Information Technology
Near-Term Effort to Automate Paper-Based Immigration Files Needs Planning Improvements Gao ID: GAO-06-375 March 31, 2006The United States Citizenship and Immigration Services (USCIS) relies on about 55 million paper-based files to adjudicate applications for immigration status and other benefits. Ensuring the currency and availability of these manual files, referred to as alien files, or A-Files, is a major challenge. To address this challenge, USCIS has initiated efforts, both long and near term, to automate the A-Files. The long-term effort is now being re-examined within the context of a larger USCIS organizational transformation initiative. In the near term, USCIS has begun a digitization program, which it estimates will cost about $190 million over an 8-year period to electronically scan existing paper files and store and share the scanned images. GAO was asked to determine whether USCIS was effectively managing its A-Files automation efforts.
USCIS's effectiveness in managing its long-term effort for automating the A-Files cannot yet be determined because the scope, content, and approach for moving from paper-based to paperless A-Files has yet to be defined. Nevertheless, GAO believes that USCIS's recent decision to re-examine prior agency plans for a strategic A-Files automation solution within the context of an agencywide transformation strategy appropriately recognizes the integral support role that information technology plays in organizational and business transformation. GAO also believes that the success of USCIS's organizational transformation depends on other key supporting practices, such as having a comprehensive and integrated transformation plan (goals and schedules) and results-oriented performance measures. With respect to USCIS's near-term A-Files automation effort, known as the Integrated Digitization Document Management Program (IDDMP), effective planning is not occurring. In particular, USCIS has not developed a plan governing how it will manage this program and its contractors, and it has not developed an evaluation plan for its ongoing digitization concept of operations pilot test, even though it has either awarded or plans to award contracts totaling about $20 million for this pilot. In addition, USCIS officials told us they do not yet know which A-Files immigration forms will be scanned. Without a defined scope and adequate planning, this program is at risk of falling short of expectations.
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: Team: Phone:GAO-06-375, Information Technology: Near-Term Effort to Automate Paper-Based Immigration Files Needs Planning Improvements
This is the accessible text file for GAO report number GAO-06-375
entitled 'Information Technology: Near-Term Effort to Automate Paper-
Based Immigration Files Needs Planning Improvements' which was released
on May 1, 2006.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as part
of a longer term project to improve GAO products' accessibility. Every
attempt has been made to maintain the structural and data integrity of
the original printed product. Accessibility features, such as text
descriptions of tables, consecutively numbered footnotes placed at the
end of the file, and the text of agency comment letters, are provided
but may not exactly duplicate the presentation or format of the printed
version. The portable document format (PDF) file is an exact electronic
replica of the printed version. We welcome your feedback. Please E-mail
your comments regarding the contents or accessibility features of this
document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
March 2006:
Information Technology:
Near-Term Effort to Automate Paper-Based Immigration Files Needs
Planning Improvements:
GAO-06-375:
GAO Highlights:
Highlights of GAO-06-375, a report to congressional requesters.
Why GAO Did This Study:
The United States Citizenship and Immigration Services (USCIS) relies
on about 55 million paper-based files to adjudicate applications for
immigration status and other benefits. Ensuring the currency and
availability of these manual files, referred to as alien files, or A-
Files, is a major challenge. To address this challenge, USCIS has
initiated efforts, both long and near term, to automate the A-Files.
The long-term effort is now being re-examined within the context of a
larger USCIS organizational transformation initiative. In the near
term, USCIS has begun a digitization program, which it estimates will
cost about $190 million over an 8-year period to electronically scan
existing paper files and store and share the scanned images. GAO was
asked to determine whether USCIS was effectively managing its A-Files
automation efforts.
What GAO Found:
USCIS‘s effectiveness in managing its long-term effort for automating
the A-Files cannot yet be determined because the scope, content, and
approach for moving from paper-based to paperless A-Files has yet to be
defined. Nevertheless, GAO believes that USCIS‘s recent decision to re-
examine prior agency plans for a strategic A-Files automation solution
within the context of an agencywide transformation strategy
appropriately recognizes the integral support role that information
technology plays in organizational and business transformation. GAO
also believes that the success of USCIS‘s organizational transformation
depends on other key supporting practices, such as having a
comprehensive and integrated transformation plan (goals and schedules)
and results-oriented performance measures. With respect to USCIS‘s near-
term A-Files automation effort, known as the Integrated Digitization
Document Management Program, effective planning is not occurring. In
particular, USCIS has not developed a plan governing how it will manage
this program and its contractors, and it has not developed an
evaluation plan for its ongoing digitization concept of operations
pilot test, even though it has either awarded or plans to award
contracts totaling about $20 million for this pilot. In addition, USCIS
officials told us they do not yet know which A-Files immigration forms
will be scanned. Without a defined scope and adequate planning, this
program is at risk of falling short of expectations.
Image: A-Files Storage at National Records Center in Lee's Summit,
Missouri.
[See PDF for Image]
Source: DHS.
[End of Image]
What GAO Recommends:
GAO is making recommendations to the Secretary of Homeland Security to
help ensure that USCIS‘s long-term organizational transformation
initiative is effectively managed and that improvements are made to
USCIS‘s planning for its near-term A-Files digitization and document
management effort. In written comments on a draft of this report, the
Department of Homeland Security agreed with our recommendations and
described actions that are planned and under way to address them.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-375].
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Randolph C. Hite at (202) 512-3439 or
hiter@gao.gov.
