Petition to establish qualifying relationship between 
petitioner and an alien relative who wishes to immigrate to the United 
States. 

Form number: I-131[B]; 
Application type: Advance parole (travel document); 
Purpose: An extraordinary measure used sparingly to bring an otherwise 
inadmissible alien to the United States for a temporary period of time 
because of a compelling emergency. 

Application type: Reentry permit/refugee travel document; 
Purpose: Application for admission to the United States upon return 
from abroad during the permit's validity, without having to obtain a 
returning resident visa. 

Form number: I-140; 
Application type: Immigrant worker; 
Purpose: Petition for classification of an alien who wishes to 
immigrate to the United States based on employment. 

Form number: I-751; 
Application type: Removal of conditional status; 
Purpose: Petition to remove the conditions on residence based on 
marriage. 

Form number: I-765; 
Application type: Employment authorization document; 
Purpose: Application for employment authorization. 

Form number: I-821; 
Application type: Temporary protected status; 
Purpose: Application for temporary immigration status granted to 
eligible nationals of designated countries. 

Form number: N-400; 
Application type: Naturalization; 
Purpose: Application for naturalization. 

Form number: N-600/643; 
Application type: Certificate of citizenship; 
Purpose: Application for certificate of citizenship based on parentage. 

Form number: I-589; 
Application type: Asylum application; 
Purpose: Application for asylum. 

Form number: I-881; 
Application type: Nicaraguan Adjustment and Central American Relief Act 
203 application (NACARA 203); 
Purpose: Application to suspend deportation under section 203 of the 
Nicaraguan Adjustment and Central American Relief Act (Pub.L. 105-100). 

Form number: I-867; 
Application type: Credible fear referral; 
Purpose: Referral to an asylum officer for credible fear determination. 

Source: GAO compilation of USCIS information. 

[A] A nonimmigrant worker is an alien who is admitted to the United 
States for a specified job for a specified period of time, but not for 
permanent residence. 

[B] The I-131 form is used for applications for advance parole as well 
as for applications for refugee travel documents and applications for a 
reentry permit. For the purposes of backlog elimination progress 
reporting, USCIS is using these two groupings in reporting progress on 
this form type. 

[End of table] 

In October 2000, the Immigration Services and Infrastructure 
Improvements Act mandated INS, the agency previously responsible for 
USCIS's functions, to develop a plan to eliminate its backlog of 
benefit applications. The act defines backlog as the period of time in 
excess of 180 days (6 months) that an immigration benefit application 
has been pending before the agency.[Footnote 10] Moreover, in February 
2001, in the President's fiscal year 2002 budget, the Administration 
proposed a universal 6-month standard for completing adjudication of 
immigration applications and supported a 5-year, $500 million 
initiative to meet this standard. The President reiterated this goal 
during a naturalization ceremony on July 10, 2001, saying, "Today, 
here's the goal for the INS: a six-month standard from start to finish 
for processing applications for immigration. It won't be achievable in 
every case, but it's the standard of this administration and I expect 
the INS to meet it." 

In May 2001, we reported on the difficulties INS had in managing its 
workload, resulting in ever-growing backlogs of applications, despite 
growth in staff and budget.[Footnote 11] For example, although the 
agency's efforts to meet production goals for processing naturalization 
and adjustment of status applications did help reduce backlogs in those 
areas, backlogs for other application types increased. 

Under a 5-year plan starting in March 2002, INS intended not only to 
eliminate the immigration benefit application backlog, but also to 
achieve a 6-month processing standard for all applications in every 
office. The original plan was to eliminate the backlog in 2 years, with 
the remaining years used to invest in information technology in order 
to prevent future backlogs. However, in part because of events 
following the September 11, 2001, terrorist attacks, including 
attention to national security priorities and agency reorganization, 
INS's resources were diverted from backlog elimination efforts. For 
example, adjudicators assumed responsibility for registering and 
fingerprinting nationals already living in the United States from 
countries identified as potential threats and for overseeing the 
student immigration tracking system--functions that have since been 
transferred to the Immigration and Customs Enforcement (ICE) bureau 
within DHS. In June 2004, the newly formed USCIS issued a revised 
backlog elimination plan that proposed to eliminate the backlog of 
benefit applications by September 30, 2006, and to reduce application 
completion times to no more than 6 months. 

USCIS Estimated a Backlog of About 1.2 Million Unadjudicated 
Applications as of June 30, 2005: 

As of June 30, 2005, USCIS estimated it had about 1.2 million cases 
remaining in its backlog, down from 3.7 million at the end of fiscal 
year 2003. However, USCIS's operational definition of backlog is 
different than the definition contained in the Immigration Services and 
Infrastructure Improvements Act of 2000, and its count is not a precise 
reflection of the number of cases that have been pending for more than 
6 months. USCIS defines its backlog generally in terms of its pending 
workload--that is, the number of applications it has on hand minus the 
number of applications it has received during a specified period of 
time, which is 6 months or less, depending on the type of application. 
It has established targets for each fiscal year for reducing its 
pending workload, by application type, based upon its estimate of how 
much time is required to complete each type. Table 2 shows these 
workload targets by application type and fiscal year. 

Table 2: Workload Targets by Application Type and Fiscal Years 2004, 
2005, and 2006: 

Form number: I-485; 
Application type/purpose(s): Adjustment of status; 
Targets (months): 2004: 20; 
Targets (months): 2005: 15; 
Targets (months): 2006: 6. 

Form number: I-129; 
Application type/purpose(s): Nonimmigrant worker; 
Targets (months): 2004: 2; 
Targets (months): 2005: 2; 
Targets (months): 2006: 2. 

Form number: I-539; 
Application type/purpose(s): Extend/change nonimmigrant status; 
Targets (months): 2004: 5; 
Targets (months): 2005: 4; 
Targets (months): 2006: 3. 

Form number: I-90; 
Application type/purpose(s): Replace/renew permanent resident card; 
Targets (months): 2004: 10; 
Targets (months): 2005: 8; 
Targets (months): 2006: 6. 

Form number: I-130; 
Application type/purpose(s): Petition for relative alien--all; 
Targets (months): 2004: 30; 
Targets (months): 2005: 16; 
Targets (months): 2006: 6. 

Form number: I-131[A]; 
Application type/purpose(s): Advance parole travel document; 
Targets (months): 2004: 3; 
Targets (months): 2005: 3; 
Targets (months): 2006: 3. 

Application type/purpose(s): Reentry permit; 
Targets (months): 2004: 11; 
Targets (months): 2005: 7; 
Targets (months): 2006: 3. 

Form number: I-140; 
Application type/purpose(s): Immigrant worker; 
Targets (months): 2004: 8; 
Targets (months): 2005: 7; 
Targets (months): 2006: 6. 

Form number: I-751; 
Application type/purpose(s): Removal of conditional status; 
Targets (months): 2004: 15; 
Targets (months): 2005: 11; 
Targets (months): 2006: 6. 

Form number: I-765; 
Application type/purpose(s): Employment authorization document; 
Targets (months): 2004: 3; 
Targets (months): 2005: 3; 
Targets (months): 2006: 3. 

Form number: I-821; 
Application type/purpose(s): Temporary protected status; 
Targets (months): 2004: 6; 
Targets (months): 2005: 6; 
Targets (months): 2006: 6. 

Form number: N-400; 
Application type/purpose(s): Naturalization; 
Targets (months): 2004: 14; 
Targets (months): 2005: 10; 
Targets (months): 2006: 6. 

Form number: N-600/643; 
Application type/purpose(s): Certificate of citizenship; 
Targets (months): 2004: 8; 
Targets (months): 2005: 7; 
Targets (months): 2006: 6. 

Form number: I-589; 
Application type/purpose(s): Application for asylum; 
Targets (months): 2004: 23; 
Targets (months): 2005: 14; 
Targets (months): 2006: 6. 

Form number: I-881; 
Application type/purpose(s): NACARA 203 application; 
Targets (months): 2004: 16; 
Targets (months): 2005: 9; 
Targets (months): 2006: 6. 

Form number: I-867; 
Application type/purpose(s): Credible fear referral; 
Targets (months): 2004: 15 days; 
Targets (months): 2005: 15 days; 
Targets (months): 2006: 15 days. 

Source: USCIS's Backlog Elimination Plan, June 16, 2004 update. 

[A] The I-131 form is used for applications for advance parole as well 
as for applications for refugee travel documents and applications for a 
reentry permit. For the purposes of backlog elimination progress 
reporting, USCIS is using these two groupings in reporting progress on 
this form type. 

[End of table] 

According to USCIS, the data management systems it currently uses to 
manage its backlog elimination efforts cannot comprehensively produce 
data to measure and track the time that all applications have been 
pending, and therefore the agency cannot readily retrieve information 
on the number of applications that have been pending for more than 180 
days, as specified in the definition of backlog in the Immigration 
Services and Infrastructure Improvements Act of 2000. Instead, USCIS 
estimates its backlog based on the number of pending applications in 
excess of the applications it received during the past 6 months. For 
example, if the agency had received 100,000 applications for benefits 
in the most recent 6 months and currently had 120,000 cases awaiting 
adjudication, it would report a backlog of 20,000 cases.[Footnote 12] 
The agency's rationale for using this proxy is that by consistently 
completing more applications than are filed each month, the agency 
should gradually reduce its pending workload of applications to a level 
at which it can complete all incoming applications within the workload 
targets established for each application type. Eventually, according to 
the agency's backlog elimination plan, as long as USCIS is processing 
all applications received within the past 6 months (or less, depending 
on the application type's workload target) there should be no backlog 
because those applications awaiting adjudication should be completed 
before they become part of the backlog count of applications pending 
longer than 6 months. However, USCIS's definition of backlog does not 
guarantee that every applicant requesting a benefit will receive a 
decision within 6 months of filing. 

In our previous work on the benefit applications backlog, we noted that 
the agency's automated systems were not complete and reliable enough to 
determine how long it actually takes to process specific benefit 
applications or to determine the exact size of its backlog.[Footnote 
13] Therefore, we recommended that the former Immigration and 
Naturalization Service develop the capability and begin to calculate 
and report actual processing times for applications as soon as reliable 
automated data are available. USCIS has agreed that ideally it would 
prefer to base its backlog calculations on the actual age of each 
pending application. However, the data management system USCIS is 
currently using to manage its backlog elimination efforts does not have 
this capability for most application types.[Footnote 14] Since our 
recommendation, USCIS has identified requirements for transforming its 
information technology systems to address deficiencies in its 
capabilities.[Footnote 15] Starting in fiscal year 2002, INS and 
subsequently USCIS invested about 2 percent ($10.5 million) of its 
funds allocated for backlog elimination in planning for technology 
improvements. Table 3 shows USCIS's annual expenditures from its 
backlog elimination funds. 

Table 3: Backlog Elimination Expenditures for Fiscal Years 2002 through 
2005 (in thousands of dollars): 

Fiscal year: 2002; 
Temporary adjudication officers: $45,404; 
Field office overtime: $20,500; 
Records operation: $15,584; 
Service center mail and data entry: $14,512; 
Information technology case management system: $4,000; 
Grand total by fiscal year: $100,000. 

Fiscal year: 2003; 
Temporary adjudication officers: 46,281; 
Field office overtime: 21,000; 
Records operation: 16,000; 
Service center mail and data entry: 14,719; 
Information technology case management system: 2,000; 
Grand total by fiscal year: 100,000. 

Fiscal year: 2004; 
Temporary adjudication officers: 47,901; 
Field office overtime: 15,000; 
Records operation: 18,000; 
Service center mail and data entry: 17,099; 
Information technology case management system: 2,000; 
Grand total by fiscal year: 100,000. 

Fiscal year: 2005 est; 
Temporary adjudication officers: 107,401; 
Field office overtime: 15,000; 
Records operation: 18,000; 
Service center mail and data entry: 17,099; 
Information technology case management system: 2,500; 
Grand total by fiscal year: 160,000. 

Fiscal year: Total; 
Temporary adjudication officers: $246,987; (53.69%); 
Field office overtime: $71,500; (15.54%); 
Records operation: $67,584; (14.69%); 
Service center mail and data entry: $63,429; (13.79%); 
Information technology case management system: $10,500; (2.28%); 
Grand total by fiscal year: $460,000. 

Source: USCIS Budget Office. 

