Military Naturalizations
USCIS Generally Met Mandated Processing Deadlines, but Processing Applicants Deployed Overseas Is a Challenge Gao ID: GAO-10-865 July 29, 2010From September 2001 to March 2009, approximately 47,000 noncitizen members of the U.S. military became naturalized U.S. citizens. The Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Service (USCIS) and the Department of Defense (DOD) have taken steps to assist noncitizens with applying for naturalization. The Kendell Frederick Citizenship Assistance Act (Kendell Frederick Act) and the Military Personnel Citizenship Processing Act (MPCPA), enacted in 2008 to expedite application processing, each directed GAO to report on implementation of the acts. This report addresses (1) the extent to which USCIS met the processing deadlines established in the acts and (2) actions USCIS has taken to expedite the processing of applications, and any challenges it has faced. GAO reviewed relevant legislation and DHS reports and guidance related to processing applications; reviewed several generalizable samples of applicants' case files (A-files); and interviewed USCIS officials.
USCIS complied in nearly all cases with the Kendell Frederick Act's requirement that it complete application processing for overseas service members within 6 months of the final background check. USCIS complied in an estimated 73 percent of service member cases and 84 percent of spousal cases with the MPCPA's requirement that it either complete application processing within 6 months of receipt or notify the applicant of the reason for the delay and provide an estimated adjudication date. For the remaining cases, the applicants' files did not document that the applicant was notified that the application would not be processed within 6 months, did not provide an estimated adjudication date in the notification of delay letter, or GAO could not determine if USCIS met the notification requirements because cases pending after July 28, 2009, were not included in GAO's probability samples. Without documentation of USCIS's actions, it is difficult for USCIS to determine its adherence to MPCPA's requirements. USCIS took several actions to expedite application processing, including establishing a military naturalization unit and using videoconferencing for overseas applicants in war zones, among others; but receiving incomplete applications, processing applicants stationed overseas, and identifying all applicants prior to their overseas deployment pose challenges to timely processing of applications. USCIS cannot identify all deploying service members because it does not have procedures for ensuring that available deployment information is collected from all applicants when they file the application, and this could result in processing delays. Additionally, not all A-files contained documentation indicating that USCIS had taken steps to locate or notify applicants, as required in its April 2009 guidance. For example, for 9 of 15 cases that were administratively closed because the applicant had failed to appear for the initial interview, no documentation was included in the A-file, as required by USCIS's guidance, that a USCIS liaison at the applicant's military installation was contacted in an attempt to locate the service member. Without documenting all actions taken, it is difficult for USCIS to determine the extent to which it is administratively closing or denying cases in accordance with its guidance. GAO recommends that the USCIS Director ensure that available deployment information is collected from all applicants when they file the application; case files document that applicants were notified of processing delays and provided an estimated adjudication date; and case files document actions taken when a case is administratively closed or denied. DHS concurred with GAO's recommendations.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Richard M. Stana Team: Government Accountability Office: Homeland Security and Justice Phone: (202) 512-8816GAO-10-865, Military Naturalizations: USCIS Generally Met Mandated Processing Deadlines, but Processing Applicants Deployed Overseas Is a Challenge
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
July 2010:
Military Naturalizations:
USCIS Generally Met Mandated Processing Deadlines, but Processing
Applicants Deployed Overseas Is a Challenge:
GAO-10-865:
GAO Highlights:
Highlights of GAO-10-865, a report to congressional committees.
Why GAO Did This Study:
From September 2001 to March 2009, approximately 47,000 noncitizen
members of the U.S. military became naturalized U.S. citizens. The
Department of Homeland Security‘s (DHS) U.S. Citizenship and
Immigration Service (USCIS) and the Department of Defense (DOD) have
taken steps to assist noncitizens with applying for naturalization.
The Kendell Frederick Citizenship Assistance Act (Kendell Frederick
Act) and the Military Personnel Citizenship Processing Act (MPCPA),
enacted in 2008 to expedite application processing, each directed GAO
to report on implementation of the acts. This report addresses (1) the
extent to which USCIS met the processing deadlines established in the
acts and (2) actions USCIS has taken to expedite the processing of
applications, and any challenges it has faced. GAO reviewed relevant
legislation and DHS reports and guidance related to processing
applications; reviewed several generalizable samples of applicants‘
case files (A-files); and interviewed USCIS officials.
What GAO Found:
USCIS complied in nearly all cases with the Kendell Frederick Act‘s
requirement that it complete application processing for overseas
service members within 6 months of the final background check. USCIS
complied in an estimated 73 percent of service member cases and 84
percent of spousal cases with the MPCPA‘s requirement that it either
complete application processing within 6 months of receipt or notify
the applicant of the reason for the delay and provide an estimated
adjudication date. For the remaining cases, the applicants‘ files did
not document that the applicant was notified that the application
would not be processed within 6 months, did not provide an estimated
adjudication date in the notification of delay letter, or GAO could
not determine if USCIS met the notification requirements because cases
pending after July 28, 2009, were not included in GAO‘s probability
samples. Without documentation of USCIS‘s actions, it is difficult for
USCIS to determine its adherence to MPCPA‘s requirements.
USCIS took several actions to expedite application processing,
including establishing a military naturalization unit and using
videoconferencing for overseas applicants in war zones, among others;
but receiving incomplete applications, processing applicants stationed
overseas, and identifying all applicants prior to their overseas
deployment pose challenges to timely processing of applications. USCIS
cannot identify all deploying service members because it does not have
procedures for ensuring that available deployment information is
collected from all applicants when they file the application, and this
could result in processing delays. Additionally, not all A-files
contained documentation indicating that USCIS had taken steps to
locate or notify applicants, as required in its April 2009 guidance.
For example, for 9 of 15 cases that were administratively closed
because the applicant had failed to appear for the initial interview,
no documentation was included in the A-file, as required by USCIS‘s
guidance, that a USCIS liaison at the applicant‘s military
installation was contacted in an attempt to locate the service member.
Without documenting all actions taken, it is difficult for USCIS to
determine the extent to which it is administratively closing or
denying cases in accordance with its guidance.
Figure: Service Members Who Became U.S. Citizens during a
Naturalization Ceremony Held at the Al Faw Palace in Baghdad, Iraq:
[Refer to PDF for image: 2 photographs]
Source: Department of Defense.
[End of figure]
What GAO Recommends:
GAO recommends that the USCIS Director ensure that available
deployment information is collected from all applicants when they file
the application; case files document that applicants were notified of
processing delays and provided an estimated adjudication date; and
case files document actions taken when a case is administratively
closed or denied. DHS concurred with GAO‘s recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-10-865] or key
components. For more information, contact Richard M. Stana at (202)
512-8816 or stanar@gao.gov.
[End of section]
Contents:
Letter:
Background:
USCIS Has Generally Met the Processing Deadlines Established in the
Kendell Frederick Act and the MPCPA:
USCIS Has Taken Actions to Expedite Military Naturalization
Processing, but Faces Challenges to Timely Completion of Application
Processing and Could Improve Its Processes Further:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Homeland Security:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Most Frequent Reasons for Delays in Processing Pending
Applications from Service Members at the Nebraska Service Center (NSC)
and Four Field Offices A:
Table 2: USCIS Documentation on Administratively Closed or Denied
Cases:
Table 3: Description of Military Naturalization Sample Populations:
Table 4: Disposition of the File Review Samples for the Eight
Populations of Military Naturalization Applications:
Figures:
Figure 1: Steps in the Military Naturalization Process:
Figure 2: Extent to Which USCIS Met Processing Requirements for
Service Members following Enactment of the MPCPA:
Figure 3: Number of Cases Administratively Closed or Denied from April
15, 2009, through July 9, 2009, by Length of Time Cases Were Open:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
July 29, 2010:
Congressional Committees:
Throughout U.S. history, noncitizens have served in the U.S. military.
From September 2001 to March 2009, approximately 47,000 noncitizen
members of the U.S. military became naturalized U.S. citizens, around
100 of them posthumously. The number of naturalizations for noncitizen
military members increased from 1,146 in fiscal year 2001 to 10,505 in
fiscal year 2009.
Since the United States began its military response to the September
11, 2001, attacks, Congress and the administration have worked to
expedite the process by which noncitizens serving in the military are
granted U.S. citizenship through naturalization.[Footnote 1] For
example, the National Defense Authorization Act for Fiscal Year 2004
reduced the period of peacetime service required for naturalization
from 3 years to 1 year, waived naturalization application fees for
noncitizen service members, required that military naturalization
processing for service members be available overseas, and required
that service members receive priority consideration for military leave
and transport to finalize naturalization. In addition, during
designated periods of hostilities, members of the U.S. armed forces
who serve honorably in an active duty status are eligible to apply for
naturalization without meeting any minimum required period of service.
In addition to statutorily designated periods of hostilities such as
World War I and II, Executive Order 13,269, issued in July 2002,
provided immediate eligibility for naturalization to noncitizens
serving honorably in an active duty status during the global war on
terrorism, beginning on September 11, 2001.[Footnote 2] The Department
of Homeland Security's (DHS) U.S. Citizenship and Immigration Services
(USCIS) and the Department of Defense (DOD) have taken steps to assist
noncitizens serving in the military in applying for naturalization.
To further expedite the processing of military naturalizations, the
Kendell Frederick Citizenship Assistance Act (Kendell Frederick Act)
[Footnote 3] and the Military Personnel Citizenship Processing Act
(MPCPA)[Footnote 4] were enacted in June and October of 2008,
respectively. The Kendell Frederick Act requires DHS to, among other
things, use the fingerprints taken at the time of service members'
enlistment in the military to satisfy background checks for
naturalization applications if certain conditions are met. The act
also requires DHS to centralize the data processing of naturalization
applications filed by members of the military serving abroad and to
ensure that these applications are adjudicated within 180 days of
receipt of responses to all background checks. The Kendell Frederick
Act mandated (1) DHS to submit a report to Congress on the military
naturalization application adjudication process, and (2) within 180
days of DHS's report, GAO and DHS's Office of Inspector General (OIG)
to report on the implementation of the act, including assessments of
any technology that may be used to improve the efficiency of the
naturalization process for members of the military and the impact of
the act on privacy and civil liberties. DHS' OIG issued its report to
Congress in January 2010. In consultation with the appropriate
congressional committees and DHS's OIG, we determined that we would
review the extent to which USCIS met the 180-day processing deadlines,
and the OIG would review the actions taken to implement the Kendell
Frederick Act, including the required technology and privacy
assessments.[Footnote 5] In response to the statutory deadline
established in the Kendell Frederick Act, we provided a congressional
briefing that set forth preliminary information regarding our study in
August 2009.
The MPCPA requires USCIS to, among other things, process and
adjudicate certain military naturalization applications within 6
months of receipt or provide applicants with an explanation for its
inability to meet the deadline and an estimate of the anticipated
adjudication date. This processing requirement applies to applications
filed by current military members who have served honorably,
applications filed on behalf of certain deceased members of the
military, as well as applications filed by the spouses, or the
surviving spouses, children, or parents of such members who are U.S.
citizens. The MPCPA also directs GAO to report to Congress no later
than 180 days after the date of the act's enactment on the results of
a study regarding USCIS's processing time for military naturalization
applications. In response to this requirement, we provided a
congressional briefing in April 2009, which included preliminary
information on our study. Because, at the time of our data collection,
USCIS had not completed processing all military naturalization
applications that had been filed during the 3 months following
enactment of the MPCPA, we were limited in our ability to compute an
average processing time, as called for by the MPCPA. We informed
congressional stakeholders that we could more accurately report the
number of applications that had been filed with USCIS during the 3
months following enactment of the MPCPA and completed within 6 months
of receipt. They agreed that this would satisfy their information
needs.
This report discusses the final results from our studies mandated by
the Kendell Frederick Act and the MPCPA and answers the following
questions:
* To what extent has USCIS met the processing deadlines established in
the Kendell Frederick Act and the MPCPA?