[End of Section]
Contents:
Letter:
Results in Brief:
Background:
USCIS Effectiveness in Managing Long-Term A-Files Automation Efforts
Remains to Be Seen, but Near-Term Document Digitization Program Is Not
Being Effectively Managed:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendixes:
Appendix I: Objective, Scope, and Methodology:
Appendix II: Comments from the Department of Homeland Security:
Appendix III: GAO Contact and Staff Acknowledgments:
Figures Figures:
Figure 1: Family-Based Adjustment of Status Application (Form I-485)
Process:
Figure 2: A-Files Storage at National Records Center in Lee's Summit,
Missouri:
Abbreviations:
A-Files: alien files:
CBP: Customs and Border Protection:
CIS: Central Index System:
CLAIMS 3: Computer Linked Application Management System 3:
DHS: Department of Homeland Security:
FBI: Federal Bureau of Investigation:
ICE: Immigration and Customs Enforcement:
IDDMP: Integrated Digitization Document Management Program:
IG: inspector general:
IT: information technology:
NBC: National Benefits Center:
NFTS: National File Tracking System:
OCIO: Office of the Chief Information Officer:
USCIS: U.S. Citizenship and Immigration Services:
US-VISIT: U.S. Visitor and Immigrant Status Indicator Technology:
United States Government Accountability Office:
Washington, DC 20548:
March 31, 2006:
The Honorable Susan M. Collins:
Chairman:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Charles E. Grassley:
Chairman:
Committee on Finance:
United States Senate:
The United States Citizenship and Immigration Services (USCIS) within
the Department of Homeland Security (DHS) relies on more than 55
million paper-based files, each containing between one and hundreds of
pages of immigration information, to adjudicate applications for
immigration status and other benefits. These alien files (A-Files) are
kept for 75 years, and the data contained in these files are also used
by federal, state, and local agencies.
Ensuring the currency and availability of these paper files to support
a range of agency mission needs is a major challenge for USCIS. To
address this challenge, USCIS plans to pursue both long-term and near-
term A-Files automation efforts. While the scope, content, and approach
to its long-term efforts have not yet been defined, in the near-term,
USCIS has begun the Integrated Digitization Document Management Program
(IDDMP), which it estimates will cost about $190 million over an 8-year
period. This program provides for electronically scanning paper forms
and associated documents contained in the A-Files, storing the
resulting electronic images, and providing user access to the images.
Thus far, USCIS has either awarded, or plans to award, five contracts
to pilot test a digitization concept of operations. These contracts are
being funded primarily with funds that were set to expire by the end of
September 2005.
As part of your request that we review USCIS's management and use of
the A-Files, we agreed to determine whether USCIS was effectively
managing its A-Files automation efforts. To accomplish this objective,
we reviewed available plans and contractor statements of work
pertaining to the automation efforts. We conducted our review from
August 2005 through February 2006 in accordance with generally accepted
government auditing standards. Details on our objective, scope, and
methodology are provided in appendix I.
Results in Brief:
It is too early to determine how effectively USCIS's long-term A-Files
automation effort is being managed because the scope, content, and
approach for moving from paper-based to paperless A-Files have yet to
be defined. The agency recently decided to re-examine this long-term
effort within the context of an agencywide organizational and business
transformation initiative, but it has not formally documented this
transformation initiative. Nevertheless, we support the concept of
aligning strategic automation of the A-Files with a transformation of
USCIS business operations, as this concept recognizes and reflects the
support role of information technology (IT) in organizational
transformation. As USCIS moves forward with what it is calling its
Transformation Strategy, it will be important for the agency to
leverage a number of interdependent transformation enablers that we
have previously reported as keys to success, such as having strong
executive leadership; establishing a comprehensive and integrated
transformation plan (e.g., goals and schedules); adopting effective
management processes, information systems, and related best practices
(e.g., use of an enterprise architecture); and employing results-
oriented performance measures.
USCIS is not effectively managing key planning activities associated
with its near-term A-Files automation effort, known as the Integrated
Digitization Document Management Program (IDDMP). In particular, it has
not yet developed a plan governing how it will manage this program and
the contractors working on it, and it has not yet developed a plan for
measuring and evaluating the results of a pilot test of a document
scanning and storage capability. According to USCIS officials, these
plans do not exist because the program is just getting started.
Nonetheless, USCIS has already awarded, or plans to award, contracts
totaling more than $20 million for this pilot. In addition, USCIS
officials told us they do not yet know which of the roughly 50 types of
A-Files-related forms will be scanned as part of the program. Without a
defined program scope and adequate program planning, IDDMP is at risk
of falling short of expectations.
To assist USCIS in its future transformation efforts, we are making
recommendations to the Secretary of Homeland Security aimed at ensuring
that certain keys to successful organizational transformation are
employed. We are also making recommendations to the Secretary for
improving IDDMP planning.
In written comments on a draft of this report, the Department of
Homeland Security agreed with our recommendations. In its letter, which
is reprinted in appendix II, the department described actions it is
taking, and plans to take, to address our recommendations. It also
provided technical comments that we have incorporated, as appropriate.
Background:
A mission of USCIS is to provide timely and accurate information and
services to immigrant and nonimmigrant aliens as well as to federal
employees who make informed decisions about, for example, granting
citizenship and approving immigration benefits. To perform this
mission, staff dispersed among approximately 89 of USCIS's field
offices[Footnote 1] require, among other things, access to an alien
applicant's case history information. Currently, this information
resides primarily in the paper-based A-Files.
To improve the reliability and currency of the A-Files, as well as
their accessibility to geographically and organizationally dispersed
users, USCIS intends to automate the A-Files, beginning with scanning
certain forms contained in the A-Files and storing the resulting
electronic images. While these automation efforts were to be part of
their IT Transformation Program, both A-Files automation and the IT
Transformation Program were recently incorporated into an agencywide
organizational and business transformation effort referred to as the
USCIS Transformation Strategy.