[End of table] 

Included in USCIS's technology transformation effort is the design and 
implementation of a new, integrated case management system that should 
provide the agency with the capability to produce management reports on 
the age of all pending benefit applications. USCIS considers this new 
case management system to be one of the most critical components of its 
technology transformation and plans to begin implementation in fiscal 
year 2006. However, this information technology transformation effort 
is still in the early stages of planning, and USCIS does not expect 
these systems, including the new case management system, to be fully 
deployed before fiscal year 2010. Until USCIS develops the ability to 
track the actual age of individual applications, it will not be able to 
provide accurate information about the actual number of applications 
that have been pending in excess of 180 days or the actual amount of 
time they have been pending. 

USCIS Has Undertaken Several Short-and Longer-Term Actions to Eliminate 
Its Backlog: 

USCIS has taken several actions to eliminate its benefit application 
backlog and to reduce the time it takes to process benefit 
applications. The most immediate short-term action was to hire 
temporary adjudicators--whose terms expire within 4 years--to address 
the backlog. In addition, USCIS began to implement longer-term 
strategies to eliminate the backlog, such as reallocating staff and 
reprioritizing the order in which the agency adjudicates petitions for 
alien relatives. The agency also has revised its guidance to increase 
the efficiency of application processing and has proposed related 
changes to its regulations. Finally, it has experimented with different 
processes to expedite application adjudication and is considering 
adopting best practices identified from those pilot programs. In 
addition to its efforts to reduce the backlog by September 30, 2006, 
the agency has developed a staffing allocation model and is planning a 
major transformation of its information technology systems to prevent 
future backlogs. According to the model, USCIS must fill positions that 
are currently vacant and better balance the number of adjudicator staff 
among the field office locations. USCIS's proposed information 
technology transformation is intended to support the prevention of 
future backlogs by upgrading its information technology infrastructure, 
providing better data management support, and developing new business 
processes. However, it is still in the early stages of planning. 

USCIS Hired Temporary Adjudicators and Supported Overtime Work: 

Beginning in fiscal year 2002, USCIS has added about 1,100 temporary 
adjudicators to address the backlog. As figure 3 shows, from fiscal 
year 2002 through fiscal year 2005, the agency allocated about 70 
percent of its backlog elimination funds for these temporary 
adjudicators and to overtime pay.[Footnote 16] USCIS allocated the 
remaining 30 percent to information technology planning, mail and data 
entry, and records management. 

Figure 3: Allocation of USCIS's Backlog Elimination Funds, Fiscal Years 
2002 through 2005: 

[See PDF for image] 

[End of figure] 

USCIS Reallocated Adjudicator Staff and Focused on Processing 
Applications for Which Benefits Can Be Provided Immediately: 

USCIS has applied several approaches to balancing its workload and 
improving the processing time for benefit applications. For example, 
between September 2003 and September 2004, USCIS transferred hundreds 
of applications for Adjustment of Status to Lawful Permanent Resident 
from the Chicago district office to the San Antonio district office for 
adjudication, because the Chicago office's workload exceeded its 
adjudicator capacity. Another approach has been to temporarily detail 
adjudicators from overstaffed offices to understaffed offices. For 
example, as of September 2005, USCIS officials said that about 50 
adjudicators from central and western region district offices had been 
detailed to the New York district office and the Garden City, New 
Jersey suboffice. In addition, another 40 adjudicators were detailed to 
the Atlanta and Miami district offices. 

USCIS has also reprioritized the order in which it adjudicates 
petitions for alien relatives. Because these relatives are subject to 
annual limits on the number of available immigration visas, even if 
USCIS were to find an alien relative eligible to immigrate, that alien 
could not immigrate if a visa were not available. Therefore, in July 
2004, USCIS decided to focus its efforts on adjudicating only those 
petitions for alien relatives where a visa was immediately available. 
According to USCIS, by setting aside those petitions for which a visa 
was not immediately available, the agency has been able to concentrate 
its efforts on those petitions for alien relatives who can immigrate 
immediately. Therefore, USCIS officials say, this approach has enabled 
the agency to increase its meaningful completions of petitions for 
alien relatives. Because of this policy change, USCIS has also removed 
those cases for which a visa is not available from its count of 
backlogged cases, eliminating approximately 1.15 million cases from its 
backlog count of about 3.7 million.[Footnote 17] 

To Boost Efficiency in Processing Benefit Applications, USCIS Proposed 
Regulations to Streamline Processes and Revised Guidance: 

USCIS has proposed or undertaken changes in regulations and processes 
to boost efficiency in processing benefit applications. While the 
results of these efforts should help eliminate the backlog and reduce 
time for completing applications, we did not evaluate the effects of 
these changes on backlog reduction and adjudication quality. 

Waiving Interview Requirements: 

As one of these streamlining efforts, the director of domestic 
operations for USCIS issued a memo in January 2005 revising its 
interview waiver requirements for adjustment of status applications. 
According to USCIS, the intent of the revised guidance is to more 
clearly define the circumstances in which service centers should 
transfer adjustment applications to district offices for interviews, 
which increases the time needed to adjudicate the case. In the summer 
of 2005, USCIS reviewed an informal sample of pending applications 
filed at the National Benefits Center to determine the percentage of 
adjustment applications that met the criteria for an interview waiver 
and found that about 20 percent met the criteria. In July 2005, USCIS 
began directing adjustment of status application packages that met the 
interview waiver criteria to the California service center for 
adjudication.[Footnote 18] According to USCIS, this process will 
alleviate some of the burden on offices that are struggling to meet 
backlog elimination targets and provide relief to offices that are 
currently sending staff to provide assistance. 

Regulatory Changes and Clarifying Guidance to Adjudicators for Requests 
for Additional Evidence and Notices of Intent to Deny: 

USCIS has issued clarifying guidance and is seeking to amend 
regulations that address when Requests for Evidence (RFE) and Notices 
of Intent to Deny (NOID) are required. Currently, federal regulations 
require USCIS to issue an RFE when initial evidence or eligibility 
information is missing from an application or petition, and in each 
case, USCIS is required to provide applicants with 12 weeks to respond. 
USCIS also has the discretion to issue an RFE for additional evidence 
and must give applicants 12 weeks to respond.[Footnote 19] 
Additionally, in some cases, federal regulations require USCIS to issue 
a NOID before denying benefits. These regulations normally require that 
applicants be given 30 days to respond to a NOID. In November 2004, a 
proposed rule was published in the Federal Register that would 
generally give USCIS discretion to issue an RFE or NOID and would allow 
USCIS to determine whether additional information is required to decide 
cases. Additionally, the rule proposes to replace the current 12-week 
response period with a more flexible approach that would allow USCIS to 
set deadlines based on factors such as type of benefit requested or 
type of application or petition filed. USCIS officials expect that 
reducing the number of RFEs and NOIDs required to be issued will reduce 
the average case-processing time by reducing the time a case is held 
awaiting decision and decreasing administrative burden. However, in 
commenting on the proposed rule, the American Immigration Lawyers 
Association expressed concern that USCIS is placing a higher priority 
on streamlining processes than on maintaining due process protections 
for applicants. In its comments, the association said that the proposed 
rule has no safeguards for ensuring that cases will be fairly 
adjudicated and that denying applications instead of giving applicants 
an opportunity to submit additional evidence results in a significant 
growth of arbitrary and capricious decisions. The final rule is still 
under review at USCIS. 

USCIS also issued guidance in February 2005 designed to increase the 
efficiency of application processing in cases involving RFEs and NOIDs 
under current regulations. Among issues covered in this guidance are 
appropriate circumstances to approve and deny benefits without issuing 
an RFE or NOID and how to choose between RFEs and NOIDs. Further, the 
guidance included instructions to limit RFEs and NOIDs to specific 
items of missing evidence. USCIS included these instructions because it 
found that adjudicators were, in some instances, issuing unnecessarily 
broad requests, which wasted adjudicator resources on review of 
unnecessary, duplicative, or irrelevant documents. 

Interim Regulatory Changes to Employment Authorization Validity Period: 

In July 2004, USCIS published an interim rule in the Federal Register 
that allows it more flexibility in establishing the length of validity 
for Employment Authorization Documents (EAD).[Footnote 20] Previously, 
federal regulations required USCIS to limit the time EADs were valid to 
1 year for specific types of applicants who applied for employment 
authorization. The interim rule removes regulatory language limiting 
EAD validity periods to 1 year. Under the interim rule, USCIS can 
determine the appropriate length of time, up to 5 years, for EADs to 
remain valid by using certain criteria such as an applicant's 
immigration status, processing time of the underlying application or 
petition, and background checks. USCIS officials said they expect that 
the ability to set longer validity periods for some types of applicants 
covered by the current regulation could reduce the adjudicative 
resources dedicated to processing renewals, thus allowing them to use 
this time to process new pending Applications for Employment 
Authorization. Although the flexibility to set the length of EAD 
validity is available, USCIS is currently restricting its EAD validity 
periods to 1 year. 

Creation of a Specialized Fraud Unit: 

According to USCIS officials, fraudulent applications have slowed the 
adjudication process. Because USCIS has not systematically tracked the 
occurrences of fraud, the agency has not been able to determine with 
any precision the extent to which fraud slows the adjudication process. 
In 2003, USCIS created the Office of Fraud Detection and National 
Security (FDNS) and revised its standard operating procedures to, among 
other things, help adjudicators identify fraudulent benefit 
applications and remove them from the processing stream. FDNS is 
currently developing a data system to track occurrences of fraud. In 
addition, to ensure that all fraud leads are collected and entered into 
this data system, adjudicators are now required by FDNS's fraud 
referral process to send all cases meeting the minimum criteria for 
suspected fraud to FDNS immigration officers, even if the adjudicator 
has sufficient evidence to deny the application or petition. 

According to USCIS officials, FDNS's fraud referral process--used in 
the district offices, service centers, and asylum offices--begins with 
an adjudicator's review of applications, petitions, supporting 
documentation, interviews, and other records. If the adjudicator 
discovers conflicting or otherwise unfavorable information that would 
lead a reasonable person to question the credibility of the applicant 
or petitioner, the adjudicator is to submit the application or petition 
to FDNS along with a list of general fraud indicators and a brief 
narrative explaining the nature of the suspected fraud that could 
render an applicant ineligible for the benefit sought. An FDNS 
immigration officer is to then conduct a variety of systems checks and 
additional research in an effort to verify the suspected fraud. If 
fraud is verified, the case is to be forwarded to the FDNS Fraud 
Detection Unit at the appropriate service center for review and 
possible referral to the Benefit Fraud Unit within ICE. According to 
USCIS, ICE has agreed to notify USCIS within 60 days whether it will 
accept or reject a request for investigation by the FDNS Fraud 
Detection Unit. If ICE declines the request for investigation, USCIS is 
to continue to pursue the information necessary to render a proper 
adjudication. If ICE investigates and verifies the suspected fraud, the 
FDNS immigration officer is to provide a written report to the 
adjudicator for preparation of the appropriate notice or decision. We 
did not evaluate the effectiveness of USCIS's fraud referral process as 
part of this review, but we plan to issue a separate report later this 
year on the nature and extent of immigration benefit fraud and the 
control mechanisms USCIS has in place to detect and deter fraud. 

USCIS Is Considering Adopting Certain Successful Practices from Pilot 
Project Experiments: 

The Homeland Security Act of 2002 created the Office of the Citizenship 
and Immigration Services (CIS) Ombudsman within the Department of 
Homeland Security, but independent of USCIS.[Footnote 21] The 
Ombudsman's role is to enhance the administration and delivery of 
citizenship and immigration services by identifying problems and 
proposing recommendations to eliminate major systemic obstacles to 
efficiency. Further, the Ombudsman is to work closely with DHS 
leadership in providing policy, planning, and program advice on 
immigration matters. In response to recommendations made in the CIS 
Ombudsman's 2004 annual report, USCIS conducted a number of pilot 
projects designed to reduce benefit application-processing times and is 
considering adopting several practices it determined to be 
successful.[Footnote 22] The agency studied the processing of two types 
of applications during the pilots--applications to replace permanent 
resident cards (form I-90) and applications to register permanent 
residence or adjust status (form I-485). The applications to adjust 
status pilots involved both petitions for alien relatives (form I-130) 
and petitions for immigrant workers (form I-140). 

