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Immigration and Naturalization Service
Management of Property

Report No. 01-09
March 2001
Office of the Inspector General

APPENDIX VI

INS COMMENTS ON THE REPORT

INS RESPONSE: Concur. The guidelines for inventorying the over $5,000 property within the annual inventory, contained in Personal Property Operations Handbook (PPOH) Chapter 7 (and included with the annual inventory call memorandum during late third quarter) have been updated to state the special attention requirement. Issuance in INSERTS is projected during the second quarter of fiscal year (FY) 2001.

RECOMMENDATION 3: Ensure that all property costing over $25,000 is identified and added to the AMIS database. Specific attention should be given to weapons training systems and similar property.

INS RESPONSE: Concur. Reinforcement of this Asset Management Information System (AMIS) data entry requirement will be stated in the "Capitalized Personal Property" paragraph of PPOH Chapter 1. Issuance in INSERTS is projected during the second quarter of FY 2001.

RECOMMENDATION 4: Ensure that all locally purchased property is added to AMIS if it meets the dollar threshold level or if it is computer equipment with data storage capability.

INS RESPONSE: Concur. Partially resolved. PPOH Chapter 3 paragraph "Establishing Accountability and Acceptance" provides the requirement for AMIS data entry of inventoriable personal property irrespective of whether the property is received from a Servicewide purchase or a local purchase. Property management reviews and INSpects will confirm compliance with this requirement. Regarding computer equipment with data storage capability, see response to recommendation 7.

RECOMMENDATION 5: Ensure that proper inventories are conducted as required, timely adjustments are made to the property management system, and adequate documentation is maintained.

INS RESPONSE: Concur. Resolved. PPOH Chapter 7, "Physical Inventories and Reconciliation of Personal Property" provides complete requirements on the conduct of inventories, AMIS adjustments, and maintenance of documentation. With the annual inventory call, these requirements are re-conveyed. Property management reviews and INSpects will confirm compliance with these requirements.

RECOMMENDATION 6: Ensure that Property Custodians do not actively participate in physical inventories of property under their jurisdiction.

INS RESPONSE: Concur. Resolved. PPOH Chapter 7, "Physical Inventories and Reconciliation of Personal Property" states the requirement that Property Custodians not actively participate in the physical inventorying of property under their jurisdiction, to include a statement of that fact as part of the completed inventory package. With the annual inventory call, this requirement is re-conveyed. Property management reviews and INSpect reviews will confirm compliance with this requirement. The INSpect Guide is under revision to incorporate this specific audit step.

RECOMMENDATION 7: Require that all property with data storage capabilities be subject to periodic inventory, regardless of acquisition cost.

INS RESPONSE: Concur. In PPOH Chapter 7, "Physical Inventories and Reconciliation of Personal Property," the lower threshold of $1,001 for biennially inventorying automated data processing equipment with memory will be eliminated. Issuance in INSERTS is projected during the second quarter of FY 2001. PPOH Chapter 7 includes an $1 and under inventory as part of the biennial inventory process to address mis-costing in AMIS.

RECOMMENDATION 8: Ensure that training is provided to all employees who have property management responsibilities, including both supervisory and property management personnel. The training should include instruction in general property management policies and procedures, including the use of AMIS as the Service's core personal property system.

INS RESPONSE: Concur. During the third quarter of FY 2001, we plan to have a Servicewide workshop with Property Custodian (PC) personnel having property management responsibilities to review property management policies and procedures, including the use of AMIS as the Service's core personal property management system. Certified property management training is being planned for Administrative Center and Headquarters Property Management Coordinator (PMC) staff during the second quarter of FY 2001. Personnel under PCs have received certified training on and authorization for property disposal from their PMCs.

RECOMMENDATION 9: Ensure that all INS property is collected and adequately documented when an employee leaves the Service. Also, revise personal property cards to require the signature of a local Firearms Control Officer to confirm the return of weapons from departing law enforcement officers.

INS RESPONSE: Concur. Complete procedures for turn-in of property by employees leaving the Service are contained in Administrative Manual section 1.1.115, which falls under the Office of Human Resources and Development (HQHRD). The National Firearms Unit (NFU) has submitted a request to HQHRD to update the Exit Clearance Form (G-559) to include the Firearms Control Officer (FCO) signature. This would ensure that an officer, in the process of departing from the Service must report to the FCO as an element of out-processing.

RECOMMENDATION 10: Establish and maintain a perpetual listing of weapons that have been reported as lost, missing, or stolen.

INS RESPONSE: Concur. Resolved. The Firearms Inventory System maintains a list of all firearms that have been reported lost, stolen or missing.

RECOMMENDATION 11: Complete reviews of case files for each of the 539 lost, missing, and stolen weapons, obtain required documentation, and initiate actions to enter the appropriate data into the NCIC.

INS RESPONSE: Concur. Partially resolved. The NFU has compiled a case file on each of the 539 lost, missing and stolen firearms. These files contain all available documentation to include memoranda, police reports, National Trace Summary reports, manufacturer invoices, etc. To better facilitate the tracking and data entry of lost, missing and stolen firearms, the NFU is in the process of obtaining access to NCIC.

RECOMMENDATION 14: Establish and enforce procedures that require Firearms Control Officers to be notified when employees are transferred with INS weapons and to make timely adjustments to AMIS.

INS RESPONSE: Concur. AM section 1.1.115, in addition to covering employees leaving the Service, also states that the Exit Clearance Form (G-559) should be completed for any employee who is reassigned within the Service. As stated in the response to recommendation 9, the G-559 is in the process of being updated to include the FCO signature. This would ensure that the FCO is notified of an officer's transfer. The FCO can then properly document the return or transfer of the officer's Service-issued firearm.

RECOMMENDATION 15: Reinforce the policy that all weapon purchases must be made by the NFU and periodically monitor enforcement of the policy.

INS RESPONSE: Concur. Partially resolved. INS Firearms Policy, AM 20.012 states that all firearms must be acquired by the NFU. During a Firearms Accountability Review (FAR), all firearms are inventoried, and all associated paperwork is reviewed for compliance. All unauthorized acquisitions are documented and reported. The INSpect Guide covering firearms is being updated to confirm compliance with this acquisition requirement.

RECOMMENDATION 16: Continue the comprehensive review of firearms accountability which has been initiated by the National Firearms Unit and establish a plan to provide more timely Servicewide or risk-based coverage.

INS RESPONSE: Concur. Resolved. The NFU has completed twenty-two FARs throughout the Service. A minimum of six FARs are scheduled during FY 2001. Locations are prioritized by the status of their firearms inventory, quarterly qualification data, training needs, and resources available.

Please direct all questions pertaining to recommendations 1 through 8 to Gene Kupferer, Director, Logistics Division at 616-7001, and for recommendations 9 through 11 and 14 through 16 to Carl Michaud, Acting Director, NFU at (814) 946-9981.