A-Files Are Important to Mission Operations of USCIS and Other Agencies:
A-Files are a critical component of the USCIS mission of ensuring the
integrity of the immigration system. These files are used by USCIS
staff to make immigration and citizenship decisions. Maintaining the
currency of these files and distributing them in a timely manner has
been a long-standing challenge.
An A-File is the set of records USCIS maintains on certain individuals
to document their interaction with USCIS in actions prescribed by the
Immigration and Nationality Act and other regulations. The single most
important set of records kept by USCIS are A-Files. An A-File contains
between one and hundreds of pages of documents and forms, such as
submitted benefits and naturalization forms, photographs, fingerprints,
and correspondence from family members or third-party sponsors.
According to USCIS, A-File information is used to:
* grant or deny immigration-related benefits,
* capture subsequent status changes,
* prosecute individuals who violate immigration law,
* document chain of custody for enforcement,
* provide immigrant statistics,
* control and account for records in compliance with the code of
federal regulations, or:
* certify the existence or nonexistence of records.
USCIS estimates that it currently has more than 55 million of these
paper-based files, each of which is to be maintained for a 75-year
period.[Footnote 2]
Generally, USCIS processes for adjudicating alien benefit requests vary
by type of application or form, and may involve creating, searching,
transporting, obtaining, examining, updating, or storing the A-File.
Figure 1 is an example of one such process: the Family-Based Adjustment
of Status, also referred to as the Application to Register Permanent
Residence, or Form I-485.[Footnote 3] The process of submitting this
form involves both manual and automated steps.
Figure 1: Family-Based Adjustment of Status Application (Form I-485)
Process:
[See PDF for image]
Source: GAO analysis of USCIS data.
[A] Computer Linked Application Management System 3.
[B]Central Index System.
[C]National File Tracking System.
[End of figure]
As illustrated in figure 1, the alien submits the I-485, along with the
required fee and supporting information, to a USCIS "lock box" in
Chicago that is operated by the Department of the Treasury on behalf of
USCIS.[Footnote 4] Treasury then captures the form electronically and
creates an extract file containing selected I-485 data elements that it
sends in an electronic format to the USCIS National Benefits Center
(NBC), along with the original paper form and supporting information.
NBC prepares a daily upload file of all cases that need biometric
appointments. This information is used to schedule an interview and
direct the applicant to the Application Support Center, where
biometrics, such as fingerprints, will be captured. NBC obtains the
paper application and the selected electronic data elements, and inputs
the data elements into the Computer Linked Application Management
System 3 (CLAIMS 3).[Footnote 5] In addition, NBC searches a USCIS
electronic index system, known as the Central Index System (CIS), to
determine whether an A-File already exists for the individual. If an A-
File does not exist, one is created. If one does exist, NBC determines
its location by accessing an additional system called the National File
Tracking System (NFTS), which tracks the physical location of the A-
File. When NBC obtains the requested A-File, it merges the Form I-485
into the A-File. NBC then performs an initial name check using the
Interagency Border Inspection System and the Federal Bureau of
Investigation (FBI) National Name Check Program, and updates the A-File
with the results.
While NBC is processing the application, the Application Support Center
is collecting the applicant's biometrics and sending the data
electronically to the FBI, where a criminal background check is
performed on the applicant. When the FBI has completed the background
check, it sends the results to NBC, which then prints the results and
adds them to the A-File.
When the A-File contains the I-485 application, biometrics, and
background check results, it is transported to the USCIS local office
closest to the applicant for a ruling on the applicant's request. The
local office reviews the file, interviews the applicant, and makes a
decision on the permanent residence request. The A-File is then
transported to the National Records Center in Missouri for storage (see
fig. 2).
Figure 2: A-Files Storage at National Records Center in Lee's Summit,
Missouri:
[See PDF for image]
Source: DHS.
[End of figure]
According to a recent report by the DHS Inspector General (IG), this
paper-based process is costly.[Footnote 6] For example, the estimated
costs for copiers and copy paper for one USCIS service center is more
than $400,000 per year. Further, according to senior USCIS officials,
the agency spends approximately $13 million each year transporting A-
Files within USCIS and to other bureaus and agencies.
Besides USCIS's need for A-Files, DHS's Immigration and Customs
Enforcement (ICE), Customs and Border Protection (CBP), and U.S.
Visitor and Immigrant Status Indicator Technology (US-VISIT) need
access to either the data in the A-Files or the A-Files themselves, as
do agencies external to DHS, including the FBI, the Department of
State, and state and local governments. For example, USCIS officials
told us that the FBI uses A-Files data in performing law enforcement
activities. In addition, USCIS documentation shows that ICE uses A-
Files as the principle source of information for prosecuting aliens who
have committed crimes and for immigration removal proceedings; CBP uses
A-Files when it interviews and arrests aliens; and the Department of
State uses data within the A-Files when issuing visas to alien
visitors. According to USCIS officials, obtaining access to these A-
Files has been a long-standing problem.
USCIS Intends to Address Limitations in Its IT and Data-Sharing
Environments:
The limitations in the USCIS IT and data-sharing environments are not
confined to the A-Files. According to a recent report by the DHS
IG,[Footnote 7] USCIS uses duplicative, nonintegrated, and inefficient
data systems that have limited information sharing, resulting in data
integrity and reliability problems. For example, adjudicators may need
to access more than a dozen systems using between 5 and 17 passwords,
and may have to restart these systems multiple times to process a given
application. In addition, the IG reported that the networks and
hardware platforms across USCIS offices are outdated and inconsistent.
The IG also reported that past problems in this IT environment have led
to small, disparate business process re-engineering initiatives that
were narrowly focused and were not sufficiently coordinated across the
organization to enable standardized processes.