During the period March 2004 through November 2004, USCIS conducted a 
pilot program designed to reduce processing time for applications for 
permanent resident cards. The pilot, conducted in the Los Angeles area, 
allowed for electronically filed permanent resident cards to be 
processed at application support centers, where applicants have their 
initial contact with the agency and have their photographs and 
fingerprints taken. Data showed that over 10,000 permanent resident 
cards were processed at Los Angeles application support centers and 88 
percent were approved during the initial contact. During the pilot, 
average processing times were reduced from over 8 months to about 2 
weeks. USCIS's Performance Management Division has recommended that 
USCIS implement the pilot nationwide.[Footnote 23] 

Beginning in March 2004 and May 2004 respectively, USCIS conducted 
pilot programs in the New York and Dallas district offices that focused 
on testing new processes for adjudicating family-based applications for 
adjustments of status within 90 days. Each sought to streamline and 
accelerate application processing by shifting aspects of processing 
responsibility from the National Benefits Center to the district 
offices. Besides reducing the backlog, one of the advantages of the 
ability to process adjustments of status within 90 days is reducing 
issuance of interim documents such as travel documents and employment 
authorizations. USCIS is generally required by regulation to grant 
interim employment authorization documents to applicants whose 
adjustment of status applications have not been adjudicated within 90 
days.[Footnote 24] In such cases, the adjudication process, including 
background checks, may not have been completed prior to the issuance of 
these documents.[Footnote 25] Therefore, in some instances benefits may 
be issued to applicants whose eligibility and potential risk to 
national security have not been fully determined. 

The New York pilot employed a process similar to the standard process 
of sending applications to a centralized location for receiving fees, 
conducting the initial processing, and initiating checks of records. 
Applicants were to be scheduled for an interview as soon as records 
checks were complete--with emphasis on completing these within 90 days. 
The New York pilot also placed particular emphasis on fraud deterrence. 
USCIS ultimately determined that the New York pilot was unsuccessful 
and terminated it, because, among other things, it failed to facilitate 
the adjudication of the majority of applications within 90 days and 
presented a fairness issue for earlier-filed cases. 

The Dallas pilot employed an up-front processing model that allowed 
applicants to be interviewed on the same day the application was filed. 
Data from Dallas showed that adjustment of status applications were 
completed, on average, within 90 days in 58 percent of cases where 
applications were processed using this up-front processing model. 
Moreover, according to the June 2005 CIS Ombudsman report, during the 
last weeks reported, the Dallas office was processing 71 percent of 
applications within 90 days, using the up-front processing model. 
Further, the Ombudsman's report indicated that USCIS issued fewer 
interim benefits using the up-front processing model--approximately 20 
percent of cases compared with approximately 85 percent nationally. 
Although the Dallas pilot showed improvements in adjustments of status 
within 90 days using the up-front model, USCIS raised several concerns 
during its evaluation, including concerns that (1) some inefficiencies 
resulted from the fact that information required to process 
applications was sometimes incomplete, as was the case when criminal 
history checks were not complete; (2) the pilot could not meet the 
Department of the Treasury's regulations requiring fees to be deposited 
within 24 hours; and (3) there were equity concerns because the pilot 
involved processing recently received applications before those filed 
earlier. 

Despite concerns USCIS raised in evaluating the Dallas pilot project, 
beginning in April 2005, USCIS began a phased implementation of up- 
front processing through its National Benefits Center central 
processing hub. Using elements of processes tested in the Dallas and 
New York pilot projects, USCIS has implemented up-front processing at 
three district offices--San Diego, San Antonio, and Buffalo--that did 
not have a backlog of adjustment of status applications when 
implemented. USCIS anticipates expanding the number of offices on a 
quarterly basis as they become current in their processing so that 
applicants with pending applications are not disadvantaged. The pilot 
in Dallas will also continue as long as USCIS determines that 
additional information may be gleaned and until the district office 
becomes current in processing applications. 

In March 2004, a third adjustment of status pilot for employment-based 
applications was implemented at the California service center. The 
focus was to adjudicate within 75 days petitions for immigrant workers 
with advanced degrees concurrently with the associated applications for 
adjustment of status. Included among the pilot's objectives were to (1) 
reduce the issuance of interim benefits to ineligible applicants, (2) 
identify frivolous and fraudulent filings designed to obtain interim 
benefits, and (3) reduce the number of additional background checks 
required for adjudication. This pilot identified eligible applications 
and initiated security checks as applications were filed. According to 
the pilot's subsequent evaluation report, when security checks were 
complete and no adverse information was detected, USCIS ordered 
permanent resident cards for these applicants.[Footnote 26] During this 
pilot, USCIS processed about 30 percent of immigration petitions and 25 
percent of adjustment of status applications within the target time 
frame. As with the other pilots, processing newly filed petitions and 
applications before those filed earlier was a concern. Additionally, 
USCIS expressed concern about the amount of time and resources required 
to manage the pilot, as well as the length of time it took the FBI to 
conduct background checks for aliens in certain high-tech occupations. 
Ultimately, USCIS deemed the pilot inefficient and adverse to the 
service center backlog elimination goals because resources were 
diverted from addressing backlogged cases. 

Among the recommendations proposed in its 2005 annual report to 
Congress, the CIS Ombudsman advocated that USCIS adopt the up-front 
processing model piloted in Dallas for all adjustment of status 
applications.[Footnote 27] The Ombudsman report states that overall the 
pilots show that up-front processing does work and is preferable to 
USCIS's current business processes because it can reduce workload, 
improve completion rates, enhance customer satisfaction and reduce 
issuance of interim benefits. However, according to USCIS officials, 
the report did not address the inefficiencies resulting from the delay 
of required information, the inability to meet the Department of the 
Treasury's deposit regulations, and the inequity of processing newer 
applications before those filed earlier that USCIS identified during 
the pilot. Moreover, USCIS officials said the agency does not plan to 
implement the up-front processing model at district offices with a 
backlog of adjustment of status applications, because of these 
concerns. 

The 2005 Ombudsman report also noted the indirect effect that reducing 
the backlog could have on the fee revenue on which USCIS services are 
based. For example, USCIS is required to provide an interim work permit 
to applicants whose applications for adjustment of status have not been 
adjudicated within 90 days. These interim work permits are valid for 
240 days. At their expiration, the applicant must apply, and pay a fee, 
for a renewal permit. This process could be repeated if the underlying 
application for adjustment of status continues unadjudicated. To the 
extent, however, that USCIS efforts are successful in reducing the time 
for adjudicating adjustment of status applications, the need for 
interim work permits will be correspondingly reduced, as will the fee 
revenue resulting from them. The Ombudsman's report does not estimate 
the extent of this lost revenue, but it does estimate that in fiscal 
year 2004, fee revenue from all work permit applications (not just 
interim permit applications) filed in connection with applications for 
adjustment of status totaled $135 million, approximately 10 percent of 
total USCIS revenue in that year.[Footnote 28] 

USCIS acknowledges that some revenue loss will result from its backlog 
elimination efforts. On the other hand, it expects that elimination of 
the backlog will reduce the need for staff assigned to this effort and 
consequently result in savings. As applications for interim benefits 
decline, savings in processing costs will be realized, although it is 
unknown whether they would be commensurate with the loss in 
revenue.[Footnote 29] According to USCIS, revenue loss estimates are 
under review. 

USCIS Developed a Staffing Model to Help Prevent Future Backlogs: 

In May 2005, USCIS finalized a staffing allocation model that addresses 
how many and where staff are needed to better match projected 
workloads. On the basis of this model, USCIS determined it must (1) 
retain the temporary adjudicators currently on hand (about 1,100) 
through the end of fiscal year 2006 and (2) fill vacancies to increase 
its level of permanent adjudicator staff by 27 percent (about 460) to 
maintain productivity and prevent future backlogs through fiscal year 
2007.[Footnote 30] According to USCIS, it is reasonable to assume that 
vacant permanent positions will be filled in large part from within the 
existing cadre of temporary adjudicators. 

The staffing allocation model also projects the alignment of personnel 
at each USCIS office through fiscal year 2007--one of the essential 
elements of USCIS's strategy to prevent future backlogs, according to 
the Associate Director for Operations. As previously discussed, USCIS's 
distribution of adjudicators across field offices does not match the 
distribution of the workload across field offices. To rectify this 
staffing imbalance, USCIS finalized a staffing allocation model in May 
2005 that addresses how many and where staff are needed to better match 
projected workloads. For example, because district offices in the 
eastern region have the smallest proportion of staff to workload, the 
staffing allocation model calls for about 37 percent of the total 
needed permanent positions (about 170) to be filled there. Figure 4 
shows the distribution of adjudicator staff in the regions and the 
service centers as of January 2005 compared with the proposed 
distribution that USCIS believes is required through fiscal year 2007 
to maintain productivity and prevent future backlogs. 

Figure 4: Adjudicator Staff Distribution Compared with USCIS's Proposed 
Redistribution: 

[See PDF for image] 

[End of figure] 

This kind of planning is consistent with the principle of integration 
and alignment that we have advocated as one of the critical success 
factors in human capital planning. As we have previously reported, 
workforce planning that is linked to strategic goals and objectives can 
help agencies be aware of their current and future needs such as the 
size of the workforce and its deployment across the organization. In 
addition, we have said that the appropriate geographic and 
organizational deployment of employees can further support 
organizational goals and strategies.[Footnote 31] 

USCIS has used a significant portion of its funds for backlog 
elimination efforts to hire and pay temporary adjudicators. According 
to USCIS's budget director, the agency's projected fee revenues and 
spending authority in fiscal year 2006 are sufficient to absorb the 
cost of additional permanent adjudicators called for in the staffing 
allocation model.[Footnote 32] Finally, USCIS officials said that the 
need for future staffing adjustments could be offset by future 
efficiencies gained during its transition to more robust information 
technology capabilities. We have previously reported that leading 
organizations consider how new initiatives, such as new technologies, 
affect human capital in their strategic workforce documents.[Footnote 
33] However, USCIS's current allocation staffing model does not 
consider these expected productivity gains. Reflection of these 
expected gains in its staffing allocation model should improve USCIS's 
ability to make strategic staffing decisions. 

To Help Prevent Future Backlogs, USCIS Has Proposed an Information 
Technology Transformation Plan: 

In a February 2004 hearing before the House Subcommittee on 
Immigration, Border Security, and Claims, USCIS Director Aguirre 
testified that "technology is, without a question, the only way we are 
going to get out of this horrible backlog that we have."[Footnote 34] 
Accordingly, USCIS has identified requirements for transforming its 
information technology by upgrading the agency's information technology 
capabilities to support the prevention of future backlogs and for other 
purposes. In March 2005, the Director of USCIS approved the agency's 
mission needs statement (MNS), and in April 2005, the DHS Joint 
Requirements Council approved the MNS,[Footnote 35] which outlines the 
purpose of technology transformation and the requirements to address 
deficiencies in its current information technology 
capabilities.[Footnote 36] The MNS focuses on three modernization 
efforts: (1) upgrading information technology infrastructure-- 
including improved desktops, servers and network computers; (2) 
creating an integrated foundation to support data management and 
business processes among multiple systems; and (3) developing new 
business processes--for example, the ability to adjudicate cases 
electronically. We have long been proponents of federal agencies having 
a strong Chief Information Officer (CIO) to address information and 
technology management challenges, and the Clinger-Cohen Act of 1996 
requires agency heads to designate CIOs to lead technology 
reforms.[Footnote 37] In April 2004, USCIS established an Office of the 
Chief Information Officer and in June 2005 began the process of 
aligning information technology under the CIO's authority. 

According to the MNS, the plan to transform USCIS's information 
technology will address several deficiencies in the agency's current 
information technology environment, including (1) inadequate ability to 
meet changing business requirements, (2) need for improved efficiency 
to maintain processing time goals and prevent the occurrence of 
backlogs, (3) inadequate information technology oversight and 
governance, (4) inconsistent access and data integrity controls, and 
(5) paper records systems that are not cost-effective and do not comply 
with the paperwork reduction act. Moreover, the MNS outlines several 
ways in which information technology transformation is intended to 
support the DHS strategic goals of prevention, service, and 
organizational excellence. For example, according to the MNS, by 
upgrading the technical infrastructure, USCIS can leverage the improved 
security features available in newer operating systems, thereby 
supporting the objective of the DHS prevention goal, which aims to 
ensure the security and integrity of the immigration system. 