* What actions, if any, has USCIS taken to expedite the processing of
military naturalization applications, and to what extent does it face
challenges to the timely processing of these applications?
To answer these questions, we reviewed the Kendell Frederick Act, the
MPCPA, the National Defense Authorization Act for Fiscal Years 2004
and 2008, and Executive Order 13,269; as well as relevant sections of
Title III of the Immigration and Nationality Act. To determine the
extent to which USCIS has met processing deadlines specified in the
Kendell Frederick Act and the MPCPA, we reviewed separate samples of
alien case files (A-files) from USCIS's listings of applications filed
before and after enactment of the acts. Specifically, we selected and
reviewed:
* random, probability samples of service member applications completed
during the 6-month period preceding enactment of the Kendell Frederick
Act and about 5 ½ months preceding enactment of the MPCPA.[Footnote 6]
We report the results for the pre-Kendell Frederick and pre-MPCPA
probability samples as estimates of the universe of all relevant
service member applications completed during study periods preceding
enactment of each act;
* random, probability samples of service member applications submitted
during the 3-month periods following enactment of each act.[Footnote
7] We report the results for the post-Kendell Frederick and post-MPCPA
probability samples as estimates of the universe of all relevant
service member applications submitted during the 3 months following
enactment of each act;
* all available applications for our post-MPCPA period pending longer
than 6 months that were located at the Nebraska Service Center (NSC)
and in four USCIS field offices.[Footnote 8] Although our results for
these cases are not generalizable to all post-MPCPA service member
cases pending longer than 6 months, we believe that our review of
these applications provided us with important information about such
things as reasons for application processing delays and USCIS's
documentation in A-files of actions taken to notify applicants of
processing delays;
* all applications submitted by the spouses of military members during
the 1-month period following USCIS's January 2009 centralization of
military spouse naturalization applications at the NSC.[Footnote 9]
Our results for this sample apply to all spousal applicants during the
1-month time period we reviewed;
* all applications for posthumous citizenship completed during the pre-
MPCPA period and all posthumous citizenship applications submitted
during the post-MPCPA period. Our results for these samples apply to
all posthumous applications during the pre-and post-MPCPA periods in
our review; and:
* a sample of applications that USCIS administratively closed or
denied as of July 9, 2009, in response to an April 15, 2009,
memorandum that provided guidance for systematically closing cases
that met certain criteria. Our results for this sample are not
generalizable to all cases closed or denied due to the April 15, 2009,
memorandum because we did not receive information from USCIS that
enabled us to determine the total number of applications
administratively closed or denied due to the memorandum during the
period. Even so, we believe that our review of these applications
provided us with important information about such things as USCIS's
actions to locate applicants who failed to appear for an interview or
respond to a request for evidence, and USCIS's documentation in A-
files of actions taken to administratively close or deny applications
due to the April 15 memorandum.
We reviewed applicants' A-files to determine, among other things, how
long USCIS took to process military naturalization applications,
whether USCIS provided an explanation to applicants if it could not
complete application processing within 6 months, whether the applicant
was stationed overseas or domestically at any point in the
naturalization process, reasons why applications may not have been
processed within mandated time frames, and whether USCIS was closing
or denying certain cases consistent with its own guidance. Our A-file
reviews were conducted at the following USCIS locations: the NSC in
Lincoln, Nebraska; National Records Center in Lee's Summit, Missouri;
and field offices in Los Angeles, California, Norfolk, Virginia, San
Diego, California, and Rome, Italy[Footnote 10]--four of the offices
with the highest number of pending service member applications
submitted during the 3 months following enactment of the MPCPA. We
reviewed a total of 464 A-files at these locations.
To determine what actions, if any, USCIS has taken to expedite the
processing of military naturalization applications, and the extent to
which USCIS faces key challenges to timely application processing, we
reviewed USCIS reports, memorandums, and guidance related to
processing military naturalization applications, as well as standards
for internal controls in the federal government.[Footnote 11] We
interviewed officials at USCIS headquarters, the NSC, and four of the
USCIS field offices with the highest number of pending service member
applications submitted in the post-MPCPA period. We also interviewed
cognizant officials at the Department of Justice's Federal Bureau of
Investigation (FBI); DOD; Army, Navy, and Marine Corps service
components; and the Office of Personnel Management; and reviewed
relevant documentation to determine the actions they have taken in
coordination with USCIS to help expedite the processing of military
naturalization applications. Additional details on our scope and
methodology are included in appendix I.
We conducted this performance audit from February 2009 through July
2010 in accordance with generally accepted government auditing
standards. These standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Background:
Application Process:
The Immigration and Nationality Act (INA) contains special provisions
governing the naturalization process for noncitizen members of the
U.S. military, both living and deceased. Eligibility requirements vary
depending upon the type of military service, although the service must
be honorable. To apply for naturalization, the service members
complete an application package and submit fingerprints, which are
used to conduct a background check.
Initial processing of military naturalization applications is
completed by a specialized military naturalization unit at USCIS NSC
in Lincoln, Nebraska. Staff at the NSC is to examine application
packages for completeness, begin conducting initial background checks
on the applicant, and place forms and information regarding the
applicant into an A-file. If an application is incomplete, USCIS is to
send a request for information to the military applicant's last known
address. After initial processing of the application is completed at
the center, the A-file is transferred to the USCIS field office
closest to where the applicant is based, or the location the applicant
requested, for the next phase of the application process.
Military applicants are to be scheduled for naturalization interviews
as soon as possible after the A-file arrives at the USCIS field
offices--generally within 30 days of its arrival. USCIS adjudicators
are to ensure that all background checks are valid and review the A-
file, prior to the naturalization interview, to determine if an
applicant has been involved in any disqualifying activity. At the
naturalization interviews, USCIS officers are to test applicants'
ability to read, write, and speak English; and administer a civics
test to determine the applicants' understanding of U.S. history and
government. If the applicant successfully passes these tests and is
otherwise eligible to naturalize, and there are no outstanding issues,
such as pending court cases, the application is approved and the
applicant is scheduled for the naturalization ceremony. In most cases,
according to USCIS officials, the naturalization ceremony can be
scheduled quickly, especially if a service member is about to be
deployed. Figure 1 provides a description of the military
naturalization process.
Figure 1: Steps in the Military Naturalization Process:
[Refer to PDF for image: illustration]
1) Applications received at Nebraska Service Center (NSC) and sent to
military naturalization unit.
2) Background security checks initiated at NSC or USCIS field offices
(name, fingerprint, and DOD background).
3) Application package checked for completeness.
Information or documents received complete, continue; If incomplete,
go to step 8.
4) Background checks and application successfully completed,
applicant‘s file sent to USCIS field office.
5) Applicant appears for interview.
* Applicant does not appear for interview;
* Additional attempts made to establish contact with the applicant. Is
contact made?
If yes: Interview rescheduled;
If no: Application administratively closed or denied.
6) Interview conducted.
7) Application adjudicated. Is application approved?
If yes: applicant naturalized;
If no: Application denied. Applicant not naturalized.
Information or documents received incomplete:
8) Request sent to applicant for outstanding information or documents.
9) Information or documents received.
10) Domestic applicants: Application administratively closed or denied.
Overseas applicants: Application remains pending.
Source: GAO analysis of USCIS procedures; and Art Explosion (clipart).
Note: The figure reflects major activities in the military
naturalization process.
[End of figure]
2008 Legislation to Expedite Military Naturalization Applications:
The Kendell Frederick Citizenship Assistance Act (Kendell Frederick
Act) was enacted on June 26, 2008, to streamline and expedite the
processing of military naturalization applications. The act was named
in honor of U.S. Army Reserve Specialist Kendell Frederick, who was
killed in Iraq while seeking to obtain U.S. citizenship. Over a 1-year
period, Specialist Frederick experienced several delays to having his
naturalization application processed, culminating in a requirement
that he travel to another base in Iraq to provide fingerprints for his
naturalization application. Specialist Frederick was killed en route
by a roadside bomb and USCIS posthumously granted him U.S. citizenship.
The Kendell Frederick Act contains several provisions to facilitate
the naturalization process for members of the military who are
eligible to be naturalized under sections 328 or 329 of the
Immigration and Nationality Act (INA). Section 328 of the INA is a
naturalization provision available to currently enlisted and recently
separated members of the U.S. armed forces who are lawful permanent
residents and have served honorably for a year or more. Section 329 of
the INA is a naturalization provision available to current service
members and veterans who need not be lawful permanent residents, and
who have served honorably in an active-duty status or in the Selected
Reserve of the Ready Reserve during designated periods of conflict,
including from September 11, 2001, to the present.[Footnote 12]
Section 329A of the INA is a naturalization provision for posthumous
citizenship available to service members who die as a result of their
service during a designated period of hostility.[Footnote 13]
The Kendell Frederick Act requires DHS to use the enlistment
fingerprints of these military members to satisfy background checks
for naturalization applications if certain conditions are met, such as
the submission of a naturalization application within 24 months of
enlistment. It also requires coordination between DHS, DOD, and the
FBI to implement procedures that will ensure the rapid electronic
transmission of biometric information between agencies, while
safeguarding privacy and civil liberty interests. The act includes
special provisions related to naturalization applications filed by
members of the military who are both on active duty and serving
abroad, including centralized data processing of their applications.
It establishes an expedited processing deadline for these
applications, requiring that they be adjudicated within 180 days of
receipt of responses to all background checks. The act does not
establish a deadline for adjudicating the naturalization applications
of other military members; that is, those who are not serving overseas
in an active-duty status.
The Military Personnel Citizenship Processing Act (MPCPA) was enacted
on October 9, 2008, to further expedite the processing of military
naturalization applications. The MPCPA requires USCIS to process and
adjudicate certain military naturalization applications within 6
months of receipt. These include applications from currently serving
service members applying under section 328 or 329 of the INA, current
spouses of current service members applying under section 319(b) of
the INA, surviving military spouses, children, and parents applying
under section 319(d) of the INA,[Footnote 14] as well as posthumous
applicants who die as a result of service during a period of
hostility. If unable to process these applications within 6 months of
receipt, USCIS is required to provide the applicant with an
explanation for its inability to meet the 6-month deadline and an
estimate of the date by which the application would be adjudicated.
In fiscal year 2010, Congress provided $5 million to cover the
estimated cost to USCIS of processing military naturalization
applications.
USCIS Has Generally Met the Processing Deadlines Established in the
Kendell Frederick Act and the MPCPA:
Following enactment of the Kendell Frederick Act, USCIS met the act's
processing deadline requirement for nearly all service members who
served overseas on active duty at some point during the application
process. Following enactment of the MPCPA, USCIS completed processing
an estimated 71 percent of service member applications within 6 months
of receipt of the application. In an additional 2 percent of cases,
USCIS met the MPCPA's requirement that, when applicable, it notify
applicants of a processing delay and provide them with an estimated
completion date, making USCIS fully compliant with the MPCPA in a
total of 73 percent of cases. Following enactment of the MPCPA, USCIS
also completed 84 percent of applications from spouses and all
posthumous applications within 6 months of receipt. Applicants' A-
files sometimes did not contain documentation showing that USCIS
complied with the MPCPA's notification requirements.
USCIS Completed Nearly All Military Naturalization Cases within the 6-
Month Deadline Established by the Kendell Frederick Act:
Both before and after enactment of the Kendell Frederick Act, for
service members who served overseas in an active duty status at any
time during their application process, USCIS met the act's processing
deadline requirement by completing processing nearly all applications
within 6 months of the final background check. Specifically, of 442
naturalization applications that service members filed during the 3
months following enactment of the Kendell Frederick Act, we estimate
that USCIS completed processing 98 percent of applications within 6
months of completing the applicant's background checks.[Footnote 15]
Of 1,278 naturalization applications from service members that USCIS
completed processing during the 6 months preceding enactment of the
Kendell Frederick Act, we estimate that USCIS completed processing 97
percent of the applications within 6 months of completing the
applicant's background and national security checks.[Footnote 16]
USCIS was able to meet the deadline requirements of the Kendell-
Frederick Act in such a high percentage of cases because USCIS policy
calls for conducting four types of background and national security
checks as early in the application process as possible; and one of
these four types of checks--the Interagency Border Inspection System
(IBIS) check of law enforcement data on individuals--is to be
conducted every 6 months thereafter.[Footnote 17] Because IBIS checks
are to be conducted every 6 months, almost all cases will meet the
Kendell Frederick Act's deadline of adjudicating overseas, active-duty
military naturalization applications within 6 months of receiving
responses to all background and national security checks.[Footnote 18]
In our review of service member applications from the pre-and post-
Kendell Frederick Act periods, we found that USCIS also conducted a
final IBIS check prior to the naturalization oath.