To address these limitations, USCIS began an IT Transformation Program
in March 2005 that was led by the agency's Office of the Chief
Information Officer (OCIO) and was intended to move USCIS progressively
toward a paperless environment that facilitates information sharing. In
January 2006, USCIS reported that this IT transformation effort was
being subsumed into a new, long-term organizational and business
transformation effort, referred to as the USCIS Transformation
Strategy. Under this strategy, according to USCIS officials, long-term
solutions to its A-Files automation needs will be pursued within the
context of business process re-engineering.
In the interim, however, USCIS still intends to reduce the volume of
paper associated with its existing A-Files through a program called the
Integrated Digitization Document Management Program (IDDMP). According
to USCIS, the goals of the IDDMP are to:
* comply with laws governing electronic information storage and access
and information sharing;
* reduce the backlog of immigration benefit requests, ensure timely
access to files, and reduce paper-based file storage and transportation
costs; and:
* respond to a statement in The 9/11 Commission Report that all points
in the border system--from consular offices to immigration services
offices--will need appropriate electronic access to an applicant's
file.[Footnote 8]
To accomplish these objectives, IDDMP is to convert paper forms and
documents in existing A-Files to electronic images and manage the
retrieval, movement, retention, and disposition of these images. The
program is not intended to change existing USCIS core business
processes, but rather to merely reduce the amount of paper associated
with these business processes and improve user access to these scanned
forms and documents. The program is estimated to cost about $190
million over 8 years, which includes planning, acquisition of hardware
and software products and services, and operations and maintenance.
As part of the IDDMP, USCIS initiated a digitization and storage pilot
to scan approximately 1 million A-Files that include adjudicated I-485
forms and supporting documents (each containing about 100
pages).[Footnote 9] The purpose of the pilot is to validate that the
digital format satisfies user needs, to identify network storage
requirements, and to provide insight into potential scanning and
storage problems. According to USCIS program officials, the pilot
involves five separate contracts, three of which are primarily funded
from $20 million that Congress had designated for "the historical
records project to convert immigration records into an electronic,
digitally-accessible format."[Footnote 10] The other contracts were
awarded using other USCIS funding. Officials told us that they needed
to move quickly to obligate these funds before they were due to expire
at the end of September 2005, so they awarded four of the contracts in
September 2005. A description of each of the contracts follows.
Records digitization facility. According to program officials, this
contract is intended to set up a facility for scanning the piloted
number of A-Files and for scanning future A-Files. The contract is to
cover preparing the documents for scanning, scanning the documents, and
performing quality assurance checks on the captured images. It also is
to cover indexing the scanned images using the meta-data standards
defined in the requirements definition contract portion of the
digitization pilot and temporarily storing the images in a staging
server until they are accessed under the enterprise document management
service contract. According to officials, this contract was originally
awarded in September 2005, and a protest was filed in October 2005.
During the course of the protest, the agency took corrective action,
which included re-evaluation of the proposal; the protest was
dismissed, the original award was vacated, and a new award is expected
in March 2006.[Footnote 11] The estimated value of the new contract is
$14 million.
Enterprise document management service. This contract, awarded in
September 2005, is to gather technical requirements for the design and
implementation of a system to electronically manage the scanned images
created by the records digitization process. In addition, the
contractor is to design and implement a system capable of ensuring
image and data quality and compliance with the DHS document management
standard. It also includes development of a Web infrastructure and
implementation of user interface software components. The value of this
contract is about $2.3 million.
Storage facility infrastructure. Under this contract, awarded in
September 2005, the contractor is to provide hardware, software, and a
wide area network for the digitization and storage process. The value
of this contract is about $7.2 million.
Records business process re-engineering. This contract, which was
awarded in September 2005, includes determining how I-485 A-Files are
currently used for adjudicating permanent residence requests and
documenting the process for compilation, movement, digitization, and
lockdown of I-485 A-Files. The contractor is also to determine how to
effectively relocate the I-485 forms to the records digitization
facility. The estimated value of this contract is $487,400.
Requirements definition. This contract, which was awarded in October
2005 using fiscal year 2006 funds, covers gathering and documenting non-
USCIS stakeholder digitization and document management requirements,
including the meta-data requirements for indexing the scanned
documents. As of December 2005, the first draft of requirements had
been reviewed by USCIS and some of the external stakeholders, including
ICE, CBP, and the Department of State. The contractor's next steps are
to refine the requirements and develop, among other things, the plans
of action and a concept of operations for the digitization and document
management processes. The value of this contract is about $451,000.
USCIS Effectiveness in Managing Long-Term A-Files Automation Efforts
Remains to Be Seen, but Near-Term Document Digitization Program Is Not
Being Effectively Managed:
It is not yet possible to determine the effectiveness of USCIS's
management of its long-term A-Files automation effort because this
effort is not yet under way. However, USCIS currently has a near-term A-
Files automation effort under way (IDDMP) that it is not effectively
managing. Specifically, USCIS has not developed a program management
plan to guide program execution and provide the basis for reliable cost
and schedule estimates, and it does not have a plan for evaluating its
IDDMP concept of operations pilot test of a document scanning
capability. According to USCIS officials, these plans do not exist
because the program is just getting started. Nevertheless, five
contracts have either been awarded or are to be awarded under this
program, a pilot test is under way, and significant program costs are
anticipated. Without effective planning, IDDMP is at risk of falling
short of expectations and its funding requests cannot be justified.
Long-Term A-Files Automation Effort Is Being Re-evaluated; It Is Too
Early to Determine Whether It Is Being Effectively Managed:
As we have previously reported,[Footnote 12] technology alone cannot be
relied on to solve long-standing and fundamental business problems,
such as USCIS's dependence on paper-laden A-Files. Instead, our work
has shown that such organizational and business transformation requires
a number of key, interdependent elements working collectively to effect
meaningful and long-lasting institutional change and mission
improvement. These elements begin with strong, sustained executive
leadership to direct and oversee organizational reforms. Other elements
include a comprehensive and integrated business transformation plan,
strategic management of human capital, effective processes and related
tools (such as an enterprise architecture to provide a business and
technology blueprint and associated road map), and results-oriented
performance measures that link institutional, unit, and individual
personnel goals, measures, and expectations.