According to the MNS, implementation of the information technology 
infrastructure is scheduled to be complete by fiscal year 2011. Prior 
to the proposed information technology program, USCIS had begun 
developing several information systems to enhance its information 
technology capabilities, which are reflected in the MNS. Among the 
systems are the Background Check Service, the Biometric Storage System, 
and an integrated case management system. These systems are designed to 
manage and automate security check information, to store and retrieve 
biometric data, and to manage case data in a paperless environment. 
Appendix III describes selected systems included in the MNS and their 
projected completion dates in greater detail. According to USCIS 
officials, as of September 2005, the MNS is being evaluated by the 
DHS's deputy secretary and is also awaiting review and approval by 
DHS's Investment Review Board. Although the transformation plan is 
still in the early stages of review, USCIS estimates this information 
technology modernization, as currently envisioned, will cost on a rough 
order of magnitude about $1.4 billion over 5 years. However, according 
to officials, the agency is revisiting this preliminary estimate to 
reflect recently completed business process reengineering efforts and 
budget realities. Moreover, USCIS has not yet settled on a funding 
strategy. The agency is considering a number of funding options such as 
temporarily raising fees, leveraging fees generated from new 
initiatives such as the proposed temporary worker program, and 
requesting appropriations, among other alternatives. 

The MNS does not include consideration of whether and to what extent 
the proposed technology transformation would be expected to have an 
effect on staffing levels and use. We have reported in our work on 
demonstrating results of information technology investments that 
leading organizations evaluate both the overall performance of the 
information technology function and the outcomes for individual 
technology investments.[Footnote 38] In addition, we have reported that 
high-performing, client-focused organizations must take into account 
relationships among people, processes, and technology.[Footnote 39] 
Further, significance in resource administration is one of the early- 
stage approval criteria listed in DHS's management directive on 
technology investments.[Footnote 40] Consideration of the expected 
productivity gains could help both the agency and Congress make 
informed decisions about the appropriate level and timing of investment 
in technology upgrades and staffing resource allocation. 

Despite Progress, USCIS Seems Unlikely to Eliminate the Backlog for All 
Application Types in Every Office by September 30, 2006: 

Although USCIS has made progress in reducing its backlog of benefit 
applications as it defines backlog, it seems unlikely that USCIS will 
meet its September 30, 2006, goal of reducing the number of pending 
applications to a level no greater than the previous 6 months' receipts 
for every form type at every office. It will be particularly difficult 
for USCIS to meet the progressively more ambitious targets it has set 
for completing some of the more complex benefit applications-- 
specifically for applications for adjustment of status and applications 
for naturalization[Footnote 41]--by September 30, 2006. Furthermore, 
although USCIS officials have stated that the agency has sufficient 
staff resources to process its overall projected workload by the end of 
fiscal year 2006, in certain offices, where the volume of applications 
exceeds adjudicator staff capacity, the backlog may remain. 
Additionally, external factors beyond USCIS's immediate control may 
limit the feasibility of achieving its goal, such as the need for 
extended background checks, availability of entry visas, and possible 
legislative changes. 

USCIS Met Targets for Processing Pending Applications in 2004, but May 
Have Difficulty Meeting More Ambitious Targets for Fiscal Year 2006 for 
the Two Most Complex Application Types: 

USCIS met all of its 2004 targets for processing its workload of 
pending applications and as of June 30, 2005, was showing progress 
toward meeting its workload targets for fiscal year 2005 for most 
application types. However, performance so far indicates it may have 
difficulty achieving the much more ambitious targets it set for fiscal 
year 2006 for at least two of the more complex application types. To 
ensure progress toward meeting its goal of achieving a pending workload 
of applications no greater than the number of applications it received 
during the previous 6 months, USCIS established progressively more 
stringent targets. For the application types included in the backlog 
elimination plan, table 4 shows the size of USCIS's workload--that is, 
the months of receipts pending adjudication--as of June 2005, the 
latest available data, and the workload targets established for fiscal 
years 2004 through 2006.[Footnote 42] 

Table 4: Months of Receipts Pending as of June 2005 Compared with 
Targets by Application Type for Fiscal Years 2004, 2005, and 2006: 

[See PDF for image] 

[A] For the purposes of reporting progress toward meeting workload 
targets, USCIS reports progress on I-130 petitions in these two 
groupings. 

[B] The I-131 form is used for applications for advance parole as well 
as for applications for refugee travel documents and applications for a 
reentry permit. For the purposes of backlog elimination progress 
reporting, USCIS is using these two groupings in reporting progress on 
this form type. 

[End of figure] 

As of June 2005, USCIS had met or exceeded its fiscal year 2005 
workload processing time targets for 10 of 15 application types (see 
solid circles in table 4). In fact, for 8 of these application types, 
USCIS met or exceeded its fiscal year 2006 targets (see solid circles 
in table 4). In addition, as figure 5 shows, USCIS has made progress in 
reducing its backlog--from a peak of about 3.8 million applications in 
January 2004 down to about 1.2 million in June 2005. Since October 
2003, completions have generally outpaced receipts, contributing to 
backlog reduction.[Footnote 43] However, the sharp drop in the backlog 
is due to USCIS's decision in July 2004 to remove from its backlog 
count those 1.15 million cases for which an immigration visa is not 
immediately available and a benefit cannot be provided. Nevertheless, 
August 2004 was USCIS's most productive month, with completions 
exceeding receipts by 138 percent. 

Figure 5: Numbers of Applications Received, Completed, and Backlogged, 
March 2003 through June 2005: 

[See PDF for image] 

[End of figure] 

USCIS's productivity notwithstanding, workload processing targets for 
two of the more complex application types appear to be rather ambitious 
in light of the agency's performance through June 2005. For example, 
figures 6 and 7 show a substantial drop in targets for reducing pending 
adjustments of status to lawful permanent resident and reflect the 
challenge USCIS faces to meet fiscal year 2005 targets for applications 
for naturalization. According to USCIS, these two application types 
require the most effort and, as of June 2005, constituted more than 
three-quarters of the remaining backlog of 1.2 million applications. 

As figure 6 shows, USCIS has made progress toward reducing its pending 
applications to adjust status to lawful permanent resident to 15 months 
for fiscal year 2005. However, the workload target for fiscal year 2006 
drops dramatically to 6 months. Further, USCIS estimates it has a 
backlog of about 600,000 of this application type as of June 2005, 
which represents the largest number of applications in the backlog. 

Figure 6: Pending Workload and Workload Targets for Applications for 
Completing Adjustment of Status to Lawful Permanent Resident (Form I- 
485): 

[See PDF for image] 

[End of figure] 

As shown in figure 7, although the difference between 2005 and 2006 
workload targets for applications for naturalization is not as 
pronounced, it is still ambitious, particularly since USCIS appears to 
be struggling to reduce its pending workload to 10 months by the end of 
fiscal year 2005. Moreover, USCIS estimates it has a backlog of about 
290,000 of this application type as of June 2005, which represents the 
second largest number of applications in the backlog. 

Figure 7: Pending Workload and Workload Targets for Completing 
Applications for Naturalization (Form N-400): 

[See PDF for image] 

[End of figure] 

If meeting its targeted workload is a reliable indicator of USCIS's 
ability to meet its September 30, 2006, goal, then its progress through 
June 2005 and the more ambitious targets that must be achieved for 
these two application types raises doubts about USCIS's ability to meet 
the ultimate goal of reducing its pending number of these application 
types to a level that can be adjudicated within 6 months by September 
30, 2006. 

Further, our analyses indicate that to eliminate the backlog for these 
two application types, USCIS would need to complete significantly more 
applications than it has in the past. Specifically, during the most 
recent 15 months for which data were available (April 1, 2004, to June 
30, 2005), USCIS completed about 800,000 applications for adjustment of 
status. According to USCIS's projections, it must complete another 1.3 
million (about 69 percent more) in the 15 months between July 1, 2005, 
and September 20, 2006, to eliminate the backlog of this application 
type by the deadline. Similarly, USCIS completed about 800,000 
applications for naturalization during the most recent 15 month period 
and must more than double that level and complete another 1.8 million 
naturalization applications (an increase of about 124 percent) during 
the following 15 months to eliminate the backlog of this application 
type. 

USCIS's Calculation of Backlog Elimination Is Agencywide, but Does Not 
Address All Application Types in All Locations: 

USCIS's calculation of its backlog provides an estimate of the number 
of applications on an agencywide basis that exceed the number of 
applications received over the last 6 months, rather than in each 
location. When USCIS's agencywide data reflect that it has eliminated 
the agencywide backlog for a certain application type, it may not be an 
indication that this backlog has been eliminated at every location. 
USCIS officials told us that even if they report that they have 
eliminated the agencywide backlog by the end of fiscal year 2006, it is 
possible that backlogs (i.e., pending applications representing more 
than 6 months' worth of receipts) of certain application types could 
remain at certain field locations. For example, as of June 2005, USCIS 
data indicated that, on an agencywide basis, a backlog no longer 
existed for seven types of benefit applications: applications for (1) 
renewing or replacing a lawful permanent resident card, (2) travel 
documents, (3) extending or changing status, (4) employment 
authorization, (5) temporary protected status, and petitions for (6) 
nonimmigrant workers and (7) immigrant workers. However, upon closer 
examination of the data, backlogs remained for five of these 
application types at specific locations. Specifically, as of June 2005, 
a backlog of applications to renew a lawful permanent resident card and 
applications for temporary protected status (about a dozen each) 
remained at the Vermont and Nebraska service centers, respectively. 
Moreover, a backlog of nearly 3,000 applications for travel documents 
remained across a dozen district offices combined and nearly 2,500 
remained at the Nebraska service center alone. Similarly, nearly 2,000 
applications for employment authorization remained across nine district 
offices combined and nearly 70,000 remained at the California service 
center alone. Finally, a backlog of about 3,000 petitions for immigrant 
workers remained at the California and Nebraska service centers 
combined. 

Backlogs Could Remain at Understaffed Offices: 

According to USCIS, it has the staffing capacity agencywide to address 
the backlog, but some benefit applications in offices where volume 
exceeds adjudicator capacity may require more than 6 months to process, 
causing backlogs to remain beyond September 30, 2006. USCIS estimates 
that it will have to complete about 10 million benefit applications 
between July 1, 2005, and September 30, 2006, to retire the backlog and 
reduce its pending applications, on average, to a level that can be 
processed within 6 months or less.[Footnote 44] According to the Deputy 
Associate Director for Operations, the agency's staffing level as of 
June 2005--about 3,100 permanent and temporary adjudicators and 
information officers--should be adequate to retire the backlog. 
However, the distribution of adjudicators across field offices does not 
match the current distribution of the workload across field offices. A 
reason for this staffing imbalance, according to USCIS officials, is 
that the agency hired temporary adjudicators for all district offices 
to concentrate on adjudicating forms in the backlog while permanent 
adjudicators could focus attention on adjudicating new petitions for 
alien relatives and prospective spouses and related applications for 
adjustment of status to lawful permanent resident under the Legal 
Immigration Family Equity (LIFE) Act.[Footnote 45] However, USCIS 
officials said that the anticipated volume of LIFE Act applications and 
petitions never materialized in district offices in the central and 
western regions. 

Unless the agency is successful in redistributing its adjudicator 
staff, it appears that backlogs are likely to remain at understaffed 
field offices in the eastern region in fiscal year 2007. According to 
the Deputy Associate Director for Operations, USCIS has too few 
adjudicators at district offices in the eastern region to address the 
workload, while district offices in the central and western regions 
have excess adjudicator staff. Figure 8 shows the distribution of 
workload to adjudicators across regions. 

Figure 8: Projected Workload in Hours, by Region, July 2005 through 
September 2006 Compared with Distribution of Available Adjudicator 
Hours as of June 2005: 

[See PDF for image] 

[End of figure] 

Other Factors May Hinder USCIS's Ability to Complete Certain 
Applications within 6 Months: 

Factors beyond the agency's control could prevent some applications 
from being adjudicated within 6 months. For example, some applications 
may require longer to adjudicate because of factors such as (1) the 
need for more extensive background checks for certain applicants, (2) 
annual limitations on certain visas, and (3) legislative changes. 