USCIS Completed over 70 Percent of Military Naturalization
Applications within MPCPA's Deadline, but Did Not Always Document
Compliance with Notification Requirements:
Percentage of Service Member Applications Completed within 6 Months of
Receipt Increased Significantly after Enactment of the MPCPA:
Our A-file review of a probability sample selected from 1,932
naturalization applications filed by service members during the 3
months following enactment of the MPCPA found that USCIS completed
processing an estimated 71 percent of the applications within 6 months
of receipt, and did not complete processing an estimated 29 percent
within this time period. Completing processing of 71 percent of
service members' naturalization applications within 6 months of
receipt was a significant increase compared to USCIS's processing time
during the period preceding enactment of the MPCPA. Of 4,533
applications from service members that USCIS completed processing
about 5 ½ months preceding enactment of the MPCPA, an estimated 30
percent were completed within 6 months of receipt, while 70 percent
took longer than 6 months to complete.[Footnote 19] USCIS officials
said that several factors limited the agency's ability to process a
higher percentage of military naturalization applications prior to
enactment of the MPCPA, including a surge in the total number of
naturalization applications filed in 2007 prior to an application fee
increase and the 2008 Presidential election, which placed a strain on
USCIS's adjudication resources, overall.
Documentation That USCIS Notified Applicants of Processing Delays and
Provided an Estimated Adjudication Date Was Not Always Included in
Service Members' A-Files:
The MPCPA requires USCIS to notify applicants of a processing delay
and an estimate of the date by which the application would be
adjudicated if their cases will take longer than 6 months to process.
By reviewing the applications in our sample that USCIS did not
complete processing within 6 months of receipt, we estimated the
percent of all 1,932 applications that fully met the notification
requirements, partially met the notification requirements, and did not
meet the notification requirements; as well as the percent for which
we could not determine whether USCIS met the notification
requirements. These results are as follows:
* In an estimated 2 percent of the case files, USCIS fully met
notification requirements. That is, the A-files contained letters
notifying service members that the application would not be processed
within 6 months, and the letters provided an estimated adjudication
date.
* In an estimated 3 percent of the A-files, USCIS partially met the
notification requirements. That is, the A-files contained a letter
notifying the service member that the application would not be
processed within 6 months, but the letter did not provide an estimated
adjudication date.
* In an estimated 7 percent of the A-files, USCIS did not meet the
notification requirements. That is, the A-files did not contain
documentation that USCIS notified the service member that the
application would not be processed within 6 months and did not contain
an estimated adjudication date.
* In an estimated 17 percent of the A-files, we were unable to observe
whether USCIS met the MPCPA's notification requirements. That is, we
could not determine if USCIS provided an explanation of its inability
to meet the deadline or an estimated completion date because we did
not include cases that remained pending after July 28, 2009, in our
probability sample. It is possible, therefore, that our findings that
USCIS fully complied with the requirements of the MPCPA for an
estimated 73 percent of service member applications (71 percent that
were processed within 6 months plus 2 percent that met the MPCPA's
processing delay notification requirements) is understated. Figure 2
shows our post-MPCPA findings for service members.
Figure 2: Extent to Which USCIS Met Processing Requirements for
Service Members following Enactment of the MPCPA:
[Refer to PDF for image: pie-chart]
Met MPCPA requirements: 73%;
Partially met MPCPA requirements: 3%;
Did not meet MPCPA requirements: 7%;
Unable to observe: 17%.
Source: GAO analysis of USCIS data.
[End of figure]
Our review of a separate sample of 74 service member cases pending in
four USCIS field offices similarly found that applicants' A-files
sometimes did not contain documentation that USCIS met the
notification requirements of the MPCPA. In this sample, we reviewed
only cases that USCIS did not complete processing within 6 months of
application receipt. Of the 74 cases reviewed, we found the following:
* In 31 cases (42 percent), USCIS fully met the notification
requirements. That is, the A-files contained letters notifying service
members that the application would not be processed within 6 months,
and the letters provided an estimated adjudication date.
* In 28 cases (38 percent), USCIS partially met the notification
requirements. That is, the A-files contained a letter notifying the
service member that the application would not be processed within 6
months, but the letter did not provide an estimated adjudication date.
* In 15 cases (20 percent), USCIS did not document that any action was
taken to notify the applicant. That is, the A-files did not contain
documentation that USCIS notified the service member that the
application would not be processed within 6 months and did not contain
an estimated adjudication date.
For the 15 cases where USCIS did not document that it took any action
to notify applicants of processing delays and provide them with an
estimated adjudication date, we could not determine whether USCIS
staff carried out the MPCPA's notification requirements but did not
document their efforts, or if USCIS staff did not carry out the
requirements. According to USCIS field office and headquarters
officials, human error on the part of USCIS staff was the explanation
for why some A-files lacked documentation that the notification
requirements were met. Standards for internal control require agencies
to document that transactions and other significant events are
complete and accurate, and are useful to managers in controlling their
operations and to any others involved in evaluating or analyzing
operations. Additionally, USCIS requires that copies of information
regarding all transactions, including outgoing correspondence, be
retained in the A-files of individuals as they pass through the U.S.
immigration process. USCIS personnel may have carried out the
notification requirements of the MPCPA without documenting that they
did so, but improving quality assurance measures to ensure that such
documentation is placed in A-files could help USCIS validate the
actions taken, assess USCIS's performance, and have reasonable
assurance that the notification requirements of the MPCPA were met.
USCIS officials acknowledged that improving the military
naturalization program's quality assurance measures, such as by
increasing communication with application processing staff or creating
additional checklists, or both, to enhance staff's awareness of the
need to document transactions, could help reinforce the requirement
that all actions taken be documented and ensure that USCIS has
complete and accurate information on efforts it has made to comply
with the requirements of the MPCPA.
USCIS Completed the Majority of Applications from Spouses within the
MPCPA's Deadline, but Did Not Always Document Compliance with
Notification Requirements:
Our A-file review found that within 6 months of receipt, USCIS
completed processing 47 (84 percent) of all 56 applications filed by
spouses of service members from January 22, 2009, through February 22,
2009. This period is the month following USCIS's centralization of
military spouse naturalization applications at the NSC. In 2 cases (4
percent), applicants' A-files did not document that USCIS notified the
spouse that it would not complete processing the application within 6
months. We could not determine for the remaining 7 spousal cases (12
percent) if USCIS provided an explanation of its inability to meet the
deadline or an estimate of the completion date because they remained
pending as of August 31, 2009, and we did not include them in our
sample. As with the applications from service members, USCIS explained
that human error on the part of USCIS staff was the reason why some A-
files lacked documentation that the notification requirements were met.
We were unable to determine whether, or to what extent, the processing
time for applications from spouses had improved because military
spouse applications are entered into USCIS's automated systems the
same way as all non-military naturalization cases and, once entered,
cannot be systematically separated from non-military spouse
applications. Therefore, USCIS could not identify military spouse
naturalization cases prior to its centralizing the processing of such
cases at the NSC in January 2009, and we did not have a listing of
these cases for the period preceding enactment of the MPCPA.
USCIS Met the MPCPA Processing Deadline for All Posthumous Cases:
During both the pre-and post-MPCPA periods, USCIS completed processing
within 6 months all posthumous applications submitted on behalf of
service members. This included 6 applications submitted before, and 1
application submitted after enactment of the MPCPA.
USCIS Has Taken Actions to Expedite Military Naturalization
Processing, but Faces Challenges to Timely Completion of Application
Processing and Could Improve Its Processes Further:
To expedite the military naturalization process, USCIS took a number
of actions, including establishing a military naturalization unit and
using videoconferencing for overseas applicants in war zones, among
others. However, USCIS faces challenges in completing some military
naturalization applications in a timely fashion because some
applications contain incomplete information and USCIS's information
about service members' deployment overseas is limited. In addition,
USCIS issued guidance in April 2009 to ensure that there would be a
systematic approach for administratively closing and denying
applications that could not be resolved when USCIS lacked sufficient
evidence to adjudicate the case, but the extent to which USCIS has
complied with its guidance is unclear.
USCIS Took a Number of Actions Both before and after Enactment of the
Kendell Frederick Act and MPCPA to Expedite the Military
Naturalization Process:
During the period 2000 to 2010, USCIS took several steps to expedite
the processing of military naturalization applications. Specifically,
USCIS established a unit to process military naturalization
applications, initiated an outreach program at military installations,
increased coordination with DOD and the FBI on military naturalization
issues, deployed mobile fingerprint technology, began submitting USCIS
fingerprints to the FBI for rechecking, began using videoconferencing
for naturalization interviews, and created additional information
sources on the military naturalization process. According to USCIS
officials, a number of these actions were already in place at the time
of enactment of the Kendell Frederick Act and the MPCPA. Below we
describe in greater detail the actions USCIS took.
* Military naturalization application processing unit established. In
February 2000, USCIS established the Military Naturalization Unit at
its NSC. This unit is responsible for carrying out the up-front
processing tasks for all military naturalization applications, such as
reviewing forms for completeness and conducting background checks.
According to USCIS officials, USCIS worked closely with service
members and DOD points of contact to help ensure efficient processing
of these applications. As of June 2010, the military naturalization
unit consisted of 23 staff members.[Footnote 20]
* Increased coordination with DOD. USCIS officials stated that since
2000 USCIS has met periodically, and since 2008 quarterly, with
cognizant DOD components, conducted training sessions on an as-needed
basis with DOD points of contact for immigration issues, and held
information sessions for service members at both domestic and overseas
military installations. In June 2008, USCIS initiated an outreach
program that requires, among other things, that USCIS field officials
work with (1) DOD officials at military installations within their
jurisdiction to develop and conduct seminars on the military
naturalization process for service members and their families; and (2)
their military counterparts and the NSC to create a monthly program
for USCIS officers to discuss individual immigration cases, and
conduct naturalization interviews and ceremonies at military
installations. According to USCIS, its outreach efforts resulted in
1,272 military naturalizations in fiscal year 2009, and 569 military
naturalizations during the first 4 months of fiscal year 2010.
[Footnote 21] The majority of USCIS's outreach programs in fiscal year
2010 were held at the following six military installations: Ft.
Jackson, South Carolina; Ft. Bliss, Texas; Ft. Sill, Oklahoma; Ft.
Benning, Georgia; Ft. Leonard Wood, Missouri; and Camp Lejuene, North
Carolina. USCIS officials told us they have been working to expand
naturalizations at basic training and that USCIS is placing emphasis
on scheduling interviews and performing naturalization ceremonies
prior to service members being deployed overseas. In August 2009,
USCIS and the Army launched an initiative to conduct outreach to new
enlistees at the Army's five basic training sites, providing
noncitizen enlistees an opportunity to naturalize prior to the
completion of basic training. USCIS officials stated that they
expected additional progress to be made as a result of the combined
efforts of USCIS and the military branches, and the naturalization
process to be expanded to basic training sites across the DOD. In
September 2008, USCIS established the Military Liaison Working Group,
comprised of USCIS officials, which meets to discuss topics such as
new legislation, challenges to locating service members, processing
improvements, and best practices.