Until recently, USCIS had high-level, technology-focused plans for
modernizing its information systems environment, including plans for
automating its A-Files. These plans were part of the OCIO's IT
Transformation Program, which included four components: (1)
establishing and evolving a mature CIO organization; (2) improving the
IT infrastructure; (3) implementing an information-based architecture
to facilitate information standardization, security, and sharing; and
(4) providing new business capabilities. However, agency officials told
us in January 2006 that the IT Transformation Program has been
reconsidered and will now be incorporated into a broader effort
referred to as the USCIS Transformation Strategy. While this broader
organizational and business transformation strategy has yet to be
formally documented, officials told us that the strategy will, among
other things, align IT modernization with broader organizational and
business process changes. Restated, the IT modernization will be
neither separate from nor the driver of organizational transformation.
Rather, it will support and enable organizational transformation. To
illustrate, one approach to long-term A-Files automation could
potentially involve doing away with both paper forms and electronic
images of these forms and instead provide for the electronic capture of
data when the applications are filed using Web-based services and
management of the captured data via corporate data warehouses to
facilitate data access and sharing.
USCIS's more broadly based organizational and business transformation
concept, in which IT modernization will be treated as an enabler rather
than an independent undertaking or a driver, is more consistent with
effective transformation practices employed by successful
organizations. However, our experience has shown that successful
organizations also perform other key elements related to organizational
and business transformation. As we have previously reported,[Footnote
13] these elements are as follows:
* Ensure top leadership drives the transformation. Leadership must set
the direction, pace, and tone and provide a clear, consistent rationale
that brings everyone together behind a single mission.
* Establish a coherent mission and integrated strategic goals to guide
the transformation. Together, these define the culture and serve as a
vehicle for employees to unite and rally around.
* Focus on a key set of principles and priorities at the outset of the
transformation. A clear set of principles and priorities serves as a
framework to help the organization create a new culture and drive
employee behaviors.
* Set implementation goals and a timeline to build momentum and show
progress from day one. Goals and a timeline are essential because the
transformation could take years to complete.
* Dedicate an implementation team to manage the transformation process.
A strong and stable team is important to ensure that the transformation
receives the attention needed to persevere and be successful.
* Use the performance management system to define responsibility and
assure accountability for change. A "line of sight" shows how team,
unit, and individual performance can contribute to overall
organizational results.
* Establish a communication strategy to create shared expectations and
report related progress. The strategy must effectively communicate with
employees, customers, and stakeholders.
* Involve employees to obtain their ideas and allow them to participate
in the transformation. Employee involvement strengthens the process and
allows them to share their experiences and shape policies.
* Build a world-class organization. Building on a vision of improved
performance, the organization adopts the most efficient, effective, and
economical personnel, system, and process changes and continually seeks
to implement best practices. One such practice is the use of an
enterprise architecture.[Footnote 14]
The degree to which USCIS incorporates each of these key elements into
its current transformation efforts will help to determine the success
of its efforts, including the automation of its A-Files.
USCIS Is Not Effectively Managing Its Near-Term A-Files Automation
Effort:
Industry best practices and information technology program management
principles[Footnote 15] stress the importance of effective planning in
the management of programs, such as IDDMP. Inherent in such planning is
the development and use of program management plans, which define,
among other things, program goals and major milestones, delineate work
tasks and products and the associated schedules and resources for
achieving them, define management processes and structures (e.g.,
processes and structures for tracking and overseeing contractors),
identify key players and stakeholders and their roles and
responsibilities, and specify performance measures and reporting
mechanisms. They also require plans for testing and evaluating program
products and capabilities, including plans for evaluating the results
of pilot-testing efforts. Pilot evaluation plans include goals and
objectives, tasks, time frames, resource needs, roles and
responsibilities, and evaluation criteria and results measures. Such
plans are essential to ensuring, among other things, that programs are
executed properly and that funding requests are reliably derived.
USCIS has yet to develop either an IDDMP management plan or a pilot
evaluation plan. According to USCIS OCIO officials, the IDDMP is only
now being initiated, and the program office, including program staff,
is not fully in place. Thus, they said it is too early to expect these
plans to exist. Nevertheless, USCIS has awarded four contracts and is
in the process of awarding a fifth related to the program; these
contracts total about $20 million, including an ongoing digitization
and storage technology pilot test, and it estimates that it will spend
$190 million over an 8-year period on the program. At the same time,
officials told us they do not yet know which of the roughly 50 types of
forms associated with A-Files will be scanned and stored or the
sequence in which form types will be scanned. If all forms are scanned,
information provided by USCIS shows that scanning and storage could
cost as much as $550 million.
The absence of program planning was also noted in a December 2005
workshop by one of the digitization and storage pilot contractors.
Discussion points during this workshop included IDDMP's lack of a clear
vision and business objectives, critical gaps in the digitization
approach, confusion regarding terminology and roles and
responsibilities, and the lack of a management plan. Restated, this
means that large sums of resources are being invested, and much larger
sums are likely to be invested, on a program that lacks plans for
ensuring that the resources are invested effectively and that resource
estimates are valid. According to OCIO officials, while the funding
estimates are a "guess," $20 million in funds were designated in fiscal
year 2005 for converting historical immigration records into a
digitally accessible format, and they needed to move quickly to
obligate these funds before they expired at the end of September 2005.
These officials also told us that, while they did not have time to
fully establish and staff a program office that would have pre-empted
the contractor's concerns, they are now taking steps to deal with the
concerns. However, we have yet to receive documentation from USCIS as
to the scope and nature of the steps they are taking.
Without effective planning, including a clearly defined program scope,
IDDMP is at risk of falling short of expectations and its future
funding needs are not adequately justified.
Conclusions:
While it is too early to determine how effectively USCIS is managing
its long-term A-Files automation effort, USCIS's recent decision to
reconsider its long-term IT modernization plans--including the role of
IT in the agency's broader organizational and business transformation
efforts--was both warranted and appropriate. As USCIS defines and
pursues these strategic transformation efforts, it is important that
the agency adequately incorporate the keys to successful organizational
transformation discussed in this report.
With respect to management of its near-term A-Files automation efforts,
key IDDMP planning activities are not being performed effectively.
Given the contractual commitments being made on IDDMP, as well as the
potential for the cost of this program to reach well into the hundreds
of millions of dollars, it is critical that USCIS expeditiously develop
an effective program management plan and pilot evaluation plan to guide
the execution of the program and the pilot test, respectively. Without
these plans, IDDMP is at risk of not meeting expectations and its
funding needs are not adequately justified.
Recommendations for Executive Action:
To better ensure the success of USCIS's long-term transformation
efforts, to include A-Files automation, we recommend that the Secretary
of Homeland Security direct the Director of USCIS to implement the
following two recommendations:
1. Ensure that the key elements to successful organizational and
business transformation cited in this report are employed.
2. Ensure that both a program management plan and a pilot evaluation
plan are expeditiously developed and approved for IDDMP, along with a
reliable estimate of funding requirements.
Agency Comments:
In commenting on a draft of this report, the Department of Homeland
Security agreed with our recommendations and described actions that are
planned and under way to address them. It also provided technical
comments that we have incorporated, as appropriate. The department's
comments are reprinted in appendix II.
As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
from the report date. At that time, we will send copies to the
Secretary of Homeland Security, the Director of the United States
Citizenship and Immigration Services, and appropriate congressional
committees. We will also make copies available to others on request. In
addition, this report will also 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) 512-3439 or [Hyperlink, hiter@gao.gov]. Contact
points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix III.
Signed By:
Randolph C. Hite:
Director:
Information Technology Architecture and Systems Issues:
[End of section]
Appendix I: Objective, Scope, and Methodology:
Our objective was to determine whether the United States Citizenship
and Immigration Service (USCIS) is effectively managing its alien files
(A-Files) automation efforts. To accomplish this objective, we reviewed
and analyzed USCIS's information technology (IT) strategic plan, IT
Transformation Program planning documents, and IT Transformation
Program mission needs statement, as well as available documentation for
the Integrated Digitization Document Management Program (IDDMP). In
addition, we reviewed the A-Files budget submission to the Office of
Management and Budget, the digitization and storage contractor
statements of work, and requirements meeting minutes. Among other
things, we interviewed program officials, including the USCIS chief
information officer and the IDDMP manager. We also interviewed
officials from Immigration and Customs Enforcement and met with
officials at the Department of Homeland Security (DHS) Office of
Inspector General to discuss program management activities for the
IDDMP.
We conducted our work at DHS headquarters offices in Washington, D.C.,
from August 2005 through February 2006 in accordance with generally
accepted government auditing standards.
[End of section]
Appendix II: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
Homeland Security:
March 22, 2006:
Mr. Randolph C. Hite:
Director:
Information Technology Architecture and Systems Issues:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, D.C. 20548:
Dear Mr. Hite:
Thank you for the opportunity to comment on draft report GAO-06-375,
Information Technology: Near-term Effort to Automate Paper-based
Immigration Files Needs Planning Improvements. Technical comments have
been provided under separate cover.
We appreciate the Government Accountability Office's (GAO's) statement
that U.S. Citizenship and Immigration Services' (USCIS') recent
decision to reexamine prior agency plans for a strategic A-Files
automation solution within the context of an agency-wide transformation
strategy appropriately recognizes the integral support role that
information technology plays in organizational and business
transformation. USCIS is committed to transforming the way it does
business in support of its operations and customers.
We further appreciate the GAO's review of our near-term A-File
automation efforts. The GAO concluded that effective planning has not
been occurring. While USCIS is still in the early stages of this
effort, we agree that robust planning and management will help ensure
success. USCIS established a Digitization Requirements Steering
Committee that has gathered high-level technical requirements from key
external stakeholders that use the immigration file. USCIS has
developed a high-level project approach/time-line that included
establishing a team of functional managers that developed requirements,
plans-of-action, and a working group charter through facilitated
sessions. The managers identified eight components that are key to the
success of the Digitization Pilot; Policy and Process, Security and
Privacy, Personnel, Organization and Communication, Facility,
Training, Technology, and Quality Assurance. USCIS provided GAO a copy
of the Digitization Dependency Plan with a high level road map of its
process and progress to follow. The plans-of-action for each functional
area are now incorporated into the Digitization Integrated Plan. The
GAO will be provided a copy of the final Integrated Plan.
The immediate focus for the plans-of-action is the Pilot Project and
the Records Digitization Facility that will be established upon award
of the contract. The initial concept was to scan one million I-485 A-
Files. After further discussion, however, USCIS expects modifications
to the initial approach to reflect: the need to integrate the present
digitization efforts with the future envisioned for newer electronic
files under the Business Transformation Initiative; the need to
determine the feasibility and cost benefits of digitizing a wider range
of files with varying degrees of indexing; and, the need to collaborate
more effectively with U.S. Immigration and Customs Enforcement and U.S.
Customs and Border Protection. Accordingly, USCIS is considering a plan
to also select a wider range of A-file types and to put them through
rigorous testing from beginning to end of the digitized process,
including scanning, access, storage, retrieval and further file
manipulation. This plan will explore digitization's effectiveness for
use by adjudicators and law enforcement personnel. At the same time,
USCIS will engage in the larger policy and operational issues discussed
above to assess the effectiveness of the approach and new system
components, adjusting as indicated by the experiences of this pilot.
USCIS anticipates the pilot will provide insight into potential
scanning and storage challenges and mitigation strategies for a long-
term A-file implementation solution.
In response to the two recommendations, USCIS offers the following:
Direct the Director of USCIS to ensure that the key elements to
successful organizational and business transformation cited in this
report are employed.
USCIS has been modeling its transformation efforts after best practices
and believes the relevant suggestions by the GAO are being covered as
follows:
* Ensure Top Leadership Drives the Transformation. The USCIS Director
and the Acting Deputy Director have immersed themselves in this project
to ensure its success. They assembled an Integrated Transformation
Leadership Team consisting of officials from all disciplines within
USCIS.The Acting Deputy Director and Chief of Staff hold regular team
meetings ensuring that both long-and short-term goals are accomplished
as well as stressing the importance of the goals' various components.
The Manager of the Transformation Program reports directly to the
Acting Deputy Director.
* Establish a Coherent Mission and Integrated Strategic Goals to Guide
the Transformation. The mission of the USCIS Transformation Program is,
"USCIS will deliver a new business identity, fresh tools, and
dependable information to enable its people as confident and proud
stewards of America's promise."In order to accomplish this, USCIS will
focus improvements on three areas: national security and integrity,
customer service, and administrative economy and efficiency.USCIS will
ensure the integrity of the immigration system and the security of the
country by effectively collecting, analyzing, and sharing information
used to identify eligibility and status. USCIS will deliver world-class
customer service by providing timely and accurate information and
promoting civic values. USCIS will be an innovative, flexible, and
accountable organization that invests in its people and infrastructure
to ensure cost-effective and consistent results.
* Focus on a Key Set of Principles and Priorities at the Outset Of
Transformation. Transformation established four principal priorities
that will help create a new culture and drive employee behavior while
allowing USCIS to reach its business goals. These include:
- Ensuring the security and integrity of the system;
- Providing efficient and customer-oriented immigration benefit and
immigration services;
- Strengthening the infrastructure necessary to achieve USCIS' mission;
and:
- Operating as a high-performance organization and position USCIS as an
employer of choice.
* Set Implementation Goals and a Timeline to Build Momentum and Show
Progress From Day One. As currently planned, the USCIS Transformation
Program is developing a pilot that will test end-to-end electronic
processing of a limited selection of benefits with incremental, phased
national rollout once the concept is proven. The program will start in
25 field offices with five users per office, all located in the Western
Region. There will be five benefit types tested: international
adoptions, applications for certificates of citizenship, replacement of
naturalization certificates, locally produced employment authorization
documents, and non-immigrant religious workers and cultural
representatives. The pilot also has outlined specific milestones and
their anticipated completion in line with DHS investment requirements.
Interlacing with these milestones will be business and IT metrics. The
pilot awaits departmental approval and could be changed.
* Dedicate an Implementation Team to Manage the Transformation Process.
USCIS has dedicated several teams and management groups in order to
ensure and maintain focus on the goals that USCIS has set out to do.
The individuals participating in this transformation process come from
several different disciplines. At the head of this organization is the
Milestone Decision Authority (MDA). The MDA is the senior approval
authority and decides when it is appropriate to move onto the next
phase of the acquisition life cycle.Working hand in hand with the MDA
is the Leadership Team. The Leadership Team is responsible for
approving program direction, policy decisions, investment strategy,
acquisition strategy, and program scope. The Leadership Team is
assembled from USCIS Senior Executive Service Officials whose branches
will be the most affected by Transformation.
A member of the Leadership Team is the USCIS Transformation Program
Office (TPO) Program Manager. The Program Manager serves as a liaison
between the: Leadership Team and the four other parts of the
transformation team. These four remaining team components are
Acquisition and Program Support Team, Integrated Design Team,
Technology Solutions Team, and Communications and Change Management
Team. Each one of these last four teams is highly specialized and
focuses on a narrower topic within Transformation.
* Use the Performance Management System to Define Responsibility and
Assure Accountability For Change. USCIS has identified its current
business metrics and laid out new goals and goal metrics. These goal
metrics will incorporate a combined effort from every single aspect of
USCIS. At the conclusion of the Transformation Program, processes will
be standardized and immigration services will have defined measurable
parameters. For example, one of USCIS' goals is operational efficiency.
At this time the number of applications that are initially processed
correctly varies. Once transformation is concluded, less than 10 per
cent of applications submitted will require a second review.
* Establish a Communication Strategy to Create Shared Expectations and
Report Related Progress. The Communications and Change Management Team
will be responsible for developing and executing the communications
strategy plan; conceptualizing, organizing, and rolling out content for
Intranet sites and other communication mechanisms; coordinating,
tracking, and updating communications; and planning, coordinating, and
guiding content development for key communications events with
stakeholders and the end-user community.
* Involve Employees to Obtain Their Ideas and Gain Their Ownership For
Transformation. Transformation will take a proactive approach to
strategizing and planning this area. There will be ongoing, targeted
site visits to establish Training and Change Management needs. This
will allow feedback to occur and appropriate measures in response to
this feedback to take place. Employees will have the opportunity to be
heard and impact the way the program will be shaped.
* Build a World-Class Organization. USCIS wants to change for the
better, and also become "best-in-class" in the government arena. USCIS
believes this will be possible through Transformation. It plans on
doing this by examining other benchmark best practices, as well as
constantly striving to improve in its core competencies.