Background Checks: 

USCIS performs a background check on all benefit applicants via its 
Interagency Border Inspection System (IBIS). Adjudicators said they can 
normally perform these checks on their desktop computers in a matter of 
minutes, a process we observed at the Houston district office. For 
selected immigration benefit applications, USCIS requires additional 
background information from fingerprint checks and name checks 
performed by the FBI. Officials from the FBI said they can normally 
check fingerprint records in about 24 hours or less and return the 
results to USCIS in batch format about two times a week. The FBI 
results either indicate no record of a criminal history or provide the 
applicant's criminal history record. 

However, FBI name checks can be far more involved and take more than 6 
months to complete. For example, when an applicant's name matches the 
name or alias of someone with a criminal history, the FBI is to perform 
a secondary check of multiple databases, which can take up to a month 
to complete. A small percentage of cases have to be subjected to a more 
intensive file review, which can take more than 6 months. For example, 
USCIS found an example where it took the FBI nearly 2 years to complete 
a name check for a naturalization applicant. Table 5 summarizes the 
types of background checks required for those forms included in USCIS's 
backlog elimination plan. 

Table 5: Summary of Background Checks Required for Selected Benefit 
Applications: 

Form: I-485; 
Application type/purpose(s): Adjustment of status; 
IBIS check: Yes; 
FBI fingerprint check: Yes; 
FBI name check: Yes. 

Form: I-129; 
Application type/purpose(s): Nonimmigrant worker; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Form: I-539; 
Application type/purpose(s): Extend/change nonimmigrant status; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Form: I-90; 
Application type/purpose(s): Replacement green card; 
IBIS check: Yes; 
FBI fingerprint check: Yes; 
FBI name check: No. 

Form: I-130; 
Application type/purpose(s): Petition for alien relative; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Form: I-131; 
Application type/purpose(s): Advance parole; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Application type/purpose(s): Reentry permit; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Form: I-140; 
Application type/purpose(s): Immigrant worker; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Form: I-751; 
Application type/purpose(s): Removal of conditional status; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Form: I-765; 
Application type/purpose(s): Employment authorization document; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Form: I-821; 
Application type/purpose(s): Temporary protected status; 
IBIS check: Yes; 
FBI fingerprint check: Yes; 
FBI name check: No. 

Form: N-400; 
Application type/purpose(s): Naturalization; 
IBIS check: Yes; 
FBI fingerprint check: Yes; 
FBI name check: Yes. 

Form: N-600/N-643; 
Application type/purpose(s): Certificate of citizenship; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Form: I-589; 
Application type/purpose(s): Asylum; 
IBIS check: Yes; 
FBI fingerprint check: Yes; 
FBI name check: Yes. 

Form: I-881; 
Application type/purpose(s): NACARA 203; 
IBIS check: Yes; 
FBI fingerprint check: Yes; 
FBI name check: Yes. 

Form: I-867; 
Application type/purpose(s): Credible fear referral; 
IBIS check: Yes; 
FBI fingerprint check: No; 
FBI name check: No. 

Source: Compiled from USCIS information. 

[End of table] 

According to our analysis of about 670,000 naturalization applications 
filed between February 2004 and February 2005, the FBI returned about 
59 percent of the names within 10 days, and 72 percent were returned 
within 30 days. About 11 percent of the applications (more than 74,000) 
took more than 90 days to complete. Further, about 7 percent of these 
naturalization applicants (more than 44,000) had not received a final 
response as of February 28, 2005. Until these name checks are 
completed, applications cannot be finally adjudicated. In addition, 
USCIS officials said that it often takes a long time (as much as 4 to 6 
months) to clear the names of immigrant workers with high- tech 
backgrounds who are applying to change their status to lawful permanent 
resident, because, since September 11, the FBI has become especially 
interested in carefully vetting aliens with such backgrounds. 

Visa Limitations for Immigrants: 

The availability of visas issued by the Department of State will not 
affect the backlog as defined by USCIS because USCIS excludes from its 
count of backlog those cases for which a visa is not available. 
However, it may result in some applicants having to wait much longer 
than 6 months before their benefit is adjudicated. In order to initiate 
a visa request to have an alien relative or prospective employee 
immigrate to the United States, a qualifying relative or employer must 
file a petition with USCIS on behalf of the immigrant. Section 201 of 
the Immigration and Nationality Act sets effective annual limits of 
226,000 visas for family-sponsored immigrants and approximately 148,000 
visas for employment-based immigrants.[Footnote 46] In addition, the 
act sets preference levels for both family-based and employment-based 
immigrants, which further determine which applicants receive priority 
for a visa.[Footnote 47] Further, section 203(e) of the act states that 
family-sponsored and employment-based preference visas should be issued 
to eligible immigrants in the order in which a petition on behalf of 
each was filed with USCIS.[Footnote 48] There are also annual numerical 
limitations on the number of visas that can be allocated per country 
under each of the preference categories.[Footnote 49] Thus, even if the 
annual limit for a preference category has not been exceeded, visas may 
not be available to immigrants from countries with high rates of 
immigration to the United States, such as China and India, because of 
the per country limits. Table 6 lists the types and allocation limits 
of visas for family-and employer-sponsored immigrants. 

Table 6: General Preferences for Immigration Visas and Allocation 
Limits for Fiscal Year 2005: 

Preferences: First; 
Family-sponsored immigrants: Unmarried sons and daughters of 
citizens[A]; 
Limits (percent): 23,400 (10.4); 
Employment-based immigrants: Priority workers; 
Limits (percent): 42,456 (28.6). 

Preferences: Second; 
Family-sponsored immigrants: Spouses and children, and unmarried sons 
and daughters of permanent residents; 
Limits (percent): 114,200 (50.5); 
Employment-based immigrants: Members of the professions holding 
advanced degrees or persons of exceptional ability; 
Limits (percent): 42,456 (28.6). 

Preferences: Third; 
Family-sponsored immigrants: Married sons and daughters of citizens; 
Limits (percent): 23,400 (10.4); 
Employment-based immigrants: Skilled workers, professionals, and other 
workers; 
Limits (percent): 42,456 (28.6). 

Preferences: Fourth; 
Family-sponsored immigrants: Brothers and sisters of adult citizens; 
Limits (percent): 65,000 (28.7); 
Employment-based immigrants: Certain special immigrants; 
Limits (percent): 10,540 (7.1). 

Preferences: Fifth; 
Family-sponsored immigrants: Not applicable; 
Employment-based immigrants: Employment creation; 
Limits (percent): 10,540 (7.1). 

Total; 
Limits (percent): 226,000 (100); 
Limits (percent): 148,449 (100). 

Source: Department of State, Visa Bulletin for September 2005, No. 85, 
Volume VIII. 

Note: Totals may not add because of rounding. 

[A] Spouses and prospective spouses of U.S. citizens are not subject to 
these visa limits. 

[End of table] 

Until an alien obtains an immigrant visa and enters the United States, 
or an alien already in the United States is able to adjust his or her 
status, the immigrant will not be able to become a lawful permanent 
resident. The actual petitions for alien relatives (I-131) or immigrant 
workers (I-140) can be filed with and adjudicated by USCIS at any time, 
regardless of the availability of visa numbers. However, USCIS may not 
adjudicate any pending applications for adjustment of status to lawful 
permanent resident (I-485) when visa numbers have been exhausted for 
the particular preference category or country. Since visas must be 
issued on a first-come, first-served basis within each priority 
category, applicants may be inclined to file an application to adjust 
status knowing they may remain ineligible for a benefit for many years. 
For example, in September 2005, the Department of State was issuing, 
under the general family-based preference limits, visas for unmarried 
sons and daughters of citizens whose petitions were filed with USCIS on 
or before April 15, 2001, and for brothers and sisters of adult 
citizens whose petitions were filed with USCIS on or before December 
15, 1993.[Footnote 50] In these situations, USCIS may not adjudicate 
any pending adjustment applications until visa numbers become available 
for those applicants and may have to hold such applications for several 
years. 

These kinds of delays in adjudication of pending adjustment of status 
applications for family-sponsored immigrants may continue to grow 
because of a demand that may continue to exceed the number of available 
visas each year. In fiscal year 2004, USCIS received nearly 700,000 
petitions for alien relatives--more than three times the amount of 
available annual visas. Additionally, as of June 2005, USCIS had 
received another 484,000 petitions for alien relatives that add to the 
152,000 pending petitions. According to USCIS officials, 2005 is the 
first year in which the agency has adjudicated a number of employment- 
based petitions and ensuing applications for adjustment of status up to 
the annual visa cap. As a result, USCIS will start the next fiscal year 
with a queue of pending petitions that has the potential of resulting 
in an adjudications backlog of employment-based immigration adjustment 
of status applications. 

Legislative Changes: 

USCIS officials noted that its current backlog elimination plan is 
based on the assumption that the agency will continue to operate under 
current laws. These officials noted, however, that if any new 
legislation is enacted between now and the end of fiscal year 2006 
without provisions for resources to carry out new responsibilities, the 
agency's ability to eliminate the backlog could be compromised. For 
example, USCIS officials told us that the REAL ID Act of 2005[Footnote 
51] has recently added to USCIS's workload by, among other things, 
increasing the number of persons eligible to apply for and receive 
nonimmigrant worker status for temporary nonagricultural workers and 
foreign investors, as well as adding an expanded and more complex 
ground of inadmissibility relating to terrorism that must be addressed 
as part of the adjudication of many immigration benefit 
applications.[Footnote 52] In addition, the act does not provide 
additional resources to carry out these activities. 

USCIS Lacks a Comprehensive Approach to Postadjudication Quality 
Assurance: 

USCIS operates two distinct postadjudication quality assurance 
programs, but neither provides a comprehensive review of the agency's 
efforts to ensure that immigration benefits are granted only to persons 
eligible to receive them.[Footnote 53] Both of USCIS's major quality 
assurance programs are limited to a small number of application types 
they review and, taken together, the programs do not review all 15 of 
the major application types included in the backlog elimination plan. 
One program measures quality by assessing adjudicator compliance with 
standard operating procedures used in adjudicating two application 
types, but it does not determine the reasonableness of the final 
adjudicative decision. The other program measures both compliance with 
standard operating procedures and the reasonableness of adjudicator 
decisions for selected application types. Although supervisory reviews 
of cases are conducted at the local office level, the reviews lack a 
standardized approach across all offices. USCIS is currently reviewing 
its quality assurance procedures and plans to improve the metrics used 
to measure quality agencywide. 

USCIS's Agencywide Quality Assurance Program Tracks Process Compliance 
for Two Application Types: 

USCIS's Performance Management Division administers an agencywide 
quality assurance program, which reviews adjudicator compliance with 
selected processes for adjudicating 2 of the 15 major application 
types: applications for naturalization and for adjustment of status to 
lawful permanent resident. The review is restricted to compliance with 
standard operating procedures and does not evaluate the reasonableness 
of the final adjudicative decisions. The program began in 1997 in 
response to media criticism about the integrity of its naturalization 
application processing and was developed to improve the quality and 
consistency of naturalization application processing by ensuring that 
immigration laws, regulations, policies, and operating guidance are 
adhered to during the adjudication process. In February 2005, USCIS 
expanded its quality assurance review to include adjustments of status. 

To conduct its reviews, the performance management staff selects a 
sample of applications completed during a given month and available at 
the selected district office or service center. (Completed applications 
are not stored in district offices and service centers.) In general the 
number of cases sampled depends upon the number of applications 
processed in a given month, and a sample of cases is chosen from the 
applications that are available.[Footnote 54] USCIS's Performance 
Management Division staff uses a standardized series of questions to 
determine the extent to which adjudicators have followed the required 
processes.[Footnote 55] The staff records the results and sends them to 
the adjudicative staff for correction. The quality assurance review of 
naturalization applications covers critical processes and non-critical 
processes. Critical processes are generally those that relate to 
security procedures, for example documenting fingerprints, IBIS checks, 
and name checks. Non-security-related processes such as marking 
approved applications with an approval stamp are generally considered 
noncritical processes. Figure 9 shows that for the sample of 
naturalization applications that were reviewed during fiscal year 2004 
and the first and second quarters of fiscal year 2005, USCIS exceeded 
the critical and noncritical processing accuracy goals of 99 percent 
and 96 percent respectively. 

