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entitled 'Immigration Application Fees: Current Fees Are Not Sufficient 
to Fund U.S. Citizenship and Immigration Services' Operations' which 
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January 5, 2004:

The Honorable Orrin G. Hatch: 
Chairman: 
The Honorable Patrick J. Leahy: 
Ranking Minority Member: 
Committee on the Judiciary: 
United States Senate:

The Honorable F. James Sensenbrenner, Jr.: 
Chairman: 
The Honorable John Conyers, Jr.: 
Ranking Minority Member: 
Committee on the Judiciary: 
House of Representatives:

Subject: Immigration Application Fees: Current Fees Are Not Sufficient 
to Fund U.S. Citizenship and Immigration Services' Operations:

The Homeland Security Act of 2002 (HSA)[Footnote 1] established the 
Bureau of Citizenship and Immigration Services (CIS)[Footnote 2] within 
the Department of Homeland Security (DHS). CIS is responsible for 
several functions transferred from the former Immigration Services 
Division of the Immigration and Naturalization Service (INS) under the 
Department of Justice. CIS's functions include adjudicating and 
processing applications for U.S. citizenship and naturalization, 
administering work authorizations and other petitions, and providing 
services for new residents and citizens. CIS collects fees from 
applicants to process the various immigration-related applications and 
petitions. CIS also receives appropriated funds to pay for 
administrative and overhead costs such as records management and 
backlog reduction.[Footnote 3] HSA requires that we report on whether 
CIS is likely to derive sufficient funds from fees to carry out its 
functions in the absence of appropriated funds.[Footnote 4]

This report summarizes the information provided during our November 24, 
2003, briefing to your staff on this topic. The enclosed briefing 
slides highlight the results of our work and the information provided. 
Specifically, we determined application fees collected and projected 
for funding CIS operations for fiscal years 2001 through 2003 and 
compared those totals with identifiable operating costs for those 3 
fiscal years as a basis for determining whether fees collected would 
likely be sufficient to fund CIS's operating costs.

Results in Brief:

We determined that fees were not sufficient to fully fund CIS's 
operations. In part, this has resulted because (1) the current fee 
schedule is based on an outdated fee study that did not include all 
costs of CIS's operations and (2) costs have increased since that study 
was completed due to an additional processing requirement and other 
actions.

While it is clear fees are insufficient to fully fund CIS's operations, 
there is insufficient cost data to determine the full extent of the 
shortfall. A fundamental problem is that CIS does not have a system to 
track the status of each application as it moves through the 
process.[Footnote 5] Accordingly, CIS does not have information on the 
extent to which work on applications in process remains to be finished. 
In addition, CIS does not know the current cost of each step to process 
each application. The effect is that CIS knows neither the cost to 
process new applications nor the cost to complete pending applications. 
Further, because DHS is still determining how administrative and 
overhead functions will be carried out and the related costs allocated, 
CIS does not know what future administrative and overhead costs will 
be.

For the 3-year period from fiscal year 2001 through 2003, CIS's 
reported operating costs exceeded available fees by almost $460 
million, thus creating the need for appropriated funds. CIS projects 
that this situation will remain in fiscal year 2004. Since the 
beginning of fiscal year 2001, the number of pending applications 
increased by more than 2.3 million (about 59 percent) to about 6.2 
million at the end of fiscal year 2003. This increase occurred despite 
additional appropriations beginning in fiscal year 2002 of $80 million 
annually to address the backlog. In addition, CIS has not performed an 
analysis of the steps needed to reduce processing times to the 6-month 
average goal established in the President's backlog initiative. These 
times increased significantly in fiscal year 2003 to levels well above 
the 6-month target established in CIS's March 2002 Backlog Elimination 
Plan.

Absent actions to increase fees, reduce processing costs and times, or 
both, as well as to improve the timeliness and completeness of fee 
schedule updates, CIS will continue to need appropriated funds to avoid 
even greater increases in the backlog of pending applications. The full 
costs of CIS's operations cannot be determined until analyses of the 
costs to process incoming and pending applications and administrative 
and overhead costs are completed.

Recommendations for Executive Action:

In order to achieve the goals of the President's backlog initiative, we 
recommend that the Secretary of Homeland Security direct the Director 
of CIS to perform an analysis of current processing functions to 
determine steps needed to reduce the processing time to an average of 6 
months or less.

In order to determine the cost to process new and pending applications, 
we recommend that the Secretary of Homeland Security direct the 
Director of CIS to:

* perform a comprehensive fee study to determine the costs to process 
new immigration applications and:

* determine the costs to eliminate the backlog of pending applications.

In order for CIS to know the full cost of its operations, we recommend 
that the Secretary of Homeland Security direct the Deputy Secretary to 
identify which support services and functions, such as shared services, 
modernizing and supporting shared databases, shared infrastructure, and 
other forms of support, and the cost of those functions should be 
transferred or allocated to CIS.

Regarding the timing of fee schedule updates, we recommend that the 
Secretary of Homeland Security direct the Director of CIS to identify 
options to improve the timeliness for implementing fee updates to help 
ensure that all costs are captured.

Agency Comments and Our Evaluation:

We obtained oral comments on a draft of our briefing slides from DHS 
and CIS officials. They generally agreed with our conclusions and 
recommendations. However, they stated that our recommendations did not 
address the fact that fee schedules do not go into effect promptly, 
thus delaying implementation of fee levels that would help ensure that 
the full costs of adjudications are covered. The timing of fee schedule 
updates is a key issue, and we have added a recommendation to address 
this issue. DHS and CIS officials also provided technical comments, 
which we incorporated as appropriate.

Scope and Methodology:

We analyzed actual and estimated/projected application fees and 
appropriations that fund CIS operations and the related costs for 
fiscal years 2001 through 2003. To determine if fees collected were 
sufficient to fund CIS's operations, we (1) interviewed CIS staff and 
officials and external auditors, (2) reviewed biennial fee review 
reports, (3) reviewed audit reports, (4) reviewed financial records and 
budget-related documents, (5) analyzed various other documents provided 
by CIS containing information on numbers of applications and 
application fees, and (6) analyzed data on fee collections and 
appropriated funds and compared these to our analysis of the related 
costs.

We assessed the reliability and completeness of the CIS-provided data 
for fiscal years 2001 and 2002 by reconciling the funds received and 
costs incurred to the audited financial statements. For fiscal year 
2003 data, the audit was not yet complete. We did not otherwise verify 
the data. We did not assess the effectiveness of CIS's application 
processing functions or verify the accuracy of application totals.

We requested comments on a draft of the enclosed briefing slides from 
DHS and CIS officials. We received oral comments from DHS and CIS that 
were incorporated into the briefing slides and this report as 
appropriate. We conducted our work from March through November 2003 in 
accordance with generally accepted government auditing standards.


We are sending copies of this report to congressional committees and 
subcommittees responsible for issues related to immigration services 
and the Department of Homeland Security, the Secretary of Homeland 
Security, the Deputy Secretary of the Department of Homeland Security, 
and the Director of CIS. This report is also available at no charge on 
GAO's home page at [Hyperlink, http://www.gao.gov] h [Hyperlink, http:/
/www.gao.gov] ttp://www.gao.gov. If you have any questions about this 
report, please contact me at (202) 512-9508 or Steven Haughton, 
Assistant Director, at (202) 512-5999. You may also reach us by e-mail 
at [Hyperlink, calboml@gao.gov] or [Hyperlink, haughtons@gao.gov]. 
Additional contributors to this assignment were Diane N. Morris and 
Estelle M. Tsay.

Linda M. Calbom 
Director 
Financial Management and Assurance:

Signed by Linda M. Calbom: 

Enclosure:

[End of section]

Enclosure:

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[End of figure] 

[End of section]

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FOOTNOTES

[1] Pub. L. No. 107-296, § 451, 116 Stat. 2195.

[2] The bureau is now referred to as the United States Citizenship and 
Immigration Services (CIS).

[3] A backlog exists when the processing time for a newly filed 
application exceeds the processing target time, which is 6 months or 
less for every application.

[4] Pub. L. No. 107-296, § 477(d)(3), 116 Stat. 2210.

[5] According to CIS officials, the deployment of a new system that 
will track the status of each application is expected in 2006.