| Return to the USDOJ/OIG Home Page |
Immigration and Naturalization Service Collection of Fees at Air Ports of Entry
Report No. 02-42
September 2002
Office of the Inspector General
We found that fee collection data in the INS's Financial Accounting and Control System and the Performance Analysis System did not agree for any of the eight air POEs in our sample. Furthermore, the data from both systems seldom agreed with the source documents, such as the applications processed. The lack of unique location codes in each system made it virtually impossible to reconcile the fee collection data found in the two systems. As a result, INS managers have no assurance of the accuracy or completeness of financial data and statistical data related to fee collections.
The Government Performance and Results Act of 1993 requires federal agencies to set goals, develop strategic plans, and measure the results of program performance based on whether the goals have been achieved. To determine how well the INS was meeting its goals, our audit included testing to see how the fee collection data reported in the INS's Financial Accounting and Control System compared with correlating fee?related statistics reported in the INS's Performance Analysis System.
Fee Collection Data in the Financial Accounting and Control System
Field offices must submit fee collection data and supporting documentation to the Debt Management Center (the Center) on a regular basis. In turn, personnel at the Center enter the fee information into the INS's Financial Accounting and Control System.
At the start of our audit, we requested fee collection data for the period October 1, 2000, through March 31, 2001, for all air POEs where fees were collected. The Center provided a list of only 14 locations with deposits totaling approximately $1.6 million for that 6-month period.
Analyzing the results, we found that the Center could not identify the amount of fees collected for every airport where the INS performs inspections and collects fees. In addition, the fee collection data that was available from the Financial Accounting and Control System was commingled between multiple locations in some instances. In our judgment, this occurred because not all air POEs had a unique location code in the system. For example, deposits for O'Hare International Airport in Chicago are combined with deposits from the INS District Office in Chicago using the same deposit code (CHI) in the Financial Accounting and Control System. Likewise, deposits for the Miami International Airport are combined with deposits from the Miami District Office using the same code (MIA).
Fee Collection Statistics in the Performance Analysis System
The Performance Analysis System is the INS's Service-wide system to summarize and report workload statistics. Beginning in October 2000, the Inspections Summary Report generated from the Performance Analysis System included workload statistics for the various INS applications processed.
Our fieldwork confirmed that the POEs we tested were manually inputting statistics into the Performance Analysis System on a monthly basis. However, the methods for tracking and compiling application and fee data differed among the eight air POEs we reviewed.
As with the Financial Accounting and Control System, not all air POEs had a unique location code in the Performance Analysis System. In that system, source statistics for an air POE can be distinguished from district office statistics by coding the Inspection Summary Report for port type "A" (for air). However, the Performance Analysis System could not provide statistics for individual air POEs if there was more than one airport reporting under the same location code.
Accuracy of Deposit and Statistical Data
To test the accuracy of the financial and statistical data related to fee collections, we obtained financial data from the records maintained at the air POEs because the Center could not provide the information. For comparative purposes, we requested and obtained from INS Headquarters the monthly Inspection Summary Reports for the eight air POEs in our sample for the period October 2000 through June 2001. In the Inspection Summary Report, workload data is reported in the form of the number of applications processed, by type of application. When multiplying the number of applications processed by the amount of the fee, a comparison can be made with the fee amounts deposited.
Next, we attempted to perform two separate reconciliations. First, we compared the fees deposited to the workload statistics reported in the Performance Analysis System, by month, for the period October 2000 through June 2001. Second, we selected one month from each of the three quarters and tried to compare both the financial and statistical data to the individual source documents, i.e., the applications.
Only six of the nine types of applications we encountered at the eight air POEs in our sample were reported on the Inspection Summary Report. Therefore, our comparison of statistical and financial data was limited to the following applications:
The results of our testing indicate that the fee collection data in the INS's statistical and financial systems need improvement. The following table reflects the results of our comparison between the financial data and the workload statistical data for the 9?month period of October 2000 through June 2001. The numbers shown are the number of months for the nine months tested where the data did not agree.
| Number of Months (Out of Nine) Where Data Did Not Agree | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| Source: OIG analysis of financial records maintained at the POEs and statistical data in PAS. N/A, not applicable, indicates that there were no forms processed at the POE. a Los Angeles did not report these statistics in PAS. |
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
As the table shows, overall, data for the 9-month audit period did not agree, and we could not conclusively determine the reasons for the differences at any of the air POEs tested. Generally, the difference per month, by type of application, was minimal (less than 15). However, when reviewed in the aggregate for the 9?month period, the following major discrepancies surfaced:
Furthermore, we found that staff at the Los Angeles air POE did not compile or report the statistics that we obtained for our testing from the Performance Analysis System. INS POE officials told us that nobody from INS Headquarters had ever questioned why they were not reporting.