Direct the Director of USCIS to ensure that both a program management
plan and pilot evaluation plan are expeditiously developed and approved
for Integrated Digitization Document Management Program (IDDMP), along
with a reliable estimate of funding requirements.
USCIS is in the process of establishing a Project Management Office to
manage the Digitization effort. This office will manage progress
against the existing program management plan and develop a pilot
evaluation plan, as well as reliable funding estimates, as the program
moves forward in development. It will also address the likely
modifications to the initial approach to reflect: the evolution of
USCIS' Business Transformation Initiative; the need to integrate the
present digitization efforts with the future envisioned for newer
electronic files under the Business Transformation Initiative; and, the
need to determine the feasibility and cost benefits of digitizing
certain files. At the same time, USCIS will analyze the larger policy
and operational issues discussed above to assess the effectiveness of
the approach and new system components, adjusting as indicated by the
experiences of this pilot.
Thank you again 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:
Steven J. Pecinovsky:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact: Randolph C. Hite, (202) 512-3439 or [Hyperlink,
hiter@gao.gov]
Staff Acknowledgments:
In addition to the contact named above, the following staff made key
contributions to this report: Michael Marshlick, Assistant Director;
Elena Epps; Kate Feild; and Nancy Glover.
(310610):
[End of Section]
FOOTNOTES
[1] According to agency officials, of USCIS's approximately 250
offices, 89 are considered file control offices. A file control office
is an office that is authorized to create, store, transfer, receive,
maintain, and retire A-Files.
[2] According to USCIS program officials, the 75-year storage period is
a National Archive and Records Administration requirement.
[3] Form I-485 is one of the more complex forms and business processes
that USCIS uses. It is used by adjudicators to make decisions on
granting permanent residency to alien applicants.
[4] The purpose of the lock box is to provide a single mailing location
for applications and a capability for accepting and depositing fees.
[5] CLAIMS 3 is a customer repository designed to provide funds control
for fees collected with applications, record the results of
adjudications for each benefit, and provide case status information to
applicants. This system became operational in 1993.
[6] DHS, Office of Inspector General, USCIS Faces Challenges in
Modernizing Information Technology, OIG-05-41 (Washington, D.C.,
September 2005).
[7] OIG-05-41.
[8] The National Commission on Terrorist Acts Upon the United States,
The 9/11 Commission Report (Washington, D.C., July 2004), 388.
[9] USCIS officials stated that they are now considering modifying the
scope of the pilot.
[10] House of Representatives Conference Report 108-774 to accompany
H.R. 4567 (Oct. 9, 2004).
[11] Fiscal year 2005 funds remain available for this contract pursuant
to 31 U.S.C. § 1558, which generally provides that funds available to
an agency for a contract at the time a protest is filed shall remain
available for obligation for 100 days after the date a final ruling is
made on the protest.
[12] See, for example, GAO, National Aeronautics and Space
Administration: Long-standing Financial Management Challenges Threaten
the Agency's Ability to Manage Its Programs, GAO-06-216T (Washington,
D.C.: Oct. 27, 2005).
[13] GAO, Highlights of a GAO Forum: Mergers and Transformation:
Lessons Learned for the Department of Homeland Security and Other
Federal Agencies, GAO-03-293SP (Washington, D.C.: Nov. 14, 2002).
[14] An enterprise architecture provides a clear and comprehensive
picture of an entity--whether an organization (e.g., federal department
or agency) or a functional or mission area--that cuts across more than
one organization. This picture consists of snapshots of both the
enterprise's current "as is" operational and technological environment
and its target or "to be" environment, as well as a capital investment
road map for transitioning from the current to the target environment.
These snapshots further consist of "views," which are basically one or
more architecture products that provide conceptual or logical
representations of the enterprise.
[15] Institute of Electrical and Electronics Engineers, IEEE/EIA Guide
for Information Technology, IEEE/EIA 12207.1 - 1997 (April 1998).
GAO's Mission:
The Government Accountability Office, the investigative arm of
Congress, exists to support Congress in meeting its constitutional
responsibilities and to help improve the performance and accountability
of the federal government for the American people. GAO examines the use
of public funds; evaluates federal programs and policies; and provides
analyses, recommendations, and other assistance to help Congress make
informed oversight, policy, and funding decisions. GAO's commitment to
good government is reflected in its core values of accountability,
integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through the Internet. GAO's Web site ( www.gao.gov ) contains
abstracts and full-text files of current reports and testimony and an
expanding archive of older products. The Web site features a search
engine to help you locate documents using key words and phrases. You
can print these documents in their entirety, including charts and other
graphics.
Each day, GAO issues a list of newly released reports, testimony, and
correspondence. GAO posts this list, known as "Today's Reports," on its
Web site daily. The list contains links to the full-text document
files. To have GAO e-mail this list to you every afternoon, go to
www.gao.gov and select "Subscribe to e-mail alerts" under the "Order
GAO Products" heading.
Order by Mail or Phone:
The first copy of each printed report is free. Additional copies are $2
each. A check or money order should be made out to the Superintendent
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or
more copies mailed to a single address are discounted 25 percent.
Orders should be sent to:
U.S. Government Accountability Office
441 G Street NW, Room LM
Washington, D.C. 20548:
To order by Phone:
Voice: (202) 512-6000:
TDD: (202) 512-2537:
Fax: (202) 512-6061:
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: www.gao.gov/fraudnet/fraudnet.htm
E-mail: fraudnet@gao.gov
Automated answering system: (800) 424-5454 or (202) 512-7470:
Public Affairs:
Jeff Nelligan, managing director,
NelliganJ@gao.gov
(202) 512-4800
U.S. Government Accountability Office,
441 G Street NW, Room 7149
Washington, D.C. 20548:
