Recommendations for Executive Action

1. Status: Closed - Implemented

   Comments: Through an interagency users' group, INS has discussed data needs for alien verification. An INS task force identified database inadequacies and errors and proposed resolution of them. Since January 1988, modifications have been made to the database that resulted in improved primary verification of alien status. The system is complete and operational, though changes will be made as necessary.

   Recommendation: The Attorney General should direct the Commissioner, INS, to increase efforts with federal program agencies, through user groups, to determine what information is needed to make eligibility verifications, such as on aliens permanently residing in the United States under color of law and certain other aliens, should be included in the INS automated database. Correspondingly, the Commissioner should develop plans to improve the completeness and quality of the automated database.

   Agency Affected: Department of Justice

2. Status: Closed - Implemented

   Comments: On June 30, 1988, INS issued an operations manual for the verification system, which contained estimated unit costs for various access methods and details how to process verification requests. The manual has been updated and re-issued.

   Recommendation: The Attorney General should direct the Commissioner, INS, to ensure that cost and other operating data about the new system is provided to federal, state, and other administering entities as soon as they become available, to assist the governments in making waiver decisions and selecting the most efficient methods for accessing INS data.

   Agency Affected: Department of Justice

3. Status: Closed - Implemented

   Comments: The Food and Nutrition Service (FNS) completed a study of the cost-effectiveness of IRCA verification procedures for the Food Stamp Program and concluded that IRCA procedures did not appear cost-effective. Interim regulations, originally published in October 1988, remain in effect.

   Recommendation: The Secretaries of Agriculture, Education, Health and Human Services (HHS), Housing and Urban Development, and Labor should begin developing criteria and methodologies for granting waivers and ensure that states and other administering agencies begin developing, through such means as pilot tests, empirical performance data related to Immigration Reform and Control Act (IRCA) verification procedures for use in deciding waivers.

   Agency Affected: Department of Agriculture

4. Status: Closed - Implemented

   Comments: Final regulations were published January 7, 1993, effective February 22, 1993. The regulations implement a data match and outline procedures for institutions to interpret the results. The regulations also provide for a second confirmation if the match does not confirm eligibility status.

   Recommendation: The Secretaries of Agriculture, Education, Health and Human Services (HHS), Housing and Urban Development, and Labor should begin developing criteria and methodologies for granting waivers and ensure that states and other administering agencies begin developing, through such means as pilot tests, empirical performance data related to Immigration Reform and Control Act (IRCA) verification procedures for use in deciding waivers.

   Agency Affected: Department of Education

5. Status: Closed - Implemented

   Comments: The Department of Housing and Urban Development (HUD) sees no reason to grant waivers and believes that the telephone access method would be cost-effective even for the smallest administering entities. Final rules on the IRCA verification requirements were published March 20, 1995, and became effective June 19, 1995.

   Recommendation: The Secretaries of Agriculture, Education, Health and Human Services (HHS), Housing and Urban Development, and Labor should begin developing criteria and methodologies for granting waivers and ensure that states and other administering agencies begin developing, through such means as pilot tests, empirical performance data related to Immigration Reform and Control Act (IRCA) verification procedures for use in deciding waivers.

   Agency Affected: Department of Housing and Urban Development

6. Status: Closed - Not Implemented

   Comments: Although the agency has granted unconditional waivers to Maine and Michigan, no legislation has been introduced to make SAVE optional for states.

   Recommendation: The Secretaries of Agriculture, Education, Health and Human Services (HHS), Housing and Urban Development, and Labor should begin developing criteria and methodologies for granting waivers and ensure that states and other administering agencies begin developing, through such means as pilot tests, empirical performance data related to Immigration Reform and Control Act (IRCA) verification procedures for use in deciding waivers.

   Agency Affected: Department of Health and Human Services

7. Status: Closed - Implemented

   Comments: On March 15, 1988, the Department of Labor (DOL) issued its bases for granting waivers only from automated verification and provided states with descriptions of data and information needed to support waiver requests. So far, DOL has waived automated verification for eight states, but it is still required to perform the secondary verification procedures.

   Recommendation: The Secretaries of Agriculture, Education, Health and Human Services (HHS), Housing and Urban Development, and Labor should begin developing criteria and methodologies for granting waivers and ensure that states and other administering agencies begin developing, through such means as pilot tests, empirical performance data related to Immigration Reform and Control Act (IRCA) verification procedures for use in deciding waivers.

