Federal User Fees: Additional Analyses and Timely Reviews Could Improve Immigration and Naturalization User Fee Design and USCIS Operations
GAO-09-180
Published: Jan 23, 2009. Publicly Released: Jan 23, 2009.
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Highlights
U.S. Citizenship and Immigration Services (USCIS) announced an increase to its immigration and naturalization application fees by an average of 86 percent, effective July 2007, contributing to a surge in application volume that challenged the agency's pre-adjudicative operations. In July 2007, the incoming application volume increased an unprecedented 100 percent over the prior month and the processing of 1.47 million applications was delayed. GAO was asked to review USCIS's current fee design and compare it to the principles in GAO's user-fee design guide and USCIS's management of operations affected by the new fees, specifically in projecting application volumes and contracting for application processing services. To do so, GAO reviewed legislation and agency documentation; compared the fee design to GAO's principles of effective user-fee design (equity, efficiency, revenue adequacy, and administrative burden); visited processing centers; and interviewed agency officials at these locations and in headquarters.
Recommendations
Recommendations for Executive Action
| Agency Affected Sort descending | Recommendation | Status |
|---|---|---|
| Department of Homeland Security | The Secretary of the Department of Homeland Security should direct the Acting Director of the United States Citizenship and Immigration Services to develop and conduct timely user-fee reviews that (1) builds on the 2007 fee review and keeps with the Chief Financial Officer's Act's (CFO) biennial user-fee review requirement, and (2) identifies and considers the full costs of USCIS's operations funded from the Immigration Examinations Fee Account (IEFA), including the cost of lockbox operations and processing costs for applications where the fee rates are set in statute such as for premium processing and H1-B visa. |
Closed – Implemented
In August 2010 the United States Citizenship and Immigration Service (USCIS) issued its fiscal year 2010-2011 Immigration and Examinations Fee Account Fee Review Supporting Documentation with Addendum. This fee review conforms with the biennial review requirement, as USCIS's last fee review was for fiscal years 2008-2009. This review expands prior reviews and better reflects the full costs of USCIS's operations by including USCIS's lockbox operations' costs. In June 2012, USCIS officials said they would continue to consider the costs of statutorily-set fees when they completed their ongoing analysis of processing premium processing and H1-B visa application costs.
|
| Department of Homeland Security | The Secretary of the Department of Homeland Security should direct the Acting Director of the United States Citizenship and Immigration Services to adjust the premium-processing fees to account for the consumer price index. |
Closed – Implemented
On June 11, 2010, the United States Citizenship and Immigration Service (USCIS) published a proposed rule in the Federal Register to adjust its immigration and naturalization application fees. Among the changes, USCIS proposed increasing the premium processing fee according to the Consumer Price Index.
|
| Department of Homeland Security | The Secretary of the Department of Homeland Security should direct the Acting Director of the United States Citizenship and Immigration Services to identify an appropriate level of carryover balance to ensure USCIS's continuity of operations for IEFA-funded activities and include in the next fee review a plan for achieving it. |
Closed – Implemented
In August 2010, the United States Citizenship and Immigration Service (USCIS) issued its fiscal year 2010-2011 Immigration and Examinations Fee Account Fee Review Supporting Documentation with Addendum. This review identifies the purposes for which USCIS would rely on its carryover balance and the factors that influence USCIS's ability to maintain carryover balance levels. Based on this analysis, in this report USCIS identifies an amount of carryover balance it believes appropriate for fiscal years 2010 and 2011.
|
| Department of Homeland Security | The Secretary of the Department of Homeland Security should direct the Acting Director of the United States Citizenship and Immigration Services to analyze application projection information from a workload perspective, accounting for anticipated monthly variations in application volume. |
Closed – Implemented
In March 2010 the United States Citizenship and Immigration Services (USCIS) provided analysis of the monthly receipt estimates by form type and processing location for November 2009 through September 2010. The data showed the variation in estimated monthly application receipts and identified the likely effect on workload, including intake, data entry, and mail room activities.
|
| Department of Homeland Security | The Secretary of the Department of Homeland Security should direct the Acting Director of the United States Citizenship and Immigration Services to use projection information across processing centers for workload management purposes, including (1) developing an agencywide application surge work-plan and (2) coordinating with the FMS-designated financial agent on application volume forecasting. |
Closed – Implemented
In February 2010, USCIS completed its Integrated Multi Annual Performance System (IMAPS) reporting tool. The IMAPS reports provide USCIS the capability manage its workload in such a way that any unexpected surges in workload can be quickly and easily identified so that management action can be timely taken to address such surges at USCIS and FMS-designated financial agent facilities. USCIS has developed an IMAPS performance report for each field offices, service centers and the National Benefits Center. The IMAPS system allows USCIS roll-up each individual field office and service center IMAPS reports so as to generate a consolidated regional and/or service center and national report.
|
| Department of Homeland Security | The Secretary of the Department of Homeland Security should direct the Acting Director of the United States Citizenship and Immigration Services to document projection decision making more effectively, by more comprehensively accounting for (1) known application volume drivers, (2) the magnitude by which baseline projections have been adjusted in order to account for application volume drivers, and (3) reasons why OIS's projections--based on statistical analysis of historical application volumes--were not adjusted to account for any anticipated drivers. |
Closed – Implemented
In August 2010, the United States Citizenship and Immigration Service (USCIS) issued its fiscal year 2010-2011 Immigration and Examinations Fee Account Fee Review Supporting Documentation with Addendum. USCIS included in this review documentation of it its application volume decisions, the application volume drivers and projected level of application volume adjustment, where appropriate.
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| Department of Homeland Security | The Secretary of the Department of Homeland Security should direct the Acting Director of the United States Citizenship and Immigration Services to develop and implement procedures for USCIS to validate the contractors' invoices for incoming mail services at all four service centers. |
Closed – Implemented
U.S. Citizenship and Immigration Services (USCIS) pays contractors a fixed unit price for each piece of incoming and outgoing mail processed. In April 2011, USCIS issued a policy for validating service center mailroom counts. According to the new policy, the contract performance analysis unit will observe and randomly count incoming and outgoing mail received, selecting mail to be counted using a randomly selected sample.
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Administrative costsClaims processingClaims processing costsContract administrationContractsCost analysisData collectionData integrityFederal formsFederal regulationsFeesImmigrationImmigration and naturalization lawNaturalizationPrices and pricingProgram evaluationUser feesWaiversPolicies and procedures