* Increased coordination with the FBI. USCIS has worked with the FBI
to expedite the completion of name checks, a required part of USCIS's
process for conducting background checks on all naturalization
applicants. In March 2008, USCIS and the FBI jointly established
milestones for completing pending name checks, and established a goal
for completing 98 percent of all USCIS name checks within 30 days and
the remaining 2 percent in up to 90 days. According to the FBI, it met
the established goals in June 2009. USCIS established an FBI liaison
in the agency's Domestic Operations Directorate in March 2009. The
USCIS liaison to the FBI is responsible for coordinating with the FBI
to expedite name checks and background checks for military
naturalization applications.
With respect to the use of enlistment fingerprints to satisfy
background checks for military naturalization applicants, a recent
upgrade to the Office of Personnel Management's fingerprint
transaction system should enable the FBI to more quickly retrieve
fingerprints than in the past. This is because the Office of Personnel
Management has created an indicator in its system that identifies
which fingerprints are military fingerprints. We believe that this
change, which went into effect on June 14, 2010, should eliminate the
need for FBI staff to manually search for enlistment fingerprints
within the Office of Personnel Management's entire population of
fingerprints on DOD military, civilian, and contractor personnel. As a
result, the FBI's ability to locate enlistment fingerprints should be
considerably faster than the 2 weeks to more than 90 days it had
previously taken to locate such fingerprints.[Footnote 22]
* Mobile fingerprint technology deployed, mostly domestically. To
assist military naturalization applicants stationed within the United
States with providing fingerprints for background checks, USCIS has
begun to use mobile fingerprinting units at some military
installations that are distant from Application Support Centers.
[Footnote 23] As of March 1, 2010, USCIS had deployed 100 mobile
fingerprinting units for domestic use.[Footnote 24] According to USCIS
officials, the availability of mobile fingerprint units has sped up
USCIS's ability to naturalize applicants prior to their being deployed
overseas. For its overseas offices, USCIS purchased 30 mobile
fingerprint units during fiscal year 2008 and deployed them from
November 16, 2009, through February 1, 2010, though officials noted
that these units are intended primarily for refugee and other
immigrant processing. They stated that while the mobile fingerprint
units might more likely be used to fingerprint military spouses than
service members overseas because the spouses are not stationed in war
zones, it is more convenient for both spouses and service members to
use their local military police, personnel office, or legal assistance
office to take the fingerprints for submission to USCIS.
* Resubmission of USCIS fingerprints to the FBI. In March 2009, USCIS
issued guidance to overseas offices on resubmitting electronic
fingerprints to the FBI in military naturalization cases where
fingerprint clearances had expired. DHS policy requires that
fingerprints be rerun to determine if any new information arose during
the previous 15 months that could disqualify the applicant from
eligibility for citizenship. USCIS reported that the fingerprint
resubmission process has reduced the need for service members
stationed in war zones overseas to travel to be fingerprinted, thereby
reducing their risk of being harmed.
* Videoconferencing used for overseas applicants in war zones. USCIS
is currently using videoconferencing technology to conduct preliminary
naturalization interviews with service members stationed in
Afghanistan. From October 2009 through April 2010, the Bangkok
district office conducted over 75 preliminary interviews using
videoconferencing technology with service members in Afghanistan.
Officials said the preliminary interviews lasted about 25 to 30
minutes, and provided USCIS the opportunity to correct any
deficiencies on the application, prepare sworn statements, review
court dispositions, and conduct the naturalization test. USCIS
officials said that Bangkok office staff traveled to Afghanistan and
other military installations to conduct the final interview, witness
the service member signing the naturalization certificate, and
administer the naturalization oath. USCIS officials said that during
the first quarter of fiscal year 2011, the agency plans to implement a
pilot test overseas that will measure the pros and cons of using video
technology for service members deployed to combat zones during some or
all of the military naturalization process. USCIS officials said that
using videoconferencing technology for naturalization interviews poses
a greater challenge in some combat zones because the military command
uses this equipment and it is not readily accessible or available to
USCIS.[Footnote 25]
* New information sources on application process created. In August
2007, USCIS established a toll-free Military Helpline and an e-mail
address to provide military naturalization applicants additional
opportunities to obtain answers to their questions about the
naturalization process. The helpline is intended to provide live
assistance to applicants and enable them to update information on
their application, such as a change of address or a change in their
duty station.
Incomplete Information on Applications and Limited Information about
Overseas Deployment Are Challenges to Timely Completion of Some
Military Naturalization Applications:
USCIS's ability to complete processing military naturalization
applications in a timely manner is affected by several factors. These
include USCIS receiving applications with incomplete information, not
consistently identifying applicants with imminent overseas deployment
plans, and facing particular challenges with processing applicants who
are stationed overseas.
* Naturalization applications submitted with incomplete information.
USCIS officials said they encountered processing delays because
applicants frequently did not submit a naturalization application
package with complete information. For example, specific to military
naturalizations is the Request for Certification of Military or Naval
Service (Form N-426), a form that service members must submit to DOD
to obtain authenticated certification of military service. According
to USCIS officials, incomplete or missing Forms N-426 was the primary
reason for delays in the military naturalization application process.
USCIS revised the form in March 2009 to make it easier to understand
and complete. In February 2010, USCIS also eliminated the requirement
that service members submit a biographic information form (Form G-
325B) with the naturalization application. According to USCIS
officials, information on the form was redundant and, prior to this
change, application processing was delayed until the applicant
submitted this form. Further, according to USCIS officials, the
contact information provided in the military naturalization
application is often a permanent address and not where the applicant
is located when on duty. USCIS officials said they have encouraged DOD
liaisons to review the naturalization application packages for
completeness before the applications are submitted to USCIS for
processing.
* Applicants with imminent overseas deployment plans are not
consistently identified. USCIS has identified some military
naturalization applicants prior to their being deployed overseas, but
it has not consistently identified applicants with imminent deployment
plans. According to USCIS officials, an agency goal is to process and
complete processing military naturalization applications before the
applicant is deployed overseas. Moreover, internal control standards
for the federal government state that an agency's internal control
activities should provide reasonable assurance that the objectives of
the agency are being achieved. However, USCIS is currently limited to
learning about service members' upcoming overseas deployment during
its outreach activities at military installations, when DOD points of
contact at military installations take the initiative to inform the
local USCIS field office of a deployment, or when service members
independently notify USCIS of their deployment orders. According to
USCIS officials, NSC and field office staff take steps to expedite
these high priority cases when they learn about them. However, USCIS
does not have procedures in place to proactively and systematically
identify priority military naturalization cases at the start of the
naturalization process.
When service members mail their applications to the NSC, they may or
may not provide information related to their deployment status. USCIS
does not request that such information be provided either on the
naturalization application or the instructions accompanying the
application. If a service member knows that he or she will be deployed
but does not note this in the application package or otherwise notify
USCIS, USCIS would not be in a position to give priority to an
applicant who will be deployed imminently. In the absence of
information on deployment status, USCIS officials told us that
applications are generally processed on a first-come, first-served
basis.
Based on our file review of military naturalization applicants that
DOD data indicated were deployed overseas at some point during the
application process, we found that USCIS A-files contained no
documentation of overseas deployment for an estimated 7 percent of the
1,278 pre-Kendell Frederick Act and 9 percent of the 442 post-Kendell
Frederick Act service member applicants. We do not know how many, if
any, of these service members filed their applications in the United
States prior to overseas deployment, and the Kendell Frederick Act
does not require USCIS to maintain such documentation. However, it is
possible that some of these service members filed their application
domestically and were then deployed overseas. Developing procedures to
collect information at the start of the naturalization application
process about all service members' deployment plans could help USCIS
be better informed about whether or not a service member expects to be
deployed and assist it in determining which applications to designate
for priority processing. As a result, USCIS would be better positioned
to meet its goal of completing processing of military naturalization
applications before the applicant is deployed overseas.
USCIS officials acknowledged that the agency does not have procedures
for proactively and systematically collecting up-front deployment
information from all military naturalization applicants. They noted
that USCIS is currently in the process of revising the naturalization
application, and that it may be feasible to request deployment
information on the naturalization application itself, on the
instructions accompanying the application, or on USCIS's military
naturalization Web site. Such steps could help ensure that USCIS has
consistent, systematic information to enable it to determine which
applicants may soon be leaving the country and require expedited
processing of their naturalization applications.
* Processing applicants stationed overseas can pose particular
challenges to timely application processing. Our review of pending
cases that USCIS did not complete within 6 months of application
receipt suggested that service members who had been stationed
overseas, and particularly those stationed in Iraq, posed particular
challenges to USCIS completing the application within the time frame
required by the MPCPA. Our review of 74 pending cases at USCIS's NSC,
and in Los Angeles, California, Norfolk, Virginia, San Diego,
California, and Rome, Italy--four of the offices with the highest
number of pending service member applications submitted during the 3
months following enactment of the MPCPA--indicated that 46 (62
percent) of the applicants were stationed overseas at some point
during the application process, and 28 (38 percent) were stationed in
the United States. Of the 46 overseas applicants stationed overseas,
20 (43 percent) were stationed in Iraq, 1 (2 percent) was stationed in
Afghanistan, and 25 (54 percent) were stationed in other overseas
locations.
Applicants stationed overseas had more delays associated with the
interview and changes with the applicant's jurisdiction than
applicants stationed in the United States. For example, the
naturalization interview was a reason for application processing being
delayed in 37 percent of the 46 pending applications from service
members stationed overseas and 14 percent of the 28 pending
applications from service members stationed domestically. The service
member moving to a new jurisdiction was a reason for application
processing being delayed in 33 percent of pending applications from
service members stationed overseas and 4 percent of 28 pending
applications from service members stationed domestically. Table 1
below presents information on these and the other most frequent
reasons we found for delays in USCIS pending cases in the select field
offices.
Table 1: Most Frequent Reasons for Delays in Processing Pending
Applications from Service Members at the Nebraska Service Center (NSC)
and Four Field Offices[A]:
Reason for delay: Naturalization interview[C];
Overseas applicants[B](N = 46 service members):
Number of delays: 17;
Percent of delays: 37%;
Domestic applicants[B](N = 28 service members):
Number of delays: 4;
Percent of delays: 14%.
Reason for delay: Service member moved to new jurisdiction;
Overseas applicants[B](N = 46 service members):
Number of delays: 15;
Percent of delays: 33;
Domestic applicants[B](N = 28 service members):
Number of delays: 1;
Percent of delays: 4.
Reason for delay: Obtaining and processing[C] fingerprints;
Overseas applicants[B](N = 46 service members):
Number of delays: 8;
Percent of delays: 17;
Domestic applicants[B](N = 28 service members):
Number of delays: 2;
Percent of delays: 7.
Reason for delay: Application incomplete;
Overseas applicants[B](N = 46 service members):
Number of delays: 6;
Percent of delays: 13;
Domestic applicants[B](N = 28 service members):
Number of delays: 9;
Percent of delays: 32.
Reason for delay: Oath ceremony[C,D];
Overseas applicants[B](N = 46 service members):
Number of delays: 4;
Percent of delays: 9;
Domestic applicants[B](N = 28 service members):
Number of delays: 10;
Percent of delays: 36.
Source: GAO analysis of USCIS A-files.
Notes: These applications from service members stationed overseas at
some point during the application process were received by USCIS from
October 9, 2008, through January 9, 2009, and were pending as of July
28, 2009.
[A] The field offices are Los Angeles, California, Norfolk, Virginia,
San Diego, California, and Rome, Italy.
[B] The number of delays does not sum to the number of applicants, and
the percentages do not sum to 100 percent because some applications
experienced multiple reasons for delays and some applications
experienced delays that occurred infrequently (2 times or less) for
both overseas and domestic applications, and were therefore not
included in the table. When delays occurred infrequently for one group
but not the other, the results are included in the table (e.g., 1
domestic applicant experienced a delay because he/she moved to a new
jurisdiction, whereas 15 overseas applicants experienced this same
reason for a delay).
[C] We did not collect data on the reasons delays occurred with the
naturalization interview; obtaining and processing fingerprints; and
the oath ceremony.