   Agency Affected: Department of Labor

8. Status: Closed - Implemented

   Comments: The Department of Agriculture (USDA) issued an interim rule on implementation requirements and reimbursable verification costs on October 7, 1988. These interim rules remain in effect.

   Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should increase efforts to provide guidance to administering entities on IRCA requirements, the criteria and procedures for granting waivers, and the types of verification costs that will be reimbursable.

   Agency Affected: Department of Agriculture

9. Status: Closed - Implemented

   Comments: Education waived IRCA requirements but developed regulations for an alternative verification system. Final regulations were published January 7, 1993, and effective February 22, 1993.

   Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should increase efforts to provide guidance to administering entities on IRCA requirements, the criteria and procedures for granting waivers, and the types of verification costs that will be reimbursable.

   Agency Affected: Department of Education

10. Status: Closed - Implemented

    Comments: On March 20, 1995, HUD issued final rules for administering entities on the IRCA verification requirements.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should increase efforts to provide guidance to administering entities on IRCA requirements, the criteria and procedures for granting waivers, and the types of verification costs that will be reimbursable.

    Agency Affected: Department of Housing and Urban Development

11. Status: Closed - Not Implemented

    Comments: HHS has provided guidance to states regarding reimbursable costs. No further action is intended.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should increase efforts to provide guidance to administering entities on IRCA requirements, the criteria and procedures for granting waivers, and the types of verification costs that will be reimbursable.

    Agency Affected: Department of Health and Human Services

12. Status: Closed - Implemented

    Comments: DOL has provided information on IRCA requirements, as well as specific guidance and instructions for administering entities that plan to implement the requirements during fiscal year 1988, including types of reimburseable verification costs. Criteria and procedures for requesting and granting waivers were issued on May 26, 1988. No further guidance is needed.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should increase efforts to provide guidance to administering entities on IRCA requirements, the criteria and procedures for granting waivers, and the types of verification costs that will be reimbursable.

    Agency Affected: Department of Labor

13. Status: Closed - Implemented

    Comments: The USDA interim rule guiding state food stamp agencies to implement IRCA verification procedures before October 1, 1988, requires them to submit for approval a state plan and budget projection statement that provides data on the numbers of alien applicants, expected savings, and verification costs. This and other interim rules remain in effect.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should develop and implement plans for capturing data on numbers of alien applicants, savings, and costs of verification with INS and for monitoring the system to ensure that administering entities use the most effective and economical verification means.

    Agency Affected: Department of Agriculture

14. Status: Closed - Not Implemented

    Comments: Education's decision to waive the IRCA verification requirements nullified the need to gather data on savings and costs of IRCA verification. Final regulations were published January 7, 1993, and effective February 22, 1993.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should develop and implement plans for capturing data on numbers of alien applicants, savings, and costs of verification with INS and for monitoring the system to ensure that administering entities use the most effective and economical verification means.

    Agency Affected: Department of Education

15. Status: Closed - Implemented

    Comments: HUD believes that existing data collection systems are sufficient for monitoring purposes. Public housing authorities chose the most effective methods of verification. Final rules, proposed March 20, 1995, on data collection systems became effective on June 19, 1995.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should develop and implement plans for capturing data on numbers of alien applicants, savings, and costs of verification with INS and for monitoring the system to ensure that administering entities use the most effective and economical verification means.

    Agency Affected: Department of Housing and Urban Development

16. Status: Closed - Not Implemented

    Comments: In its response to the requirements of 31 U.S.C. 720, dated May 23, 1988, HHS stated that it planned to develop updated estimates of avoided costs by using alien data captured in ongoing program reports and data supplied by INS. However, HHS has since determined that changing its methods for capturing these data would not be cost effective and, thus, plans no change.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should develop and implement plans for capturing data on numbers of alien applicants, savings, and costs of verification with INS and for monitoring the system to ensure that administering entities use the most effective and economical verification means.

    Agency Affected: Department of Health and Human Services

17. Status: Closed - Implemented

    Comments: The DOL database system is currently operational and is collecting work load data to monitor the efficiency and effectiveness of the alien verification process.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Housing and Urban Development, and Labor should develop and implement plans for capturing data on numbers of alien applicants, savings, and costs of verification with INS and for monitoring the system to ensure that administering entities use the most effective and economical verification means.

    Agency Affected: Department of Labor

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