The Immigration and Naturalization Service's
Automated I-94 System
Report Number 01-18
August 6, 2001
According to the INS's strategic plan, its mission is "to determine the admissibility of persons seeking entry and to adjust the status of and provide other benefits to legally entitled noncitizens within the country with proper regard for equity and due process. This includes assistance to those who seek permanent resident status and those who wish to become citizens through naturalization."
In 1995, the INS began efforts to identify a process to automate the collection of I-94 arrival and departure data at airports of entry. The manual system in use at the time, which continues to be the primary system today, required most non-U.S. citizen and non-permanent residents entering the United States to complete one of three forms - the regular I-94 form, the I-94W form for those visitors participating in the Visa Waiver Pilot Program 1 , or the I-94T for those passengers in transit to a final destination outside of the United States.
The manual form process works as follows. During airline check-in at a foreign port of departure or during the flight, most non-U.S. citizens receive one of the I-94 forms that they are required to fill out during the flight. Upon arrival in the United States, the passenger surrenders the completed form to an INS inspector. After completion of the inspection process, the inspector detaches the "departure record" portion of the form and returns it to the passenger. The inspector retains the "arrival record" portion of the form. The INS sends the arrival records to a contractor who keys in the data and creates an input tape for the Nonimmigrant Information System (NIIS). When passengers depart the United States, the airlines collect the departure records and provide those records to INS inspectors at the port of entry. The INS also sends the departure record to a contractor for data entry and the creation of an input tape. Another contractor uploads the data on the input tapes into NIIS. The data is supposed to be matched within NIIS to identify overstays.
In 1995, personnel at the INS were concerned with the reliability of the I-94 data collected with the manual system; they reported in a Systems Development Life Cycle (SDLC) 2 document the following problems. Arrival data was not entered into NIIS in a timely fashion. Approximately 25 percent of arrival and departure records did not match. Departure records were not always collected. As a result of problems collecting departure records, some nonimmigrants were identified as overstays even after they had left the country. Forms were often incomplete and inspection processing was slow. I-94s were not delivered from the port of entry to the data entry contractor in a timely fashion.
The Automated I-94 System currently in use was introduced by the INS in May 1997. The system captures I-94 arrival and departure data electronically at airports of entry, and it uploads non-U.S. citizen information to the Arrival/Departure Information System (ADIS) 3 which forwards the data to NIIS. A pilot of the system was operated in Philadelphia by US Airways and the INS. Currently, US Airways and TWA are the only two participating airlines and only at four U.S. airports: Charlotte, Philadelphia, Pittsburgh, and St. Louis. For boarding passengers, the airline produces automated I-94 arrival cards using Advance Passenger Information System (APIS) 4 data. The new automated I-94 arrival card, which is similar to a boarding pass, uses magnetic stripe technology to encode the APIS data and takes the place of the three manual versions.
At the port of entry, the passenger presents the I-94 arrival card to the immigration inspector, who uses the Automated I-94 System to interface with APIS and the Interagency Border Information System (IBIS) 5 , and electronically confirm the arrival. When the inspection is complete, the inspector creates an arrival record in the local I-94 database by adding the actual arrival information, produces the automated I-94 departure card, and provides it to the passenger. The Automated I-94 System generates an admission number that is printed and encoded on both the arrival and departure cards. The arrival record is stored in a local database until a daily upload to ADIS occurs. The automated I-94 departure card, showing the details of admission, is given to the traveler. The traveler is supposed to surrender it upon departure from the United States. The collection process is unchanged from the manual system. The departure cards are collected by the air carriers and returned to the INS. The departure information is electronically collected and stored in the I-94 database until it is uploaded to ADIS.
Currently, the relevant data from ADIS is transferred to NIIS. Information from NIIS on individuals that should not be admitted to the United States is transferred to the National Automated Immigration Lookout System (NAILS). NAILS data is the INS's contribution to IBIS, the interagency system that contains lookouts from the Departments of State and Agriculture, the Customs Service, and the INS. Finally, the Automated I-94 System queries IBIS to determine if the individual being inspected is the subject of a lookout. The chart below shows the relationship of the Automated I-94 System to other databases on which INS immigration inspectors rely. The flow of information from the I-94 System to the related systems and subsequent data processing should allow immigration inspectors to identify confirmed overstays during the inspection process.
The Automated I-94 System and Related Databases
|Automated I-94 System||ADIS||NIIS|
|IBIS (with APIS Data)||NAILS|
In 1996, the Illegal Immigration Reform and Immigrant Responsibility Act was passed. Section 110 of the Act required the Attorney General to develop an automated entry and exit control system to: (1) collect a record of departure for every alien departing the United States and match the record of departure with the record of the alien's arrival in the United States; and (2) enable the Attorney General to identify, through on-line searching procedures, lawfully admitted nonimmigrants who remain in the United States beyond the period authorized.
In June 2000, concerned that full implementation of Section 110 would cause excessive and costly traffic delays at the land borders, Congress passed the Immigration and Naturalization Service Data Management Improvement Act. The Act amended Section 110 to require the Attorney General to create an Integrated Entry and Exit Data System. This electronic system was to provide access to, and integrate, alien arrival and departure data that are: (1) authorized or required to be created or collected under law; (2) in an electronic format; and (3) in a database of the Department of Justice or the Department of State, including those created or used at ports of entry and at consular offices. In addition, unlike Section 110, the Act prohibits the INS from imposing any "new documentary or data collection requirements on any person in order to satisfy" the requirement to build an Integrated Entry and Exit Data System.
Prior Audit Work
In September 1997, the OIG reported that the INS could not identify individual overstays and, although the INS had some demographic information on overstays, it could not adequately describe the characteristics of the overstay population in the United States, such as countries of origin, occupations, or worksites where overstays are employed. Such information would assist the INS in developing an enforcement strategy that effectively targets overstays.
In the past five years, both the OIG and the U. S. General Accounting Office (GAO) have reported that the INS does not adequately manage its automation systems. In July 1999, in a follow-up to a 1998 audit, the OIG found that: (1) estimated completion dates for some automation projects were delayed without explanations for the delays, (2) costs continued to spiral upward with no justification for how the funds are spent, and (3) projects were nearing completion with no assurance that they would meet performance and functional requirements.
In August 2000, the GAO reported that the INS does not have an enterprise architecture which is an institutional systems blueprint that defines in both business and technology terms the INS's current and target operating environments and provides a road map for moving between the two. Moreover, the GAO found that the limited steps the INS had taken toward developing such a blueprint had been hampered by a lack of management controls and were therefore unlikely to produce a complete and useful enterprise architecture. In December 2000, the GAO reported that the INS did not have the defined and disciplined investment management processes necessary to effectively manage its information technology investments.
In response to the two GAO reports referenced above, the INS has two initiatives under way. According to INS officials, the INS assigned responsibility for enterprise architecture and information technology (IT) investment management to the INS Office of Strategic Information and Technology Development, which has day-to-day responsibility for both the development of an enterprise architecture and the implementation of an improved IT investment management process. The INS officials told us that the INS has obtained the FY 2001 funding, staffing, and contractor support needed to implement both the enterprise architecture and IT investment management, and that the INS expects to make significant progress toward development of an INS target architecture within 12 months. As recommended by the GAO, the INS plans to submit its IT investment management process to the Department of Justice's Chief Information Officer for approval. The INS expects the new IT investment management process to be implemented by the end of FY 2001.