[D] Our finding that the oath ceremony delayed application processing
in 10 of 28 (36 percent) of pending domestic applications reviewed
compared to 4 of 46 (9 percent) of pending overseas applications
reviewed may possibly be explained by differences in the oath
administration process. In domestic cases, courts have the discretion
to administer the naturalization oath to persons residing within their
jurisdiction. If the court exercises its discretion to administer the
oath--rather than waiving its authority and permitting USCIS to do so--
then applicants may need to wait for up to 45 days for the
naturalization ceremony because the court maintains statutory
jurisdiction to administer the oath for 45 days from the date on which
USCIS certifies to the court that an applicant is eligible for
naturalization. In overseas cases, in contrast, USCIS officials
generally administer the oath within 1 day of the interview, and
sometimes on the same day. As a result, delays in completing the
naturalization interview may more directly affect delays in the oath
ceremony for overseas cases than for domestic cases.
[End of table]
In Iraq and Afghanistan, USCIS faces delays in completing
naturalization applications because of limitations imposed by DOD on
USCIS staff accessing areas of conflict to avoid distracting service
members from their mission priorities. DOD generally limits USCIS to
conducting four visits to Iraq and two visits to Afghanistan each
fiscal year to conduct interviews and naturalization oaths. Given such
limitations, it can be especially difficult for USCIS to meet the
MPCPA processing deadline requirement for service members stationed in
these war zones.
Extent to Which USCIS Has Complied with Its Guidance for
Administratively Closing and Denying Applications Is Unclear:
In April 2009, USCIS issued guidance that contained time parameters
for administratively closing or denying a case when an applicant fails
to appear for an interview or respond to a request for evidence;
however, because of missing documentation in applicants' A-files, our
review could not confirm that USCIS was consistently following its
guidance. USCIS officials said that although they could
administratively close or deny applications prior to the April 2009
guidance, many USCIS field offices kept military naturalization cases
open for extended periods of time in order to be flexible with
military applicants with whom they had lost contact or who failed to
appear or respond to information requests. The April 2009 guidance was
issued so that USCIS field offices would have a systematic approach to
closing and denying cases that could not be resolved when USCIS lacked
sufficient evidence to adjudicate the case. They said that many such
cases had previously remained open at USCIS field offices for extended
periods of time to allow the service members every opportunity to
complete the application process, which negatively affected processing
times. According to USCIS officials, military naturalization cases
that are administratively closed or denied under the April 2009
guidance can be reopened and processing continued with no adverse
effect on applicants if they subsequently reestablish contact with
USCIS about their naturalization application.
The April 2009 guidance identified five conditions under which a
naturalization case could be administratively closed or denied. These
conditions included the applicants' failure to (1) appear for the
initial interview; (2) appear for fingerprinting at the Application
Support Center; (3) appear for subsequent scheduled interviews or
respond to subsequent requests for evidence; (4) provide evidence
requested before the initial interview; and (5) comply with a request
for appearance at the naturalization oath ceremony. The guidance also
specified the actions that adjudicators were to take before closing
the case, time frames for completing the actions, and documentation
indicating that adjudicators took the required actions.
We reviewed 42 randomly selected cases that were administratively
closed or denied from April 15, 2009 (the date that USCIS issued its
guidance) through July 9, 2009 (the most recent date for which USCIS
had available data at the time of our information request). We found
that the average length of time for USCIS to close or deny 41 of these
cases was 22 months.[Footnote 26] Six cases had been open for at least
3 years before USICS closed or denied them, with the longest having
been open for 6-½ years. Figure 3 below presents information on the
length of time the cases were open before USCIS decided to
administratively close or deny them.
Figure 3: Number of Cases Administratively Closed or Denied from April
15, 2009, through July 9, 2009, by Length of Time Cases Were Open:
[Refer to PDF for image: vertical bar graph]
Length of time cases are open:
Under 6 months:
Number of cases: 7.
6 months up to 1 year:
Number of cases: 10.
1 year up to 2 years:
Number of cases: 7.
2 years up to 3 years:
Number of cases: 11.
3 years or more:
Number of cases: 6.
Source: GAO review of USCIS A-files.
[End of figure]
In our analysis of 42 cases administratively closed or denied under
the April 2009 guidance, we found that 15 were closed because the
applicant failed to appear at the initial interview; 15 were closed
for miscellaneous other reasons;[Footnote 27] 10 were denied because
the applicant failed to provide fingerprints; and 2 were denied
because the applicant failed to respond to subsequent requests for
evidence. For the 42 cases, we sought to determine what actions, as
required by the April 2009 guidance, USCIS took to locate and notify
applicants that had failed to appear for an initial interview or
failed to provide fingerprints or additional evidence. USCIS's actions
included searching databases, contacting military liaisons, or mailing
a second request for evidence to the applicant, or a combination. In a
number of instances, A-files did not contain documentation indicating
that USCIS had taken steps to locate or notify applicants, as required
in its April 2009 guidance. For example, for 9 of 15 cases that were
administratively closed because the applicant failed to appear for the
initial interview, we found no documentation in the A-file that a
USCIS liaison at the applicant's military installation was contacted
in an attempt to locate the service member. Table 2 below presents the
results of our analysis on the extent to which USCIS documented the
actions it took in accordance with its April 2009 guidance.
Table 2: USCIS Documentation on Administratively Closed or Denied
Cases:
Condition when USCIS administratively closes or denies case:
Administratively Closed; Applicant fails to appear for the initial
interview;
Number of cases reviewed: 15;
Actions required by USCIS to locate applicant upon abandonment of the
application:
Search available databases and correspondence for a change of address
or request to reschedule the interview;
Documentation indicating action taken to locate or notify applicant:
Yes: 0;
No: 15;
Not applicable or could not determine: 0.
Contact USCIS liaison at the applicant's military installation in
attempt to locate the service member;
Documentation indicating action taken to locate or notify applicant:
Yes: 6;
No: 9;
Not applicable or could not determine: 0.
Send second interview notice to the service member after finding a
change in address, new contact information, or request to reschedule
the interview;
Documentation indicating action taken to locate or notify applicant:
Yes: 1;
No: 4;
Not applicable or could not determine: 10[A].
Condition when USCIS administratively closes or denies case:
Administratively Closed; Miscellaneous reasons, other than applicant
fails to appear for the initial interview;
Number of cases reviewed: 15;
Actions required by USCIS to locate applicant upon abandonment of the
application:
Search available databases and correspondence for a change of address
or request to reschedule the interview;
Documentation indicating action taken to locate or notify applicant:
Not applicable or could not determine: 15[B].
Contact USCIS liaison at the applicant's military installation in
attempt to locate the service member;
Documentation indicating action taken to locate or notify applicant:
Not applicable or could not determine: 15[B].
Send second interview notice to the service member after finding a
change in address, new contact information, or request to reschedule
the interview;
Documentation indicating action taken to locate or notify applicant:
Not applicable or could not determine: 15[B].
Condition when USCIS administratively closes or denies case: Denied
for Abandonment; Applicant fails to provide fingerprints;
Number of cases reviewed: 10;
Actions required by USCIS to locate applicant upon abandonment of the
application:
Search available databases and correspondence for a change of address
to locate applicant and advise about the fingerprint requirement;
Documentation indicating action taken to locate or notify applicant:
Yes: 2;
No: 8;
Not applicable or could not determine: 0.
Contact applicant and alert him or her about the fingerprint
requirement and methods to fulfill it;
Documentation indicating action taken to locate or notify applicant:
Yes: 0;
No: 10;
Not applicable or could not determine: 0.
Contact applicant and confirm that he or she is stationed domestically
and able to report to an Application Support Center.for fingerprinting;
Documentation indicating action taken to locate or notify applicant:
Yes: 0;
No: 5;
Not applicable or could not determine: 5[C].
Contact USCIS liaison at the applicant's military installation in
attempt to locate the service member;
Documentation indicating action taken to locate or notify applicant:
Yes: 4;
No: 5;
Not applicable or could not determine: 1[D].
Send second Application Support Center appointment notice to the
service member after finding a change in address, new contact
information;
Documentation indicating action taken to locate or notify applicant:
Yes: 1;
No: 2;
Not applicable or could not determine: 7[E].
Conditions when USCIS administratively closes or denies case: Denied
on the Merits of the Case; Applicant fails to provide evidence
requested after the initial interview;
Number of cases reviewed: 2;
Actions required by USCIS to locate applicant upon abandonment of the
application:
Search available databases and correspondence for a change of address
or request for an extension of time;
Documentation indicating action taken to locate or notify applicant:
Yes: 0;
No: 2;
Not applicable or could not determine: 0.
Contact USCIS liaison at the applicant's installation in attempt to
locate the service member;
Documentation indicating action taken to locate or notify applicant:
Yes: 0;
No: 2;
Not applicable or could not determine: 0.
Send second request for evidence to the service member or a 30-day
extension to respond to the request for evidence after finding a
change in address, new contact information, or a request for an
extension of time;
Documentation indicating action taken to locate or notify applicant:
Yes: 0;
No: 0;
Not applicable or could not determine: 2[F].
Source: GAO analysis of USCIS A-files.
Note: The 42 cases were randomly selected from cases administratively
closed or denied from April 15, 2009, through July 9, 2009.
[A] Not applicable because there was no indication in applicants' A-
files of an address change, new contact information, or request to
reschedule the interview.
[B] Could not determine because we did not collect data on actions
taken to locate applicants when the case was administratively closed
for miscellaneous reasons.
[C] Not applicable because applicant was not stationed domestically,
and Application Support Centers are located within the Unites States.
[D] Not applicable because applicant was no longer in the military at
the time USCIS was determining whether to administratively close or
deny the case.
[E] Not applicable because there was no indication in applicant's A-
files of an address change or new contact information.
[F] Not applicable because there was no indication in applicants' A-
files of an address change, new contact information, or request for
time extension.
[End of table]
For A-files that lacked documentation that the requirements of USCIS's
April 2009 guidance were met, we could not determine if USCIS staff
carried out all the requirements but did not document their efforts,
or if they did not carry out all the requirements. USCIS officials
told us that human error on the part of USCIS personnel was the reason
why some A-files lacked documentation of all actions taken under the
April 2009 guidance. Standards for internal control guidelines call
for agencies to document that transactions and other significant
events are complete and accurate, and are useful to managers in
controlling their operations and to any others involved in evaluating
or analyzing operations. Additionally, USCIS's guidance in the April
2009 memo and the Adjudicator's Field Manual both state that all
actions taken to locate the applicant should be documented on a
"Record of Action" form in the applicant's A-file. USCIS personnel may
have taken all the actions set forth in the guidance, but improving
quality assurance measures to ensure that such documentation is placed
in A-files could help USCIS validate the actions taken and determine
the extent to which USCIS personnel are adhering to management's
intentions as set out in the April 2009 guidance for administratively
closing or denying military naturalization cases. Some headquarters
and field officials indicated that improving the military
naturalization program's quality assurance measures, such as providing
additional supervision, training, and communication with application
processing staff, could help reinforce the requirement that all
actions taken be documented and ensure that USCIS has complete and
accurate information on the actions it has taken under the April 2009
guidance.
Conclusions:
USCIS has made a number of procedural improvements to its processing
of military naturalizations, and these appear to have helped it
increase the percentage of applications completed within 6 months of
receipt, as required by the MPCPA. The mobile nature of the military
population, in general, can make it challenging to complete
naturalization applications in a timely fashion. Locating applicants
who are deployed overseas, especially in war zones, can pose even
greater challenges to the timely completion of the application
process. In comparison to the pre-MPCPA time period in our review,
USCIS significantly increased the percentage of military
naturalization applications completed within 6 months of receipt.
At the same time, developing procedures to be more proactive in
ascertaining which service members have orders to deploy overseas
could help ensure that USCIS has consistent, comprehensive information
to assist it in determining which applicants may soon be leaving the
country and require priority, expedited processing of their
naturalization applications. As a result, USCIS would be better
positioned to meet its goal of completing processing of military
naturalization applications before the applicant is deployed overseas.
