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Processing Deadlines, but Processing Applicants Deployed Overseas Is a 
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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 ˝ 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 ˝ 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-˝ 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 ˝ 
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 ˝ 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 ˝-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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