Figure 9: Processing Accuracy Rates for the Naturalization Quality 
Procedures for Cases Reviewed in Selected Offices and Centers, Fiscal 
Years 2004 and 2005, First and Second Quarters: 

[See PDF for image] 

[End of figure] 

The review of adjustment of status applications, like the review of 
naturalization applications, includes security system checks and checks 
on adjudication processes, but only reports an overall processing 
accuracy rate, not the processing accuracy rates for critical 
processes. USCIS's quality assurance reviews reported an overall 
agencywide processing accuracy rate of 98.5 percent for the sample of 
cases examined for the period January 2005 through March 2005.[Footnote 
56] A study conducted by an independent management consultant, using 
sampling methods similar to those USCIS uses to assess adjudicator 
compliance with standard processes, produced similar results as USCIS 
for naturalization and lower results for adjustment of status 
applications.[Footnote 57] For example, the consultant found that the 
overall processing accuracy rate for naturalization applications was 
over 98 percent for the cases reviewed at selected district offices. 

USCIS's Service Center Quality Assurance Program Tracks Process 
Compliance and Evaluates Reasonableness of Adjudication Decisions: 

Since April 2002, USCIS's Service Center Operations Division has 
performed quality assurance reviews designed to evaluate the quality 
and correctness of adjudicative decisions for selected benefit 
applications filed exclusively at service centers. This quality 
assurance review uses the same guidance as the agencywide program to 
select cases to review. In general the number of cases sampled depends 
upon the number of applications processed in a given month, and a 
sample of cases is chosen from the applications that are available. Two 
application types were selected for the initial review--first, 
applications for adjustment of status and, 6 months later, applications 
to extend or change nonimmigrant status. Subsequently, the service 
center added other application types to its review including petitions 
for alien relatives and petitions for nonimmigrant workers. 

For this review, a sample of case files is selected and independently 
reviewed by the quality assurance unit. The review selects cases based 
on three types of adjudicative decisions: (1) approvals, (2) denials, 
and (3) requests for evidence. Each case file is evaluated for 
compliance with processes and procedures and completeness of the 
administrative actions. In addition, the reviewer evaluates the 
reasonableness of the decision outcome--that is, whether he or she 
would have made the same decision given the evidence provided. The 
Service Center Operations Division has developed a series of 
standardized checklists that is used for reporting purposes.[Footnote 
58] When errors are detected in the review, such as when an IBIS check 
is marked as valid on the checklist when in fact the IBIS check had 
expired, service center guidance indicates that corrective actions 
should be taken. For example, if an erroneous decision was identified 
during the review of an approved case, the corrective action could 
result in the cases being reopened and the benefit being rescinded. The 
guidance further indicates that after the initial quality assurance 
reviews, a small sample of previously reviewed cases should be checked 
a second time by a separate reviewer to validate the initial results. 

The Service Center Operations Division develops a quality level 
indicator by calculating the number of correct decisions identified 
among the total number of cases reviewed. According to USCIS, the 
emphasis of the program is on using trend analyses to identify and 
address weaknesses in administrative decision making rather than 
meeting a specific performance target. In fiscal year 2004, the Service 
Center Operations Division reviewed three forms--employment-based 
applications for adjustment of status, applications to extend or change 
nonimmigrant status, and petitions for alien relatives. The rates of 
correct decisions for the forms reviewed were 94.3 percent, 95.7 
percent, and 93.5 percent respectively. In the first two quarters of 
the fiscal year 2005, in addition to continuing the reviews of 
adjustments of status and petitions for alien relatives, USCIS added 
petitions for nonimmigrant workers. The rate of correct decisions for 
reviewed applications of this type was 98 percent for the period 
January 2005 through April 2005. 

USCIS Supervisors Review Quality of Staff Adjudications: 

Aside from these two quality assurance programs, USCIS also checks 
quality through supervisory reviews of case files at the local office 
level. However, these reviews are not consistently performed across all 
local offices. For example, some local offices, such as the San Antonio 
district office, perform supervisory reviews of all cases awaiting 
adjudication, as well as a group of adjudicated cases, while others, 
such as the Texas service center, may perform supervisory reviews of 
all cases adjudicated by new staff. 

USCIS Is Reviewing Its Quality Assurance Programs: 

The independent review of USCIS's quality assurance program, discussed 
previously, made a number of recommendations to improve the agency's 
programs; among them, that the Performance Management Division's 
quality assurance program include application types not currently part 
of the program to determine their level of compliance with adjudicative 
procedures. In addition it recommended that that USCIS focus fewer 
resources on naturalization applications in offices that consistently 
meet the quality goal and spend resources on the new adjustment of 
status application review because the review shows compliance was lower 
for this application. According to USCIS guidance, the agency planned 
to progressively include other application types and operations in its 
quality assurance approach, but the agency has not established specific 
strategies and timelines for doing so. According to agency officials, 
USCIS is in the process of collecting and validating data on the 
current inventory of quality assurance measurements in use throughout 
USCIS. After the validation process, they plan to analyze this 
information to identify gaps and areas of improvement. USCIS plans to 
design, develop, and test a draft set of proposed quality metrics. 
USCIS plans to have a final set of quality metrics available by 
December 2005, which the agency says will reflect several dimensions of 
quality including accuracy, consistency, timelines, efficiency, 
customer service and production. 

Conclusions: 

USCIS intends to address deficiencies in its current information 
technology systems through technology transformation, including the 
development of a new, integrated case management system capable of 
providing managers reports on the actual age of pending immigration 
benefit applications. Under USCIS's current method for calculating 
backlog, it is possible for individual applicants to wait longer than 6 
months for a benefit decision, even if the backlog for that benefit 
type has technically been eliminated. USCIS's proposed technology 
transformation should have the capability to provide information about 
the actual number of applications that have been pending for more than 
6 months so that the agency is able to define its backlog consistently 
with the statutory definition of any application pending adjudication 
for more than 180 days. 

USCIS has made substantial progress toward its goal of reducing its 
backlog of benefit applications and may eliminate much of the backlog 
by September 30, 2006. In addition to efforts to eliminate the current 
backlog, it is important for the agency to take steps to prevent future 
backlogs. The agency's ambitious technology transformation plan 
promises to meet this need by moving the agency from a manual, paper- 
driven process to an automated, paperless adjudication environment. As 
USCIS strives to become a high-performing, client-focused organization, 
it must take into account relationships among people, processes, and 
technology. For example, one of the assumptions underlying technology 
transformation is that it will facilitate more efficient, streamlined 
processes, which in turn could yield productivity gains, thus allowing 
more work to be accomplished without added staff resources. The agency 
has not identified these potential effects in its staffing and 
technology plans. Considering these relationships and including them in 
operational and strategic plans would give USCIS a sound basis for 
making strategic decisions regarding resource allocation. Without such 
information, Congress cannot be assured that the agency's investments 
in information technology will contribute to maximizing productivity 
and preventing future backlogs. 

At present, USCIS's quality assurance efforts do not comprehensively 
assess the adjudicative process and its outcomes, nor do they address 
all benefit application types. While USCIS has taken steps and has 
other steps planned to identify and address shortcomings in its quality 
assurance program, it has not yet developed the specific performance 
measures and goals needed to ensure consistent quality of adjudication 
across all components of the adjudication process. As a result, the 
agency cannot be assured that all benefit applications are adjudicated 
in compliance with agency guidance and that reasonable decisions are 
rendered on a consistent basis. 

Recommendations for Executive Action: 

To help determine the size of its backlog in a manner consistent with 
the definition in the Immigration Services and Infrastructure 
Improvements Act of 2000, we recommend that the Secretary of Homeland 
Security direct the Director of USCIS to develop and implement the 
capability to produce management reports on the actual age of 
individual benefit applications as soon as practicable in its long-term 
technology transformation process. 

To help ensure that USCIS has the information necessary to make sound 
strategic decisions regarding resource allocation--including staffing 
allocation and investment in technology transformation--and to inform 
Congress about expected gains from investments in technology, we 
recommend that the Secretary of Homeland Security direct the Director 
of USCIS to take the following two actions: 

* identify potential productivity gains and their effects on preventing 
future backlogs and: 

* identify the potential effects of technology improvements on its 
staffing allocation plans. 

To improve its quality assurance efforts and to help ensure that 
benefits are provided only to eligible individuals, we recommend that 
the Secretary of Homeland Security direct the Director of USCIS to 
modify its quality assurance programs to address both adjudication 
process compliance and reasonableness of adjudicator decisions and 
expand coverage to all types of benefit applications. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Department of Homeland 
Security for review. On November 8, 2005, we received written comments 
on the draft report, which are reproduced in full in appendix VII. The 
department concurred with the findings and recommendations in the 
report, and agreed that efforts to implement our recommendations are 
useful for ensuring that USCIS provides decision makers with full and 
adequate information. Specifically, the department said that USCIS's 
proposed case management system will provide the capability to produce 
management reports on the actual age of individual benefit 
applications. In addition, the department said USCIS is currently 
piloting several initiatives to increase productivity and efficiency 
and will continue to seek opportunities and methods to streamline 
processes and increase productivity while maintaining integrity and 
security of the adjudicative process. The department also said that 
USCIS is committed to analyzing staffing allocation levels twice yearly 
to ensure that resources are properly aligned with its workload. 
Moreover, as process and technology improvements are realized, resource 
allocations will be changed to fit the conditions. Finally, the 
department said that USCIS has begun to develop a comprehensive quality 
management program intended to develop a set of quality performance 
measures to assess servicewide performance for all benefit application 
types. These measures will address both process compliance and the 
quality of adjudicators' decisions. The department also provided 
technical comments on our draft report, which we incorporated where 
appropriate. 

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 date of this report. At that time, we will send copies of this 
report to the Secretary of the Department of Homeland Security and the 
Director of United States Citizenship and Immigration Services. In 
addition, the report will be available at no charge on GAO's Web site 
at http://www.gao.gov. 

If you or your staff have any questions about this report or wish to 
discuss it further, please contact me at (202) 512-8777 or at 
JonesPL@gao.gov. Key contributors to this report are listed in appendix 
VII. 

Sincerely yours, 

Signed by: 

Paul L. Jones: 
Director, Homeland Security and Justice Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

During our review, we interviewed United States Citizenship and 
Immigration Services (USCIS) officials in headquarters from a number of 
divisions, including the offices of Budget, Field Operations, Service 
Center Operations, Records Services, Modernization Services, Asylum 
Division, Performance Management, and Administrative Appeals. We also 
spoke with the USCIS Chief Information Officer and officials in the 
Office of the Citizenship and Immigration Services Ombudsman. In 
addition, we spoke with officials from Immigration and Customs 
Enforcement, as well as a stakeholder group that frequently interacts 
with USCIS, the American Immigration Lawyers Association. We visited 
and interviewed officials in 10 USCIS field offices--the California 
service center, in Laguna Niguel; the Texas service center, in Dallas; 
the National Benefits Center, near Kansas City; district offices in 
Dallas, Houston, Los Angeles, San Antonio, San Diego, and Washington, 
D.C; and the Los Angeles asylum office. We selected these offices 
because they constituted a cross section of field offices that (1) were 
handling large, medium, and small volumes of applications and 
petitions; (2) were overstaffed and understaffed; (3) had backlogs of 
applications or petitions or no backlogs; and (4) had conducted or were 
conducting some of the pilot projects. Because we selected a 
nonprobability sample of field offices to visit, the results from our 
interviews with USCIS officials in these offices cannot be generalized 
to USCIS offices nationwide.[Footnote 59] 

To determine the status of USCIS's backlog of pending benefit 
applications, we interviewed agency officials and reviewed USCIS's 
backlog elimination plans and updates along with the agency's 
supporting analyses and compared them with the statutory definition of 
backlog in the Immigration Services and Infrastructure Improvements Act 
of 2000. 

To determine the actions USCIS has taken to eliminate the backlog of 
applications and prevent future backlogs, we reviewed USCIS's planning 
documents on the agency's staffing, budget, and information technology 
modernization. We also reviewed evaluation reports on process 
streamlining initiatives and pilot projects, as well as interviewing 
appropriate USCIS officials. Where possible, we corroborated their 
responses with agency data that we assessed for reliability and 
determined were sufficiently reliable for our purposes. 

To estimate the likelihood that USCIS would eliminate the backlog by 
September 30, 2006, we tracked and compared the agency's progress in 
reducing its workload with the targets USCIS established. We also 
analyzed workload and staffing data from the agency's Performance 
Analysis System, the official system of record used to manage the 
agency's backlog elimination efforts. We reviewed existing information 
about the data and the system that produced them, including procedures 
for ensuring accuracy. We also interviewed USCIS staff in the 
Performance Management Division regarding the collection and analysis 
of the workload data and determined that the data were sufficiently 
reliable for the purposes of this report. In addition, we reviewed 
USCIS's backlog elimination progress reports and staffing analysis 
model that were derived from the Performance Analysis System. We also 
collected and analyzed information on factors that could affect USCIS's 
ability to eliminate the backlog, including the duration of Federal 
Bureau of Investigation (FBI) name checks for naturalization 
applications, visa allocation limits, and new legislation. We analyzed 
data on FBI name checks obtained from USCIS's Computer Linked 
Application Information Management System (CLAIMS 4). We assessed the 
reliability of CLAIMS 4 data by (1) performing electronic testing of 
the required data elements for obvious errors in accuracy and 
completeness, (2) reviewing related documentation, and (3) interviewing 
USCIS staff knowledgeable about the CLAIMS 4 system and obtaining 
answers to written questions about the system, and we determined that 
these data were sufficiently reliable for our purposes. We also 
reviewed information on visa allocation limits from the Department of 
State and spoke with USCIS officials in the Office of Operations and 
the Office of Fraud Detection and National Security. Finally, we 
discussed with USCIS officials the effects the REAL ID Act of 2005 had 
on the adjudications workload as an example of how new legislation 
without the provision of additional resources could take adjudicator 
staff resources away from backlog elimination efforts.[Footnote 60] 

To determine how USCIS ensures the quality and consistency of 
adjudicator decisions, we interviewed USCIS officials in the 
Performance Management Division. We reviewed USCIS reports and data on 
accuracy rates related to its two quality assurance programs. We also 
reviewed the findings and recommendations of an independent study on 
USCIS's quality assurance programs. Finally, we discussed supervisory 
review practices with senior managers at the field offices we visited. 
However, we did not independently verify the extent and quality of 
supervisory review. 

We conducted our work from September 2004 through October 2005 in 
accordance with generally accepted government auditing standards. 

[End of section] 

Appendix II: USCIS Organizational Structure: 

USCIS carries out its service function through a network of field 
offices consisting of a National Benefits Center, 4 service centers, 78 
district and local offices, 31 international offices, 8 asylum offices, 
and 129 application support centers. 

* USCIS's National Benefits Center,[Footnote 61] located in Missouri, 
was created in April 2003 to serve as a central processing hub for 
benefit applications generally requiring an interview, such as 
petitions for admission of spouses and other family members. These 
"preprocessing" activities include conducting background security 
checks, performing initial evidence reviews, adjudicating any 
associated employment authorization and travel applications, denying 
adjustment of status cases for applicants who are statutorily 
ineligible, and forwarding scheduled cases to the cognizant district so 
that the applicant can be interviewed and the case decided. Eventually, 
the National Benefits Center will also preprocess all applications for 
naturalization. 

* USCIS's 4 service centers are located in California, Nebraska, Texas, 
and Vermont. They were created in 1990 to help reduce application 
backlogs in the district offices. Service centers process 35 types of 
applications, including petitions for permanent and temporary workers 
and applications for employment-based adjustment of status to permanent 
resident. Since February 1996, the service centers have shared 
responsibility with the districts for processing naturalization 
applications. Naturalization applications are received by the service 
centers and processed up to the point of interview, at which time 
responsibility for processing the case is shifted to the appropriate 
district so that the applicant can be interviewed and the case decided. 

* USCIS's 78 district and local offices and 31 international offices 
are located throughout the nation and around the world. These offices 
generally process applications that require interviews with the 
applicant or verification of an applicant's identity. In addition to 
processing naturalization applications, districts process petitions for 
alien relatives and family-based adjustment of status applications, 
among others. 

* USCIS's 8 asylum offices are located in Newark, New Jersey; New York, 
New York; Arlington, Virginia; Miami, Florida; Chicago, Illinois; 
Houston, Texas; Los Angeles, California; and San Francisco, California. 
Asylum offices adjudicate asylum applications and applications for 
suspension of deportation and special rule cancellation of removal 
under Section 203 of the Nicaraguan and Central American Relief Act 
(NACARA 203); conduct "credible fear" and "reasonable fear" screening 
interviews of certain removable persons who have expressed a fear of 
return to the country of removal to determine if they qualify for an 
opportunity to seek relief from removal before an Immigration Judge, 
and provide staffing support to the Refugee Branch to assist in USCIS's 
overseas refugee processing efforts. 

* USCIS's 129 application support centers are under the jurisdiction of 
districts and are located throughout the nation. They were established 
in fiscal year 1998 to serve as INS's designated fingerprint locations. 
In June 2000, INS shifted responsibility for processing applications 
for renewal of permanent resident cards (i.e., green cards) from the 
districts to the support centers. 

[End of section] 

Appendix III: Information Technology Systems: 

Several information technology systems critical to USCIS's information 
technology transformation plan are in development. One objective of 
this plan is to develop a new integrated customer-focused case- 
processing system that will deliver comprehensive information from 
immigration applications. Other systems under development are USCIS's 
Background Check Service system, which is designed to manage security 
check information and the Biometric Storage System, which will store 
biometric data. 

Integrated Case Management System: 

The integrated case management system is a tool that will be used by 
USCIS staff in processing benefits and adjudicating cases. USCIS's 
information technology transformation mission needs statement estimates 
that the case management system development will begin in fiscal year 
2006. USCIS is currently assembling the system requirements and 
conducting surveys of industry best practices. In addition, USCIS is 
reviewing a cost-benefit analysis to evaluate alternative 
implementation strategies for the new integrated case management 
system. USCIS anticipates that its current case management systems will 
be decommissioned by fiscal year 2011. 

Background Check Service: 

The Background Check Service system automates and manages the 
submission of all security checks including name and fingerprints from 
the FBI and Interagency Border Inspection System. The Background Check 
Service system will track and store security check responses in a 
centralized system. USCIS is preparing to initiate the testing and 
implementation phase, but USCIS must first select a hosting and 
production facility for the system. As of August 2005, USCIS estimates 
the deployment of the Background Check Service system to be December 
2005. 

The Biometric Storage System: 

The Biometric Storage System allows USCIS to store biometrics 
information for verification of identity and for future form 
submissions. Biometric storage capacity will be expanded to allow 
storage of biometric information for all USCIS customers, allowing 
information to be resubmitted for subsequent security checks. The 
system will capture 10-prints for FBI fingerprint checks and image sets 
(photograph, press-prints, and signatures). According to USCIS, the 
Biometric Storage System repository will be located with the United 
States Visitor and Immigrant Status Indicator Technology and Automated 
Biometric Identification System Programs to enable data sharing and 
more detailed background check and authentication processes.[Footnote 
62] As of August 2005, USCIS estimated that the Biometric Storage 
System will become operational in August 2006. 

[End of section] 

Appendix IV: District Office Application for Naturalization (N-400) 
Processing Quality Checklist: 

[See PDF for image] 

[End of figure] 

[End of section] 

Appendix V: Adjustment of Status (I-485) Processing Quality Assurance 
Checklist: 

[See PDF for image] 

[End of figure] 

[End of section] 

Appendix VI: Service Center Checklists Used for Reviewing Quality 
Assurance of Petitions for a Nonimmigrant Worker: 

[See PDF for image] 

[End of figure] 

[End of section] 

Appendix VII: Comments from the Department of Homeland Security: 

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

November 8, 2005: 

Mr. Paul L. Jones: 
Director, Homeland Security and Justice Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Jones: 

RE: Draft Report GAO-06-20, Immigration Benefits: Improvements Needed 
to Address Backlogs and Ensure Quality of Adjudications: 

(GAO Job Code 440351): 

The Department of Homeland Security appreciates the opportunity to 
comment on the Government Accountability Office's (GAO) draft report. 
We agree with the recommendations contained therein and appreciate the 
acknowledgement that significant progress in addressing backlogs of 
immigration benefit applications has been made. 

The Department's U.S. Citizenship and Immigration Services (USCIS) top 
priority has been the elimination of the backlog of cases by the end of 
FY 2006, while ensuring the security and integrity of the immigration 
system. GAO found that USCIS has limitations in its ability to 
automatically track all applications through its existing technology 
infrastructure, which would ensure an accurate determination of each 
application that exceeded the 6-month processing time. However, USCIS 
has been able to manage its backlog elimination efforts through 
effective analysis of its workload and placing staff where workload 
needs demanded, focusing its efforts on petitions and applications 
where the benefit was immediately available, streamlining processes and 
adopting best practices identified in selected pilot initiatives. We 
agree with GAO's conclusion that USCIS faces challenges in meeting its 
FY 2006 goals for eliminating the backlog in its naturalization and 
adjustment of status workloads. We remain optimistic, however, that 
with dedicated effort, careful planning and strong leadership these 
goals are still attainable. To ensure that USCIS will not incur any 
additional backlogs in future years, USCIS is developing a case 
management system for deployment in October 2006. The vision is for all 
cases received after September 30, 2006, to be entered, tracked and 
managed through the new system. 

The GAO's recommendations are useful in ensuring that USCIS provides 
decision makers with full and adequate information. The GAO first 
recommends the Secretary of Homeland Security direct the Director of 
USCIS to develop and implement the capability to produce management 
reports on the actual age of individual benefit applications as soon as 
practicable in its long-term technology transformation process. The 
proposed case management system is being planned to provide this 
capability. 

The GAO also recommends the Secretary of Homeland Security direct the 
Director of USCIS to (1) identify potential productivity gains and 
their effects on preventing future backlogs; and (2) identify the 
potential effects of technology improvements on its staffing allocation 
plans. We agree with the recommendation, and in response to the first 
part, USCIS is currently piloting several initiatives to increase 
productivity and efficiency. USCIS headquarters will continue to work 
with field components to seek methods to streamline processes while 
ensuring process integrity and security. Additionally, USCIS will 
continue to work with the USCIS Ombudsman's office in seeking 
opportunities to increase productivity within adjudicative processes 
while maintaining the integrity of the immigration system. In response 
to the second part of the recommendation, USCIS is committed to 
analyzing staffing allocation levels twice yearly to ensure that 
resources are properly aligned with workload. As business processes and 
information technology improvements we realized, resource allocations 
will change to fit the business model. By analyzing resource 
allocations every six months, those changes can be effected timely. 

Finally, the GAO recommended the Secretary of Homeland Security direct 
the Director of USCIS to modify its quality assurance programs to 
address both adjudication process compliance and reasonableness of 
adjudicator decisions and expand coverage to all types of benefit 
applications. USCIS has embarked upon a comprehensive quality 
management program aimed at identifying, designing, and developing a 
set of quality performance measures that will be used to measure and 
report against Service-wide performance targets and that support USCIS 
strategic goals and objectives. The quality management program will 
include all form types as well as adjudicators' decisions. 

Technical comments will be sent under separate cover. 

Sincerely, 

Signed by: 

Steven J. Pecinovsky: 
Director: 
Departmental GAO/OIG Liaison Office: 

[End of section] 

Appendix VIII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Paul L. Jones, (202) 512-8777 or JonesPL@gao.gov: 

Staff Acknowledgments: 

In addition to those named above, David Alexander, Leo Barbour, Karen 
Burke, Virginia Chanley, Frances Cook, Nancy Finley, Kathryn Godfrey, 
Clarette Kim, Marvin G. McGill, Eva Rezmovic, E. Jerry Seigler, James 
Ungvarsky, and Robert E. White were key contributors to this report. 

FOOTNOTES 

[1] USCIS collects fees for most applications types, except for 
applications for asylum (I-589). (8 C.F.R. 103.7). 

[2] GAO, Immigration Benefits: Several Factors Impede Timeliness of 
Application Processing, GAO-01-488 (Washington, D.C.: May 4, 2001). 

[3] We have reported previously that the fees USCIS collects are 
insufficient to fully fund its operations and that the agency does not 
have the systems in place to determine the cost of each step in 
processing benefit applications. See GAO, Immigration Application Fees: 
Current Fees Are Not Sufficient to Fund U.S. Citizenship and 
Immigration Services' Operations, GAO-04-309R (Washington, D.C.: Jan. 
5, 2004). 

[4] Immigration Services and Infrastructure Improvements Act of 2000 § 
205(a), 8 U.S.C. § 1574(a). 

[5] By the end of fiscal year 2006, USCIS expects to have allocated a 
total of $560 million instead of $500 million. According to USCIS 
officials, the President requested and received a onetime additional 
$60 million in fiscal year 2005 to get USCIS back on track because of 
the required security enhancements performed on all immigration benefit 
applications after September11, 2001. Twenty percent of the backlog 
reduction funding has been made up of fee revenues from premium 
processing services. 

[6] Nonprobability sampling is a method of sampling where observations 
are selected in a manner that is not completely random, usually using 
specific characteristics of the population as criteria. Because each 
unit in a population does not have an equal chance to be selected, it 
is possible for a nonprobability sample to contain a systematic bias 
that limits its ability to describe the entire population. 

[7] The annual allocation of immigrant visas is limited by statute and 
is based on family relationship priority, educational and skill level 
priorities for prospective employers, and country of origin. If a visa 
is not available, USCIS will not process petitions for alien relatives 
or immigrant workers. 

[8] Service centers generally adjudicate applications that do not 
require interviews with the applicants. 

[9] The National Benefits Center processes (1) applications for 
adjustment of status to lawful permanent resident, (2) applications for 
employment authorization, (3) applications for travel documents, and 
(4) petitions for alien relatives. 

[10] 8 U.S.C. § 1572(1). 

[11] GAO, Immigration Benefits: Several Factors Impede Timeliness of 
Application Processing, GAO-01-488 (Washington, D.C.: May 4, 2001). 

[12] USCIS measures its progress in reducing the backlog by calculating 
what it calls "cycle time," the number of past months' receipts that 
equal the number of applications currently pending. For example, if 
120,000 applications were pending and USCIS had received 110,000 
applications in the most recent 7 months, and another 20,000 in the 
eighth month, USCIS would report its cycle time as 7.5 months (120,000 
- 110,000 = 7 months + 0.5 [10,000/20,000] from the eighth month.) 
Because this cycle time is not a true measure of time, we refer to it 
in this report as workload. 

[13] GAO, Immigration Benefits: Several Factors Impede Timeliness of 
Application Processing, GAO-01-488 (Washington, D.C.: May 4, 2001). 

[14] According to USCIS, the agency can produce on-demand reports on 
processing times for applications for naturalization. However, this 
capability is limited to this single application type. 

[15] USCIS, Mission Needs Statement for the USCIS IT Transformation 
(Washington, D.C.: Mar. 31, 2005). 

[16] With the exception of premium fees for expedited processing, these 
funds do not include the benefit application processing fees USCIS is 
authorized to collect. 

[17] For the purposes of calculating its backlog, USCIS does not 
include these cases. However, these cases remain in USCIS's count of 
pending cases. 

[18] The adjustment of status package consists of the application to 
adjust status, in addition to ancillary applications and petitions, 
such as applications for travel documents, petitions for alien 
relatives, and applications for employment authorization. 

[19] 8 C.F.R § 103.2(b)(8). 

[20] The interim rule was codified at 8 C.F.R. § 274a.12. 

[21] 6 U.S.C. § 272(a). 

[22] Citizenship and Immigration Services Ombudsman, Annual Report 2005 
(Washington, D.C.: June 30, 2005). 

[23] The Performance Management Division is charged with developing the 
USCIS backlog elimination plan and monitoring progress against the 
plan, developing and managing the National Quality Program, analyzing 
and recommending resource allocation, and performing statistical data 
analysis. 

[24] 8 C.F.R. § 274a.13(d). 8 CFR § 274a.12(c) states that USCIS has 
discretion to establish a specific validity period for an employment 
authorization document. 

[25] USCIS checks applicant names with its Interagency Border 
Inspection System before issuing an Employment Authorization Document. 

[26] USCIS, USCIS Pilot Project Evaluation: California Service Center 
Backlog Elimination Pilot (Washington, D.C.: May 19, 2005). 

[27] Citizenship and Immigration Services Ombudsman, Annual Report 2005 
(Washington, D.C.: June 30, 2005). 

[28] The report also estimates that another $51 million in application 
fees for other interim benefits is associated with applications for 
adjustment of status. 

[29] USCIS does not charge fees for adjudicating certain applications 
for benefits, such as the Application for Asylum. Consequently, fees 
charged for other benefits--including interim benefits--must subsidize 
processing costs for fee-exempt applications. In addition, as we 
recently reported (GAO-04-309R), USCIS cannot currently determine the 
exact costs of processing individual applications for benefits. 

[30] Beginning in fiscal year 2002, USCIS began hiring temporary 
adjudicators to help eliminate the backlog for terms of 4 years. Terms 
for these temporary adjudicators will begin to expire in fiscal year 
2006. 

[31] GAO, Comptroller General's Forum: High Performing Organizations- 
Metrics, Means and Mechanisms for Achieving High Performance in the 
21st Century Public Management Environment, GAO/04-343SP (Washington, 
D.C.: Feb. 3, 2004). 

[32] Effective October 26, 2005, USCIS will increase fees for 
immigration benefit applications on average about $10 per application 
to account for inflation. These increases will apply to applications 
and petitions filed on or after October 26, 2005. 

[33] GAO, Executive Guide: Measuring Performance and Demonstrating 
Results of Information Technology Investments, GAO/AIMD-98-89 
(Washington, D.C.: March 1998). 

[34] "Funding for Immigration in the President's 2005 Budget," Hearing 
before the Subcommittee on Immigration, Border Security, and Claims, 
Committee on the Judiciary, House of Representatives, Feb. 25 and Mar. 
11, 2004, Serial No. 68., Washington, D.C., p. 49. 

[35] The DHS Joint Requirements Council is a review board that reviews 
and validates mission needs statements for proposed programs as well as 
their cross-functional needs and requirements, and makes 
recommendations on proposed new programs. 

[36] USCIS, Mission Needs Statement for the USCIS IT Transformation 
(Washington, D.C.: Mar. 31, 2005). 

[37] GAO, Federal Chief Information Officers: Responsibilities, 
Reporting Relationships, Tenure, and Challenges, GAO-04-823 
(Washington, D.C.: July 21, 2004). 

[38] GAO/AIMD-98-89. 

[39] GAO-04-343SP. 

[40] The Department of Homeland Security, Management Directive, 
Investment Review Process, MD-1400. 

[41] According to USCIS, these applications are more complex than most 
other form types and require more time to adjudicate, because the 
applications are longer and a greater number of processes have to be 
applied to each, such as interviews, name checks, fingerprint checks, 
and Interagency Border Inspection System checks. 

[42] USCIS generally calculates its pending workload by counting back 
the number of preceding months until the sum of the monthly 
applications received equals the current month's number of applications 
awaiting adjudication. Unlike other USCIS cycle times, which are based 
on receipts, the Asylum Division's cycle times are based on 
completions. For I-589 and I-881 applications, cycle time is calculated 
by dividing the number of pending cases by the average number of cases 
completed each month over the last 12 months. The backlog equals the 
number of pending cases greater than 6 times the average number of 
cases completed each month over the last 12 months. 

[43] According to USCIS, the number of receipts peaked in March 2004 in 
anticipation of the increase in application fees scheduled for April 
30, 2004. 

[44] This estimate includes the current 1.2 million applications in the 
backlog plus more than 8.6 million projected future applications, to be 
filed over the 15-month period between July1, 2005, and September 30, 
2006. 

[45] Pub. L. No. 106-553, 114 Stat. 2762A-142 (2000). The former INS 
published a final rule in the Federal Register on June 4, 2002, 
establishing procedures for certain class action litigants to apply for 
adjustments of status under legalization provisions of the LIFE Act. 

[46] 8 U.S.C. § 1151(a)(1), (a)(2), (c), (d). 

[47] 8 U.S.C. § 1153(a), (b). 

[48] 8 U.S.C. § 1153(e). 

[49] 8 U.S.C. § 1152. 

[50] Similarly, as an example of country-based limits, the Department 
of State was issuing visas to unmarried sons and daughters of U.S. 
citizens whose applications were filed on or before January 1, 1983, if 
they come from Mexico, and March 22, 1991, if they come from the 
Philippines. 

[51] Emergency Supplemental Appropriations Act for Defense, the Global 
War on Terror, and Tsunami Relief, 2005, Pub. L. No. 109-13, div. B, 
119 Stat. 231, 302-23. 

[52] The REAL ID Act also removed the limit on the number of 
applications for adjustment of status for persons requesting asylum the 
agency can process each year (i.e., 10,000 applications per year). 
According to a USCIS official, this resulted in nearly 180,000 
applications for adjustment of status for asylees being added to 
USCIS's backlog count in June 2005. Although this increase in the 
asylum division's workload could challenge the division's backlog 
elimination efforts, it is not expected to prevent the division's 
ability to eliminate the backlog of asylum cases by September 30, 2006. 

[53] Our assessment of USCIS's efforts to ensure the quality of 
adjudicator decisions did not include predecision quality assurance 
efforts such as adjudicator training. 

[54] Because the review is based on a sample drawn from completed cases 
that are available for review (those files that have not already been 
transferred) rather than from all applications, it is unclear to what 
extent the results are representative of all closed cases. 

[55] See appendix IV for samples of the checklist used for Applications 
for Naturalization and appendix V for the checklist used for 
adjustments of status. 

[56] USCIS has not yet established the acceptable level of quality for 
adjustment of status applications. According to USCIS officials, they 
will establish this target using the initial 4 months of data. 

[57] Booz Allen Hamilton, Quality Assurance Compliance Assessment and 
Review Findings, a special report prepared at the request of the United 
States Citizenship and Immigration Services (Washington, D.C.: February 
2005). 

[58] See appendix VI for examples of service center checklists. 

[59] Nonprobability sampling is a method of sampling where observations 
are selected in a manner that is not completely random, usually using 
specific characteristics of the population as criteria. Because each 
unit in a population does not have an equal chance to be selected, it 
is possible for a nonprobability sample to contain a systematic bias 
that limits its ability to describe the entire population. 

[60] Emergency Supplemental Appropriations Act for Defense, the Global 
War on Terror, and Tusnami Relief, 2005, Pub. L. No. 109-13, div. B, 
119 Stat. 231, 302-23. 

[61] The National Benefits Center was initially called the Missouri 
Service Center when it opened in March/April 2001. 

[62] United States Visitor and Immigrant Status Indicator Technology 
interfaces with other Department of Homeland Security systems for 
relevant purposes, including status updates and benefit adjudication. 
In particular, it exchanges biographic information with the Student and 
Exchange Visitor Information System and the Computer Linked Application 
Information Management System. 

GAO's Mission: 

The Government Accountability Office, the investigative arm of 
Congress, exists to support Congress in meeting its constitutional 
responsibilities and to help improve the performance and accountability 
of the federal government for the American people. GAO examines the use 
of public funds; evaluates federal programs and policies; and provides 
analyses, recommendations, and other assistance to help Congress make 
informed oversight, policy, and funding decisions. GAO's commitment to 
good government is reflected in its core values of accountability, 
integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through the Internet. GAO's Web site ( www.gao.gov ) contains 
abstracts and full-text files of current reports and testimony and an 
expanding archive of older products. The Web site features a search 
engine to help you locate documents using key words and phrases. You 
can print these documents in their entirety, including charts and other 
graphics. 

Each day, GAO issues a list of newly released reports, testimony, and 
correspondence. GAO posts this list, known as "Today's Reports," on its 
Web site daily. The list contains links to the full-text document 
files. To have GAO e-mail this list to you every afternoon, go to 
www.gao.gov and select "Subscribe to e-mail alerts" under the "Order 
GAO Products" heading. 

Order by Mail or Phone: 

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548: 

To order by Phone: 

Voice: (202) 512-6000: 

TDD: (202) 512-2537: 

Fax: (202) 512-6061: 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov 

Automated answering system: (800) 424-5454 or (202) 512-7470: 

Public Affairs: 

Jeff Nelligan, managing director, 

NelliganJ@gao.gov 

(202) 512-4800 

U.S. Government Accountability Office, 

441 G Street NW, Room 7149 

Washington, D.C. 20548: