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Highlights

Following the terrorist attacks of September 11, 2001, the federal government's need to locate aliens in the United States was considerably heightened. Without reliable alien address information, the government is impeded in its ability to find aliens who represent a national security threat or who could help with the nation's anti-terrorism efforts. Requesters from both the Senate and House asked GAO to review the reliability of INS's alien address information and identify the ways it could be improved.

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Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
Directorate of Border and Transportation Security 1. In order to promote compliance with the change of address notification requirements through publicity and enforcement and to improve the reliability of its alien address data, the Attorney General should direct the INS Commissioner to identify and implement an effective means to publicize the change of address notification requirement nationwide. As part of its publicity effort, INS should make sure that aliens have information on how to comply with this requirement, including where information may be available and the location of change of address forms.
Closed - Implemented
USCIS has taken multiple steps to implement this recommendation. Specifically: (1) In January 2007, USCIS launched a new web-based service allowing non-citizens to submit change of address information online. The on-line service is intended to offer a modern, comprehensive, and reliable way for aliens to update their addresses. By logging on to http://www.uscis.gov/AR-11, non-citizens are guided through several screens that provide explanation about the change of address process and includes the change of address form, AR-11, which can be submitted on-line. (2) By going to www.uscis.gov/addresschange users can also obtain information on such things as how to report a change of address, who must comply, what information to include, and penalties for failure to comply, and can access the change of address form, as well. (3) In May 2006, USCIS put a fact sheet on its web site providing detailed information in English and Spanish on the steps that various categories of aliens should take to notify USCIS of an address change. (4) In February 2007, the director of USCIS's Office of Records Management stated that she visited many field offices during her tenure, and encouraged local field leadership to work with local U. S. Postal Service offices to inform them about the Form AR-11 filing requirement. (5) In 2004, USCIS and the U.S. Postal Service signed a memorandum of understanding wherein USPS created a hyperlink on its web site that enables users to connect with USCIS's change of address form. (6) To promote awareness of the change of address filing requirement, USCIS also designed leaflets and posters for placement in Post Offices and USCIS customer service offices. We consider these steps to be responsive to GAO's recommendation and consider the recommendation to have been fully implemented.
Directorate of Border and Transportation Security 2. In order to promote compliance with the change of address notification requirements through publicity and enforcement and to improve the reliability of its alien address data, the Attorney General should direct the INS Commissioner to develop procedures for distributing change of address forms to include making arrangements with the U.S. Postal Service to provide for placing change of address forms in all post offices, as required by the Code of Federal Regulations.
Closed - Not Implemented
USCIS did a cost analysis for stocking the AR-11 forms at the U.S. Postal Service and found that it would cost over one million dollars for the displays, the printing of the revised forms, and for the USPS employees to restock the displays. Therefore, this recommendation will not be implemented. In lieu of placing AR-11 forms in post offices, USCIS signed a memorandum of understanding wherein USPS agreed to place a hyperlink to USCIS's AR-11 on its web site.
Directorate of Border and Transportation Security 3. In order to promote compliance with the change of address notification requirements through publicity and enforcement and to improve the reliability of its alien address data, the Attorney General should direct the INS Commissioner to establish written procedures and controls to ensure that alien address information in all automated databases is complete, consistent, accurate, and current.
Closed - Not Implemented
USCIS took some actions that should help ensure that address information for many aliens is entered into relevant databases, but there remain gaps in the process, so this recommendation is being closed as not implemented.
Directorate of Border and Transportation Security 4. In order to promote compliance with the change of address notification requirements through publicity and enforcement and to improve the reliability of its alien address data, the Attorney General should direct the INS Commissioner to, in connection with updating automated databases, establish procedures and controls that permit INS to verify receipts of change of address records and issue a certificate of no record, when aliens do not comply with the change of address notification requirement.
Closed - Not Implemented
USCIS officials told us in February 2007 that they had responded to the part of the recommendation that was within their control. Specifically, anytime a non-citizen "touches" USCIS, USCIS will have an electronic fingerprint. This notwithstanding, it would be difficult for USCIS to assert that the data are 100% reliable. In addition, issuing a certificate of no record is an enforcement function that lies with another agency, U.S. Immigration and Customs Enforcement. Because GAO's work was done when immigration services and enforcement were within a single agency (the Immigration and Naturalization Service), and because those two functions are no longer within the same agency, this partially implemented recommendation is being closed.
Directorate of Border and Transportation Security 5. In order to promote compliance with the change of address notification requirements through publicity and enforcement and to improve the reliability of its alien address data, the Attorney General should direct the INS Commissioner to revise INS's operating instructions to make clear that noncompliance with address reporting requirements can be the sole basis for removal, as provided at 8 U.S.C. 1306(b).
Closed - Not Implemented
USCIS officials told us in February 2007 that, rather than stating the implications of noncompliance in the negative, they wanted to send a positive message. Therefore, the "Terms and Conditions" page of USCIS's web site states the importance of complying with the change of address requirement. This was a positive effort, but it does not meet the intent of the recommendation. Since USCIS has no further plans along these lines, the recommendation is being closed.
Directorate of Border and Transportation Security 6. In order to promote compliance with the change of address notification requirements through publicity and enforcement and to improve the reliability of its alien address data, the Attorney General should direct the INS Commissioner to provide a field on change of address forms that an alien can use to report a Social Security Number or indicate that they do not have one, with the appropriate notifications and safeguards required by law.
Closed - Not Implemented
USCIS does not intend to implement this recommendation. Officials said that the principal reason for not putting a space for the Social Security Number (SSN) on the form AR-11 is that they do not need the number. USCIS tracks aliens by A-number, not by SSN. USCIS does not intend to implement this recommendation. USCIS believes that identity theft and other security concerns pose a risk that make it inadvisable for the agency to maintain information it doesn't need for its own purposes.
Directorate of Border and Transportation Security 7. In order to promote compliance with the change of address notification requirements through publicity and enforcement and to improve the reliability of its alien address data, the Attorney General should direct the INS Commissioner to evaluate alternative approaches and their associated costs for obtaining or assembling complete alien address information, particularly for those aliens who do not comply with the change of address notification requirement.
Closed - Implemented
In response to our recommendation that it evaluate alternative approaches and their associated costs for obtaining or assembling complete alien address information, USCIS explored the possibility of engaging in a memorandum of understanding (MOU) with the U.S. Postal Service to place Forms AR-11 in post offices. USCIS conducted an analysis to determine how much it would cost to produce Form AR-11 displays, print forms, and have Postal Service employees do initial stocking and restocking of the displays. USCIS determined that these would cost over $1 million, and that this would be cost prohibitive for USCIS. In lieu of an MOU to display the Form AR-11 is post offices, the Postal Service placed a hyperlink on its web site to the Form AR-11. USCIS also implemented other alternative approaches, using both the Internet and manual distribution mechanisms, to publicize the change of address notification requirement and thereby assemble more complete alien address information.

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