In addition, by ensuring that documentation requirements are followed,
USCIS could strengthen its ability to validate its personnel's actions
and help ensure that it has complete and accurate information on (1)
efforts made to comply with the notification requirements of the MPCPA
when USCIS does not meet the 6-month processing deadline, and (2)
actions taken to make the decision that a case should be
administratively closed or denied.
Recommendations for Executive Action:
To enhance efforts to expedite application processing and ensure that
actions taken by USCIS personnel fully comply with the notification
requirements of the MPCPA and USCIS's guidance for closing cases, we
recommend that the Director of USCIS take the following 3 actions:
1. develop procedures to help ensure that available deployment
information is proactively and systematically collected from all
military naturalization applicants at the time they file their
naturalization applications;
2. for cases where USCIS is unable to adjudicate a military
naturalization application within 6 months of receipt, institute
quality assurance measures to help ensure that applicants' A-files
contain a copy of the letter notifying the applicant of the reasons
for the delay and an estimated adjudication date; and:
3. for cases that are administratively closed or denied, institute
quality assurance measures to help ensure that all actions taken under
USCIS' April 2009 guidance are documented in applicants' A-files.
Agency Comments and Our Evaluation:
We provided a draft of this report to DHS and DOD for their review and
comment. On July 27, 2010, DHS provided written comments agreeing with
our recommendations. DHS's letter explained the actions it is planning
to take in response to the recommendations in our report. When
implemented, these actions will address the intent of our
recommendations. To address the first recommendation to help ensure
that available deployment information is collected from all military
naturalization applicants at the time they file their naturalization
application, DHS plans, among other things, to incorporate questions
pertaining to applicants' active duty status and deployment overseas
into the naturalization application form. To address the second
recommendation to help ensure that applicants' A-files contain the
required documentation if their naturalization applications cannot be
adjudicated within 6 months of receipt, DHS plans to develop quality
assurance measures specific to naturalization cases subject to the
MPCPA notification requirements. To address the third recommendation
to help ensure that the A-files of applicants whose cases are
administratively closed or denied contain documentation of actions
taken under DHS's April 2009 guidance, DHS plans to develop and
implement additional quality assurance measures to ensure that DHS
officers document all actions in the A-file. DHS's comments are
reprinted in full in appendix II. DHS also provided us technical
comments, which we incorporated as appropriate. DOD did not provide
comments on our draft report.
We are sending copies of this report to the Secretary of Homeland
Security, the Secretary of Defense, and other interested parties. In
addition, the report will be available at no charge on GAO's Web site
at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-8777 or stanar@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Other key contributors to this report
are listed in appendix III.
Signed by:
Richard M. Stana:
Director, Homeland Security and Justice Issues:
List of Committees:
The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Member:
Committee on Armed Services:
United States Senate:
The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Charles E. Schumer:
Chairman:
The Honorable John Cornyn:
Ranking Member:
Subcommittee on Immigration, Refugees and Border Security
Committee on the Judiciary:
United States Senate:
The Honorable Ike Skelton:
Chairman:
The Honorable Howard P. McKeon:
Ranking Member:
Committee on Armed Services:
House of Representatives:
The Honorable Bennie G. Thompson:
Chairman:
The Honorable Peter T. King:
Ranking Member:
Committee on Homeland Security:
House of Representatives:
The Honorable Zoe Lofgren:
Chairwoman:
The Honorable Steven A. King:
Ranking Member:
Subcommittee on Immigration, Citizenship, Refugees, Border Security,
and International Law:
Committee on the Judiciary:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To determine the extent to which USCIS has met the processing
deadlines established in the Military Personnel Citizenship Processing
Act (MPCPA) and the Kendell Frederick Citizenship Assistance Act
(Kendell Frederick Act), we reviewed aliens' case files (A-files) from
USCIS's listings of naturalization applications filed before and after
enactment of the acts for applications filed by (1) service members,
(2) spouses of service members, and (3) applicants for posthumous
citizenship.[Footnote 28] We also reviewed A-files for cases that had
been administratively closed or denied by USCIS due to applicants'
failure to respond to requests for appearance or evidence. Our file
reviews were conducted at the following USCIS locations: the Nebraska
Service Center[Footnote 29] (NSC) in Lincoln, Nebraska; National
Records Center in Lee's Summit, Missouri; and the domestic field
offices--Los Angeles, California, Norfolk, Virginia, and San Diego,
California, and the international office--Rome, Italy--with the
highest number of pending service member applications submitted in the
post-MPCPA period, as of July 28, 2009.[Footnote 30] We selected and
reviewed either samples of or all available applications contained in
A-files for the following eight populations, or categories, of
military naturalization applications:
Table 3: Description of Military Naturalization Sample Populations:
MPCPA populations:
Sample populations and time periods: Applications filed by service
members; (1) Pre-enactment--Naturalization applications USCIS
completed from April 28, 2008, through October 8, 2008, about 5 ½
months prior to enactment of the MPCPA;
Applications reviewed and results reported: We selected and reviewed a
random probability sample of these applications. The results of the
sample are reported as estimates of the universe of all service member
applications completed during about 5 ½ months preceding enactment of
the MPCPA. The pre-MPCPA period was intended to be 6 months but was 20
days less due to a programming error during sample selection. We
believe that the exclusion of these 20 days had no effect on our
results. Unless otherwise noted, the margin of error for estimates of
percentages of completed pre-MPCPA applications is plus or minus 14
percentage points or less at the 95 percent level of statistical
confidence.[A]
Sample populations and time periods: Applications filed by service
members; (2) Post-enactment--Naturalization applications received by
USCIS from October 9, 2008 through January 9, 2009, the 3-month period
following the enactment of the MPCPA. We obtained a listing of the
applications filed during this period and their status in USCIS's case
management system (CLAIMS 4) as of July 28, 2009. This allowed USCIS
from more than 6 months to about 9 and one-half months to complete the
applications;
Applications reviewed and results reported:
* Completed applications--We selected and reviewed a random
probability sample of completed applications. The results of the
sample are reported as estimates of the universe of all service member
applications received by USCIS during the 3 months following enactment
of the MPCPA and completed as of July 28, 2009. Unless otherwise
noted, the margin of error for estimates of percentages of post-MPCPA
completed applications is plus or minus 10 percentage points or less
at the 95 percent level of statistical confidence;
* Pending applications--We reviewed all available pending applications
as of July 28, 2009, at the NSC and in the 4 USCIS field offices that
we visited. The results are not generalizable to all post-MPCPA
service member cases pending longer than 6 months because our sample
was limited to the applications we reviewed at these offices. However,
they provided us with important information about such things as
reasons for application processing delays and USCIS's documentation in
A-files of actions taken to notify applicants of processing delays.
Sample populations and time periods: Applications filed by spouses of
service members; (3) Post-enactment--Naturalization applications
submitted by the spouses of military members and received by USCIS
from January 22, 2009, through February 22, 2009, the 1-month period
following the transfer of the processing of spousal applications to
the NSC. We obtained a listing of these applications according to
their status in CLAIMS 4 as of August 31, 2009, to allow USCIS about 6
months to complete applications received on February 22, 2009;
Applications filed prior to January 22, 2009, are not identifiable in
USCIS's data system. As a result, we were unable to review
applications submitted prior to the enactment of the MPCPA;
Applications reviewed and results reported:
* Completed applications--We reviewed all known completed applications
for the time period. The results for this analysis apply to all
spousal applicants during the one-month time period we reviewed;
* Pending applications--We reviewed all available pending applications
as of August 31, 2009, at the NSC and in the Los Angeles Field Office.
There were no pending spousal applications in the other field offices
we visited;
Since we did not select random probability samples of spouse
applications to review, there are no sampling errors associated with
our review of these applications.
Sample populations and time periods: Applications for posthumous
citizenship; (4) Pre-enactment--Applications for posthumous
citizenship USCIS completed from April 8, 2008, through October 8,
2008, the 6-month period prior to enactment of the MPCPA;
Applications reviewed and results reported: We reviewed all posthumous
applications completed during this period.
Sample populations and time periods: Applications for posthumous
citizenship; (5) Post-enactment--Applications for posthumous
citizenship received by USCIS from October 9, 2008, through January 9,
2009, the 3-month period following enactment of the MPCPA;
Applications reviewed and results reported: We reviewed all posthumous
applications filed during this period.
Kendell Frederick populations:
Sample populations and time periods: Applications filed by service
members who served overseas at some point during the processing of
their applications; (6) Pre-enactment--Naturalization applications
that USCIS completed from December 25, 2007, through June 25, 2008,
the 6-month period prior to enactment of the Kendell Frederick Act. We
obtained a listing of all service member applications completed during
this period, and worked with DOD to identify those where the applicant
served overseas;
Applications reviewed and results reported: We selected and reviewed a
random probability sample of these applications. The results of the
sample are reported as estimates of the universe of all overseas
service member applications completed during the 6 months preceding
enactment of the Kendell Frederick Act. Unless otherwise noted, the
margin of error for estimates of percentages of completed pre-Kendell
Frederick Act applications is plus or minus 13 percentage points or
less at the 95 percent level of statistical confidence.
Sample populations and time periods: Applications filed by service
members who served overseas at some point during the processing of
their applications; (7) Post-enactment--Naturalization applications
received by USCIS from June 26, 2008, through September 26, 2008, the
3-month period following enactment of the Kendell Frederick Act. We
obtained a listing of all service member applications filed during
this period and their status in CLAIMS 4 as of July 28, 2009, and
worked with DOD to identify those where the applicant served overseas;
Applications reviewed and results reported: We selected and reviewed a
random probability sample of these applications, all of which had been
completed. The results of the sample are reported as estimates of the
universe of all service member applications received by USCIS during
the 3 months following enactment of the Kendell Frederick Act. Unless
otherwise noted, the margin of error for estimates of percentages of
completed post-Kendell Frederick Act applications is plus or minus 9
percentage points or less at the 95 percent level of statistical
confidence.
Administratively closed/denied applications:
Sample populations and time periods: Applications administratively
closed/denied to due to applicants' failure to respond to requests for
appearance or evidence; (8) Naturalization applications that were
administratively closed or denied due to the conditions described in
an April 15, 2009, USCIS memorandum, as of July 9, 2009;
Applications reviewed and results reported: While the files we
reviewed were randomly selected, we cannot generalize the results of
reviewing these applications to all applications administratively
closed or denied as of July 9, 2009, due to the April 15 memorandum
because we do not know the actual population count of applications
administratively closed or denied for this period. In addition, close
to half of the requested files were not available for review during
our site visit to the NSC because they had been transferred to various
locations nationwide for further processing.[B] Even so, our review of
these applications provided us with important information about such
things as USCIS's actions to locate applicants who failed to appear
for an interview or respond to a request for evidence, and USCIS's
documentation in A-files of actions taken to administratively close or
deny applications due to the April 15 memorandum.
Source: GAO:
[A] All statistical samples are subject to sampling error; that is,
the extent to which the sample results differ from what would have
been obtained if the whole population had been observed. Measures of
sampling error are defined by two elements, the width of the
confidence intervals around the estimate (sometimes called the
precision of the estimate) and the confidence level at which the
intervals are computed. Because we followed a probability procedure
based on random selections, our sample is only one of a large number
of samples that we might have drawn. As each sample could have
provided different estimates, we express our confidence in the
precision of our particular sample's results as a 95 percent
confidence interval (e.g., plus or minus 10 percentage points). This
is the interval that would contain the actual population value for 95
percent of the samples we could have drawn. As a result, we are 95
percent confident that each of the confidence intervals based on the
review of the files in this sample includes the true values in the
population.
[B] We received a list of 387 applications that had been
administratively closed or denied as of July 9, 2009. In total, we
selected from this list a random probability sample of 154
applications to review. Upon beginning our review of the A-files, we
determined that many applications had not been either administratively
closed or denied based on the April 15 memorandum, and so were not
qualified to be included in our sample. We inquired with USCIS about
the presence of these applications in our sample and learned that the
list of applications provided to us had not been limited only to
applications administratively closed or denied due to reasons in the
April 15 memorandum but had comprised all applications
administratively closed or denied during our sample period. Of the
total number of 154 files requested, we reviewed 42 that had been
closed or denied due to the memorandum; 41 were determined not
qualified to be in the group; and, 71 were not reviewed because they
had been transferred to locations we did not visit.
[End of table]
We reviewed A-files to address this objective because limitations with
USCIS's case management system, CLAIMS 4, prohibited us from analyzing
data from the system to calculate application processing times
[Footnote 31] and obtain other information relevant to our study. We
reviewed A-files to determine, among other things, how long USCIS took
to process military naturalization applications, when various
background checks were completed, whether USCIS provided an
explanation to applicants if it could not complete application
processing within 6 months, reasons why applications may not have been
processed within mandated time frames, and whether USCIS was closing
or denying certain cases consistent with its own guidance. In
addition, because USCIS was unable to identify service members who
served overseas during the application process, we coordinated with
DOD's Defense Defense Manpower Data Center (DMDC) to identify these
applicants in order to select our sample populations for the Kendell
Frederick Act.[Footnote 32] We questioned DMDC about the reliability
of the data in the files used to identify service members serving
overseas, and determined that the data were sufficiently reliable for
our purposes.
We developed data collection instruments to review applications for
each of the eight populations in Table 3 and pretested these
instruments with a number of military naturalization applications to
help ensure that they effectively captured the data available in the A-
files and addressed our research objectives. Furthermore, we verified
the accuracy and completeness of our data collection efforts and
subsequent analyses.[Footnote 33] We reviewed a total of 464 A-files.
See table 4 for a summary of the disposition of the file review
samples for each of the military naturalization populations.
Table 4: Disposition of the File Review Samples for the Eight
Populations of Military Naturalization Applications:
Populations/Sample groups: Pre-MPCPA service members: Completed as of
7/28/09;
Number of applications in the sample group according to CLAIMS 4:
4,533;
Number of applications selected for review: 52;
Number of selected applications not available for review: 0;
Number of selected applications misclassified or not qualified for the
sample group: 2[A];
Number of applications qualified for the sample group that were
reviewed: 50.
Populations/Sample groups: Post-MPCPA service members: Completed as of
7/28/09;
Number of applications in the sample group according to CLAIMS 4:
1,624[B];
Number of applications selected for review: 101;
Number of selected applications not available for review: 4;
Number of selected applications misclassified or not qualified for the
sample group: 1[C];
Number of applications qualified for the sample group that were
reviewed: 96.
Populations/Sample groups: Pending as of 7/28/09 (at the NSC and
selected field offices);
Number of applications in the sample group according to CLAIMS 4: 149;
Number of applications selected for review: 149;
Number of selected applications not available for review: 19;
Number of selected applications misclassified or not qualified for the
sample group: 56;
Number of applications qualified for the sample group that were
reviewed: 74.
Populations/Sample groups: NSC;
Number of applications in the sample group according to CLAIMS 4: 71;
Number of applications selected for review: 71;
Number of selected applications not available for review: 2;
Number of selected applications misclassified or not qualified for the
sample group: 51[D];
Number of applications qualified for the sample group that were
reviewed: 18.
Populations/Sample groups: Norfolk;
Number of applications in the sample group according to CLAIMS 4: 10;
Number of applications selected for review: 10;
Number of selected applications not available for review: 0;
Number of selected applications misclassified or not qualified for the
sample group: 1[E];
Number of applications qualified for the sample group that were
reviewed: 9.
Populations/Sample groups: Los Angeles;
Number of applications in the sample group according to CLAIMS 4: 10;
Number of applications selected for review: 10;
Number of selected applications not available for review: 1;
Number of selected applications misclassified or not qualified for the
sample group: 1[F];
Number of applications qualified for the sample group that were
reviewed: 8.
Populations/Sample groups: San Diego;
Number of applications in the sample group according to CLAIMS 4: 21;
Number of applications selected for review: 21;
Number of selected applications not available for review: 0;
Number of selected applications misclassified or not qualified for the
sample group: 0;
Number of applications qualified for the sample group that were
reviewed: 21.
Populations/Sample groups: Rome;
Number of applications in the sample group according to CLAIMS 4: 37;
Number of applications selected for review: 37;
Number of selected applications not available for review: 16;
Number of selected applications misclassified or not qualified for the
sample group: 3[G];
Number of applications qualified for the sample group that were
reviewed: 18.
Populations/Sample groups: Post-MPCPA spouses of service members:
Completed as of 8/31/09;
Number of applications in the sample group according to CLAIMS 4:
44[H];
Number of applications selected for review: 44;
Number of selected applications not available for review: 0;
Number of selected applications misclassified or not qualified for the
sample group: 0;
Number of applications qualified for the sample group that were
reviewed: 48[I].
Populations/Sample groups: Pending as of 8/31/09 (at the NSC, National
Benefits Center, National Records Center, and selected field offices);
Number of applications in the sample group according to CLAIMS 4: 6;
Number of applications selected for review: 6;
Number of selected applications not available for review: 1;
Number of selected applications misclassified or not qualified for the
sample group: 4;
Number of applications qualified for the sample group that were
reviewed: 1.
Populations/Sample groups: NSC, National Benefits Center, National
Records Center;
Number of applications in the sample group according to CLAIMS 4: 5;
Number of applications selected for review: 5;
Number of selected applications not available for review: 1;
Number of selected applications misclassified or not qualified for the
sample group: 4[J];
Number of applications qualified for the sample group that were
reviewed: 0.
Populations/Sample groups: Los Angeles;
Number of applications in the sample group according to CLAIMS 4: 1;
Number of applications selected for review: 1;
Number of selected applications not available for review: 0;
Number of selected applications misclassified or not qualified for the
sample group: 0;
Number of applications qualified for the sample group that were
reviewed: 1.
Populations/Sample groups: Pre-MPCPA posthumous applicants: Completed;
Number of applications in the sample group according to CLAIMS 4: 6;
Number of applications selected for review: 6;
Number of selected applications not available for review: 0;
Number of selected applications misclassified or not qualified for the
sample group: 0;
Number of applications qualified for the sample group that were
reviewed: 6.
Populations/Sample groups: Post-MPCPA posthumous applicants: Completed;
Number of applications in the sample group according to CLAIMS 4: 1;
Number of applications selected for review: 1;
Number of selected applications not available for review: 0;
Number of selected applications misclassified or not qualified for the
sample group: 0;
Number of applications qualified for the sample group that were
reviewed: 1.
Populations/Sample groups: Pre-Kendell Frederick Act overseas service
members: Completed as of 7/28/09;
Number of applications in the sample group according to CLAIMS 4:
1,278;
Number of applications selected for review: 62;
Number of selected applications not available for review: 1;
Number of selected applications misclassified or not qualified for the
sample group: 2[K];
Number of applications qualified for the sample group that were
reviewed: 59.
Populations/Sample groups: Post-Kendell Frederick Act overseas service
members: Completed as of 7/28/09;
Number of applications in the sample group according to CLAIMS 4: 442;
Number of applications selected for review: 95;
Number of selected applications not available for review: 7;
Number of selected applications misclassified or not qualified for the
sample group: 0;
Number of applications qualified for the sample group that were
reviewed: 87[L].
Populations/Sample groups: Administratively closed/denied by USCIS due
to reasons in the April 15 memorandum;
Number of applications in the sample group according to CLAIMS 4: 387;
Number of applications selected for review: 154;
Number of selected applications not available for review: 71;
Number of selected applications misclassified or not qualified for the
sample group: 41[M];
Number of applications qualified for the sample group that were
reviewed: 42.
Source: GAO analysis:
[A] Upon review, one application was found to have been completed in
August 2009, after the end of our pre-MPCPA period; the second
application was found to have been closed in April 2007, before the
start of our sample period.
[B] CLAIMS 4 also identified 308 applications received during the 3-
month period that were pending as of July 28, 2009. An additional 49
applications filed during this period had been withdrawn by applicants
and 6 applications had been terminated. A terminated application
occurs when it is found that an applicant has filed the N-400 more
than once, and USCIS terminates the duplicate(s).
[C] The applicant was found to have already been a citizen at the time
of the application.
[D] Forty-nine applications had been misclassified because the
applications had been closed on July 4, 2009, and CLAIMS 4 had not
been updated to indicate they had been completed. Also, 2 applications
were found to have been opened after January 9, 2009, and were not
qualified to be included in the post-MPCPA population.
[E] One application was found to have been submitted before our sample
time period.
[F] One application was found to have been submitted by a spouse and
not a service member.
[G] Three applicants were found to have already been citizens at the
time of their applications.
[H] CLAIMS4 also identified 12 additional spousal applications
received during the 1-month period that were pending as of August 31,
2009. Two additional applications filed during this period had been
withdrawn by applicants.
[I] In addition to the 44 completed applications in CLAIMS 4, we found
4 applications in our file review identified as pending in CLAIMS 4
that had actually been completed prior to August 31, 2009. Therefore,
we included these 4 applications in our analysis of completed
applications.
[J] Four applications we reviewed at the NSC that had been identified
as pending had actually been completed prior to August 31, 2009. Three
of these applications had been misclassified because the applicants
had been naturalized prior to August 31, 2009--one in March 2009--and
one applicant had been denied prior to August. CLAIMS 4 had not been
updated to indicate these applications had been completed.
[K] Two applicants were found to have been naturalized after our
sample time period.
[L] One file qualified and available for review was inadvertently not
completed.
[M] These applications were determined not to have been
administratively closed or denied due to reasons in the USCIS April
15, 2009, memorandum, or in the instance of one, closed prior to the
issuance of the memorandum.
[End of table]
To determine the actions USCIS took to implement the processing
deadline requirements in the MPCPA and the Kendell Frederick Act, and
any key challenges experienced in its implementation efforts, we
reviewed USCIS reports, memorandums, and guidance related to
processing military naturalization applications. We interviewed
officials at USCIS headquarters, the NSC, and field offices in Los
Angeles, California, Norfolk, Virginia, San Diego, California, and
Rome, Italy. We also interviewed officials at the Federal Bureau of
Investigation (FBI) and DOD, including those within the Army, Navy,
and Marine Corps service components; and reviewed relevant
documentation to identify the actions they have taken in coordination
with USCIS to help expedite the processing of military naturalization
applications and obtain their perspectives on any challenges they have
experienced. In addition, we augmented officials' perspectives on key
challenges experienced with the results from our review of applicant A-
files.
For both objectives, we reviewed the Kendell Frederick Act, the
Military Personnel Citizenship Processing Act (MPCPA), the National
Defense Authorization Acts for Fiscal Years 2004 and 2008, and
Executive Order 13269; as well as relevant sections of Title III of
the Immigration and Nationality Act.
We conducted this performance audit from February 2009 through July
2010, in accordance with generally accepted government auditing
standards. These standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Comments from the Department of Homeland Security:
US. Department of Homeland Security:
Washington, DC 20528:
July 27, 2010:
Richard M. Stana:
Director, Homeland Security and Justice Issues:
Government Accountability Office:
441 G Street, NW:
Washington, D.C. 20548:
Dear Mr. Stana:
RE: Draft Report GA0-10-865 (Reference #440780), Military
Naturalizations: USCIS Generally Met Mandated Processing Deadlines,
But Processing Applicants Deployed Overseas Is A Challenge.
Thank you for the opportunity to review the draft report concerning
the Department of Homeland Security's (DHS) military naturalizations
process. DHS concurs with GAO's report findings and proposed
recommendations. DHS had three recommendations for executive action.
We would like to respectfully offer the following comments:
To enhance efforts to expedite application processing and ensure that
actions taken by DHS personnel fully comply with the notification
requirements of the Military Personnel Citizenship Processing Act
(MPCPA) and guidance for closing cases, the GAO draft report
recommends that DHS take the following three actions:
GAO Recommendation 1: Develop procedures to help ensure that available
deployment information is proactively and systematically collected
from all military naturalization applicants at the time they file
their naturalization applications.
DHS Response: DHS concurs with this recommendation. DHS is currently
revising the Application for Naturalization (Form N-400) to help
ensure that available deployment information is captured. To do so,
DHS is incorporating questions pertaining to the applicant's active
duty status and anticipated or imminent deployment overseas. Upon
receipt at the intake facility, DHS will flag these cases for special
expedited processing. In addition, the form instructions will advise
the applicant to notify DHS of imminent deployment plans after he or
she has filed the application.
DHS will evaluate current procedures at the intake facility to ensure
that any application packet alerting DHS of an applicant's imminent
deployment will receive special expedited processing.
Projected completion date: August 2011.
GAO Recommendation 2: For cases where DHS is unable to adjudicate a
military naturalization application within six months of receipt,
institute quality assurance measures to help ensure that applicants' A-
files contain a copy of the letter notifying the applicant of the
reasons for the delay and an estimated adjudication date.
DHS Response: DHS concurs with this recommendation. DHS will work
toward improved quality assurance measures, and will develop quality
assurance measures specific to naturalization cases subject to the
MPCPA notification requirements. DHS will amend the Naturalization
Quality Procedures to incorporate items specific to MPCPA-governed
cases, take appropriate steps to ensure that the notification letter
includes an estimated adjudication date, and place a copy of that
notification letter in the applicant's A-file.
Projected completion date: March 2011.
GAO Recommendation 3: For cases that are administratively closed or
denied, institute quality assurance measures to help ensure that all
actions taken under DHS's April 2009 guidance are documented in
applicants' A-files.
DHS Response: DHS concurs with this recommendation. DHS will develop
and implement additional quality assurance measures to ensure that DHS
officers document all actions in the applicant's A-file, as required
by the April 2009 guidance, Processing N-400s Filed Under INA 328 and
329 When Applicant Fails to Respond to a Request for Evidence or for
Appearance, when an applicant fails to appear or respond to a Request
for Evidence. DHS will amend the Naturalization Quality Procedures to
incorporate items specific to naturalization cases filed by current
and former military members that are administratively closed or denied.
Projected completion date: March 2011.
Thank you for the opportunity to comment on this Draft Report and we
look forward to working with you on future homeland security issues.
Sincerely,
Signed by:
Jerald E. Levine:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Richard M. Stana, (202) 512-8777 or stanar@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Evi Rezmovic, Assistant
Director, and James Lawson, Analyst-in-Charge, managed this
assignment. David Alexander, Frances Cook, Christine Davis, Dae Park,
Steven Rabinowitz, Anna Russell, Christine San, Mark Tremba, Ashley
Vaughan, Adam Vogt, and Johanna Wong made significant contributions to
the report.
[End of section]
Footnotes:
[1] Naturalization is the process by which U.S. citizenship is granted
to a foreign citizen or national after he or she fulfills the
requirements established by law in the Immigration and Nationality Act.
[2] Exec. Order No. 13,269, 67 Fed. Reg. 45,287 (July 8, 2002).
[3] Kendell Frederick Citizenship Assistance Act, Pub. L. No. 110-251,
122 Stat. 2319 (2008).
[4] Military Personnel Citizenship Processing Act, Pub. L. No. 110-
382, 122 Stat. 4087 (2008). The MPCPA has a sunset provision of
October 9, 2013, at which point the act will be repealed unless
subsequent legislation is enacted to extend its applicability.
[5] DHS Office of Inspector General, U.S. Citizenship and Immigration
Services' Implementation of the Kendell Frederick Citizenship
Assistance Act, OIG-10-39 (January 2010).
[6] The samples sizes and populations are discussed in more detail in
app. I. The pre-Kendell Frederick period was from December 25, 2007,
through June 25, 2008; the pre-MPCPA period was from April 28, 2008,
through October 8, 2008. The pre-MPCPA period was intended to be 6
months, but was 20 days less due to a programming error during the
sample selection. We believe that the exclusion of these 20 days had
no effect on our results.
[7] The post-Kendell Frederick period was from June 26, 2008, through
September 26, 2008; the post-MPCPA period was from October 9, 2008,
through January 9, 2009. USCIS provided us the status of post-Kendell
Frederick and post-MPCPA cases from its case management system as of
July 28, 2009. The July 28, 2009, date allowed USCIS more than 6
months to process and adjudicate applications after enactment of the
acts; provided USCIS time to locate and mail, if necessary, the files
we requested to the locations we planned to visit; and enabled us to
balance the competing demands of providing a timely report to Congress
while allowing a sufficient period of time to elapse so that we could
assess USCIS's timeliness in processing military naturalization cases
after the enactment of the two acts.
[8] The Nebraska Service Center (NSC) is USCIS's centralized location
for receiving and conducting initial processing of all military
naturalization applications, except for applications for posthumous
citizenship.
[9] The 1-month period was from January 22, 2009, through February 22,
2009. USCIS provided us the status of these cases from its case
management system, CLAIMS 4, as of August 31, 2009.
[10] Among other responsibilities, the Rome Field Office processes
applications of service members stationed in Iraq.
[11] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington D.C.: November 1999).
[12] In addition, in December 2008, the Department of Defense
announced the "Military Accessions Vital to the National Interest
(MAVNI)" pilot program temporarily permitting enlistment into military
service of U.S. nonimmigrant visa holders, asylees, refugees, or
individuals with Temporary Protected Status who possess medical,
language, and other types of skills deemed vital for military
operations.
[13] See 8 U.S.C. § 1440-1.
[14] The spouses of U.S. citizen service members who are regularly
stationed abroad, as well as the surviving spouses, children, and
parents of U.S. citizen service members who die during a period of
active duty military service, are eligible to apply for citizenship
under section 319(b), (d), or (e) of the INA, which waives otherwise
applicable requirements regarding residency and physical presence in
the United States. See 8 U.S.C. § 1430(b), (d), (e); see also, USCIS,
A Guide to Naturalization (Washington, D.C.: February 2010), pp. 18-19.
[15] For the post-Kendell Frederick Act applications, the margin of
error for estimates of percentages is plus or minus 9 percentage
points or less at the 95 percent level of statistical confidence. For
pre-Kendell Frederick Act applications, the margin of error for
estimates of percentages is plus or minus 13 percentage points or less
at the 95 percent level of statistical confidence.
[16] Our review showed that after enactment of the Kendell Frederick
Act, USCIS completed an estimated 76 percent of cases within 182.4
days of the date that it completed the initial background and national
security checks. Prior to the Kendell Frederick Act, USCIS completed
an estimated 64 percent of cases within 180 days of the initial
checks. This difference in completing naturalization application
processing between the pre-and post-Kendell Frederick Act periods is
not significant at the 95 percent level of statistical confidence.
[17] In addition to the IBIS check, USCIS's background and national
security checks consist of an FBI fingerprint check, FBI name check,
and the Defense Clearance and Investigations Index check for
information on DOD investigations. FBI fingerprint and the Defense
Clearance and Investigations Index check results are valid for 15
months from the date USCIS received a response. FBI name check results
are valid for the life of the naturalization application. If any of
the results expire prior to USCIS completing the processing of the
military naturalization application, USCIS is to rerun the check and
receive a final response before naturalizing the applicant.
[18] According to USCIS, to expedite military naturalization
application processing, it begins conducting background checks on
applicants even if the submitted application is not complete.
[19] Pre-MPCPA service member cases are applications completed by
USCIS about the 5 ½-month period prior to enactment of the MPCPA.
Unless otherwise noted, the maximum margin of error for estimates of
percentages for the pre-MPCPA applications is plus or minus 14
percentage points or less at the 95 percent level of statistical
confidence. Post-MPCPA service member cases are applications received
by USCIS during the 3-month period following the enactment of the
MPCPA. Unless otherwise noted, the maximum margin of error for
estimates of percentages for the post-MPCPA applications is plus or
minus 10 percentage points at the 95 percent level of statistical
confidence.
[20] The 23 staff members included 16 Immigration Service Officers, 1
Adjudications Supervisor, 5 clerical staff, and 1 clerical supervisor.
[21] USCIS's outreach reports provide information on the total number
of military naturalizations. They do not break out the figures for
service member, spouse, and other family member. Posthumous
naturalizations are not captured in the outreach reports.
[22] It was historically difficult to locate enlistment fingerprints
because the FBI stores enlistment fingerprints along with the
fingerprints for all DOD personnel, including civilian employees and
contractors.
[23] Application Support Centers are USCIS offices where applicants
for immigration benefits are fingerprinted.
[24] Mobile fingerprint units are laptop computers with scanners and
cameras, costing USCIS between $8,000 and $11,000 per unit.
[25] From April 2006 through March 2008, USCIS's Rome district office
used webcam (as opposed to videoconferencing) technology to conduct
preliminary naturalization interviews with service members stationed
in Iraq. This technology did not work at bases with satellite internet
connection, or at small forward operating bases that did not have
access to the Internet. For these reasons and, in part, because staff
believed that they could sufficiently resolve outstanding issues by
reviewing the service member's A-file in advance of traveling to Iraq
for the final interview and naturalization oath, the Rome office
discontinued using webcam technology for conducting preliminary
interviews.
[26] One of the 42 cases did not contain information on the date the
application was completed, so the case could not be included in
determining the average length of time to close or deny cases.
[27] Miscellaneous reasons included the applicant deploying out to sea
for a period of time, abandoning the application, and submitting an
incomplete application; and USCIS not being able to contact the
applicant.
[28] The MPCPA's processing deadline also applies to applications
filed by the surviving spouses, children, or parents of members of the
military who died while on active duty. We did not review A-files for
these populations because they were not identifiable in USCIS's data
systems.
[29] The Nebraska Service Center (NSC) is USCIS's centralized location
for receiving and conducting initial processing of military
naturalization applications
[30] We did not select a random, probability sample of all
applications because pending applications selected for such a sample
could have been located in USCIS field offices nationwide, and USCIS
could not send pending applications to a central location for our
review without disrupting the processing of the applications.
[31] GAO has previously reported that due to limitations with CLAIMS
4, USCIS has not had the capability to directly calculate how long it
takes to process naturalization applications. Instead, USCIS uses what
it calls "cycle time"--a statistical estimation as a proxy for actual
processing times, which entails counting back to previous months until
the number of currently pending applications equals the number of
receipts. GAO, Immigration Benefits: Improvements Needed to Address
Backlogs and Ensure Quality of Adjudications [hyperlink,
http://www.gao.gov/products/GAO-06-20] (Washington, D.C.: Nov. 21,
2005; and GAO, Immigration Benefits: Several Factors Impede Timeliness
of Application Processing, [hyperlink,
http://www.gao.gov/products/GAO-01-488] (Washington, D.C.: May 4,
2001).
[32] To determine these applicants, we obtained all service member
applications filed during the pre-and post-Kendell Frederick Act
periods and their status in CLAIMS 4 as of July 28, 2009, and provided
the listing of applicants to the Defense Manpower Data Center (DMDC).
DMDC used a two-step matching process to identify service members
serving overseas during the process. DMDC first used the Contingency
Tracking System (CTS) Deployment File, which contains members of all
military services deployed in support of the global war on terrorism
(GWOT). Service members found not to have been deployed in support of
GWOT during their applications process were then checked against each
military service's Personnel Build files to determine whether or not
they had been activated for overseas duty at any time during their
application process.
[33] A two-stage process was used to review applications. First, an
analyst reviewed and completed a data collection instrument for an
application. A second analyst reviewed the completed data collection
instrument and the associated application to verify the accuracy of
each coded item. All data collection instrument data were double key-
entered into an electronic file in batches (that is, the entries were
100 percent verified), and a random sample of each batch was selected
for further verification for completeness and accuracy. Computer
analyses were also performed to identify inconsistencies or other
indications of errors in the completion of the data collection
instruments or data entry. All computer syntax was peer-reviewed and
verified by a separate programmer to ensure that the syntax had been
written and executed correctly.
[End of section]
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