What GAO Found
The Department of Homeland Security's (DHS) United States Citizenship and Immigration Services (USCIS) has taken steps to assess the accuracy of the information reported by its Systematic Alien Verification for Entitlements (SAVE) system. For example, since 2014 USCIS has conducted monthly checks to ensure SAVE is accurately reporting information contained in its source systems. In addition, USCIS reports that SAVE status verifiers, who manually research a benefit applicant's immigration status during a process known as additional verification, accurately reported the applicant's status 99 percent of the time. However, from fiscal year 2012 through fiscal year 2016, GAO found that the majority of SAVE user agencies that received a SAVE response prompting them to institute additional verification did not complete the required additional steps to verify the benefit applicant's immigration status. USCIS does not have sufficient controls to help ensure agencies are completing the necessary steps because of inconsistent guidance, and lacks reasonable assurance that SAVE user agencies have completed training that explains this procedure. Improving guidance and ensuring training on verification requirements could help USCIS better ensure agencies have complete and accurate information for making eligibility determinations.
USCIS has taken actions to protect the privacy of personal information related to SAVE, such as requiring SAVE user agencies to sign a memorandum of agreement (MOA) stating the intended use of the system and provisions for safeguarding information. USCIS has also established mechanisms for access, correction, and redress regarding use of an individual's personal information; however, GAO found these mechanisms were largely ineffective and unlikely to enable benefit applicants to make timely record corrections. Specifically, USCIS provides a fact sheet for benefit applicants stating their immigration status could not be verified, along with information on contacting DHS to update or correct their records. However, the fact sheet's guidance on contacting DHS was not specific or clear, which could hinder benefit applicants' efforts to contact DHS. Without an effective method for ensuring individuals can access and correct their information, benefit applicants may face challenges ensuring accurate information is used in a SAVE check and appealing potentially erroneous denials of benefits with the user agency in a timely manner.
USCIS's SAVE Monitoring and Compliance (M&C) branch monitors user agencies' use of SAVE in accordance with their MOA. However, SAVE M&C's monitoring efforts have not improved agency compliance rates for the two monitored behaviors—deleting inactive user accounts and instituting additional verification when prompted. For example, GAO found that only 4 of 40 agencies monitored from fiscal years 2013 through 2015 had improved their compliance with requirements to complete additional verification when prompted. Further M&C does not have a documented, risk-based strategy for monitoring. Without such a strategy, USCIS is not well-positioned to target its monitoring efforts on the agencies most in need of compliance assistance or ensure the most effective use of its limited resources.
Why GAO Did This Study
Millions of applicants for healthcare, licenses, and other benefits rely on DHS's SAVE system to verify their immigration or naturalized or derived citizenship status at the request of over 1,000 federal, state, and local user agencies. Agencies use the information from SAVE to help determine an applicant's eligibility for benefits. Programs required or authorized to participate include Medicaid, certain license-issuing programs (such as driver's licenses), federal food and housing assistance, and educational programs. The House Appropriations Committee Report accompanying the DHS Appropriations Act, 2016, included a provision for GAO to review the SAVE program.
This report examines the extent to which USCIS has (1) determined the accuracy of SAVE information, (2) instituted safeguards to protect privacy and provide the ability to correct erroneous information, and (3) monitored user agency compliance with SAVE program policies. GAO analyzed SAVE policy documents and performance data, interviewed DHS officials, and interviewed officials from a non-generalizable sample of 13 SAVE user agencies selected to reflect the variety of types of agencies that use SAVE.
GAO is making nine recommendations to USCIS, including, that USCIS improve guidance and ensure training on verification requirements; develop and implement a more effective method for record correction; and develop a documented, risk-based strategy for monitoring and compliance. DHS concurred with our recommendations.
Recommendations for Executive Action
|United States Citizenship and Immigration Services||1. To improve management and oversight of the SAVE program, the director of USCIS should ensure SAVE guidance, including written materials and instructional videos, clearly and accurately reflects user agencies' responsibilities for completing each step of a SAVE check, as outlined in each agency's memorandum of agreement.|
|United States Citizenship and Immigration Services||2. To improve management and oversight of the SAVE program, the director of USCIS should develop and implement a mechanism to oversee agencies' completion of training on additional verification in accordance with SAVE MOA provisions and program policies.|
|United States Citizenship and Immigration Services||3. To improve management and oversight of the SAVE program, the director of USCIS should provide notifications to user agencies when a case is ready for the user agency to review.|
|United States Citizenship and Immigration Services||4. To improve management and oversight of the SAVE program, the director of USCIS should develop and implement a more effective method for ensuring that individuals are aware of how they can access and correct their immigration records, such as by updating and improving the Fact Sheet for Benefit Applicants.|
|United States Citizenship and Immigration Services||5. To improve management and oversight of the SAVE program, the director of USCIS should develop and implement a documented, risk-based approach to monitoring and compliance, including (1) a risk-based approach to selecting behaviors to monitor; (2) standards for what triggers compliance actions for the selected behaviors; and (3) a risk-based process for how USCIS will prioritize and select agencies for compliance actions.|
|United States Citizenship and Immigration Services||6. To improve management and oversight of the SAVE program, the director of USCIS should develop and communicate a process for user agencies to update contact information.|
|United States Citizenship and Immigration Services||7. To improve management and oversight of the SAVE program, the director of USCIS should ensure that user agencies participate in compliance reviews when selected, in accordance with SAVE MOA provisions and USCIS policy.|
|United States Citizenship and Immigration Services||8. To improve management and oversight of the SAVE program, the director of USCIS should identify the root causes of agencies' noncompliance with SAVE MOA provisions and program policies and tailor agency recommendations to those identified causes.|
|United States Citizenship and Immigration Services||9. To improve management and oversight of the SAVE program, the director of USCIS should develop and implement a process for ensuring user agencies implement corrective actions such as through a system of escalating compliance assistance actions and follow-up.|