Our comparison of financial and performance systems data to the applications processed provided further evidence that INS managers cannot rely on either the financial or statistical data related to fee collections. We could not perform the comparison at three of the airports-Detroit Metropolitan, JFK, and Los Angeles International-because they did not maintain any processed applications at those POEs. Thus, we believe it would be impossible for staff at those air POEs to determine the reasons for any discrepancies in the event that questions arose from either the Center about the fees collected or the INS Statistics Branch about the applications processed. The volume of applications processed, the manner in which they were filed, and the difficulty in determining whether a fee was paid at Pearson International Airport in Toronto prohibited us from completing the comparison at that POE.
At the remaining four air POEs in our sample-Hartsfield in Atlanta, O'Hare in Chicago, Miami International, and San Francisco International-we selected one month from each of the three quarters during the period October 2000 through June 2001 and compared the applications processed to the systems data. The following table shows the results, consolidated for the three months of our testing.
| Comparison of Applications to Systems Data | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| Source: OIG analysis of records maintained at the POEs and statistical data in PAS. N/A, not applicable, indicates that there were no forms processed at the POE. a Records were maintained at the San Francisco District Office. |
|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Our more detailed testing indicates that, with only a few exceptions, the source documents maintained at the POEs did not reconcile to either the statistical data or the fees deposit data. As a result, INS managers are not assured of the accuracy or completeness of either the financial data in the Financial Accounting and Control System or the statistical data in the Performance Analysis System. When source data does not reconcile, either errors were made or some transactions were not recorded, thereby increasing the vulnerability to loss or theft.
The Performance Analysis System captures separate statistics for the Visa Waiver (I-193) applications to reflect whether the fee was collected or waived. Our 3?month period for comparison of financial and statistical data to the applications processed included testing fee waivers at the four air POEs where the applications were available. We also found waivers of the fee for some Employment Authorization (I-765) applications at the Miami airport. Although the Performance Analysis System does not separately report fee waivers for that application, we also included that application in our testing at Miami.
Fee waivers for the Visa Waiver (I-193) applications ranged from approximately 5 percent to 16 percent. Fee waivers for the Employment Authorizations (I-765) applications were approximately 14 percent, based on the applications maintained at the POE. The following table shows the results in more detail.
| Fee Waivers | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| Source: OIG analysis of records maintained at the POEs and statistical data in PAS. N/A, not applicable, indicates that there were no forms processed at the POE. a The Performance Analysis System does not report waivers of Employment Authorizations (I-765s) separately. |
||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
The table above shows an example of how INS managers or other decision-makers could be misled, depending on the source of their information. For the three months we tested, the Performance Analysis System statistics showed that waivers of fees for the Visa Waiver (I?193) applications at the Miami and San Francisco airports were approximately 11 percent and 15 percent, respectively. However, when the applications are reviewed, those percentages drop to approximately 5 percent and 4 percent.
In our judgment, waivers of fees should be closely monitored and approved by supervisors to prevent abuse and to ensure that revenues lost due to fees being waived are minimal. We also believe that the INS should modify the Performance Analysis System to individually report, by application type, the waiver data for all fee-processed applications. Individually reporting applications processed and fee-waived applications would provide sufficient data to allow for monthly or quarterly reconciliations of workload statistics with the associated fees collected by each POE.
As evidenced by our various testing previously described, the deficiencies observed in the collection, validation, and limitations of the Performance Analysis System data are substantial. We found that:
Support of the Debt Management Center
The Debt Management Center is responsible for (1) ensuring the accuracy of the fee collection data entered into the Financial Accounting and Control System and (2) providing appropriate guidance to the POEs with regard to accurate reporting of fees collected. In our judgment, the Center cannot totally fulfill those duties until there is some method in place to compare the automated financial data to the data from other Service-wide automated systems. We believe the most logical system would be the Performance Analysis System. However, valid comparisons cannot be accomplished until both systems have the same unique location code for each field office, regardless of the size or type (e.g., air POE, land POE, district office, suboffice, or service center). Further, valid comparisons require consistent reporting in the Performance Analysis System of fees waived for all fee-processed applications.
In our judgment, if the INS is to achieve its goal to maintain timely and efficient administrative support of the Center, INS managers must first make improvements to the Financial Accounting and Control System and the Performance Analysis System and, thus, improve the quality of the data in those systems. Only then can the INS claim the Center is being adequately supported and the INS is working toward achieving Departmental goals so that it can fulfill its oversight responsibilities.
We recommend that the INS: