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Immigration and Naturalization Service Collection of Fees at Air Ports of Entry

Report No. 02-42
September 2002
Office of the Inspector General

APPENDIX IV
ANALYSIS AND SUMMARY OF ACTIONS NECESSARY TO CLOSE REPORT

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A draft report was issued to the INS on July 18, 2002. INS responded on September 17, 2002, with sufficient proposed corrective action to resolve Recommendations 1, 2, and 4 through 6. Responses to Recommendations 3, 7, and 8 were insufficient and remain unresolved. The status of each recommendation follows:

  1. Resolved. This recommendation was divided into nine subparts. INS concurred with each of the subparts and detailed individual corrective action to be completed by the end of calendar year 2002. To close this recommendation, please provide us with sufficient documentation to confirm that promised corrective action was taken.

  2. Resolved. The INS indicated that they will designate a single control point for issuing G-711 receipts, mandate their use at all POEs, require that these receipts be accounted for, and require that manual receipts be used in strict sequential order. INS further indicated that the revised procedures will be available on their Intranet via PowerPoint. To close this recommendation, please provide us with sufficient documentation to confirm that promised corrective action was taken.

  3. Unresolved. The INS agreed to discontinue the use of the DOS-based FIMS system for fee receipting purposes. However, while INS evaluates the FIMS 2000 system used only in the Buffalo District, the issue of being able to alter a receipt in the FIMS 2000 database after the receipt was provided to the alien must be thoroughly analyzed for current security gaps.

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    This capability and lack of an audit trail was demonstrated by the OIG auditor to INS supervisors. To close this recommendation, INS must clearly demonstrate that the FIMS 2000 system cannot be easily corrupted without detection, and the system must be certified by the Department's Information Management and Security Staff.

  4. Resolved. The INS agreed to modify the NAFTA checklist. It is important to understand that the Trade NAFTAs being processed did not contain any hard copy form or letter of request to document the adjudication in two of the eight ports we reviewed. In three others of the eight ports tested, the official copy of the letter was forwarded to another port. Like the Forms I-193, I-90, I-129, I-131, and the I-68, INS should use a form to document the adjudicated Trade NAFTAs. These forms should be maintained with the receipt for the fee paid for a period of six years and three months. To close this recommendation, please send us a copy of the modified checklist and instructions to all ports to use it or something similar for each Trade NAFTA adjudicated.

  5. Resolved. The INS intends to update the Inspector's Field Manual and port directors will be afforded six months to implement the new procedures. Subsequently, the port directors will certify in writing they have implemented the new procedures. To close this recommendation, please provide documentation that the Manual has been updated and that the port directors have certified implementation of the new procedures.

  6. Resolved. INS indicated that an analysis and timeframes will be established for implementation of uniform location codes. The analysis is expected to be completed by December 31, 2002. To close this recommendation, please provide us with documentation of the establishment and implementation of the uniform codes.

  7. Unresolved. INS concurred with our recommendation to develop criteria and comparative reports for periodic review and reconciliation of the fee collection data in the accounting system and the Performance Analysis System. However, INS did not provide any details or a timetable on what or how this is to occur. Since the corrective action on this recommendation will have to be linked to INS's proposed corrective action associated with Recommendations 1 (new procedures for receipts), 6 (unique location codes), and 8 (modified Inspection Summary Report), INS should reevaluate Recommendation 7 and provide to us specific proposed actions along with a timetable for completion.

  8. Unresolved. INS indicated that they revised the G.22 report in October 2000. However, the revised G.22 report allows for the waiver of fees for the I-193 only (lines 118 and 119). The G.22 does not record fee waivers separately for the I-68 (lines 106 and 107), I-765 (line 120), I-131 (not on form), Trade NAFTAs (line 123), and I-90s (lines 125 and 126). Please reevaluate this recommendation and provide a more specific and accurate response.

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