Immigration and Naturalization Service's Premium Processing Program

Report No. 03-14
February 2003
Office of the Inspector General

AUDIT OBJECTIVES, SCOPE, AND METHODOLOGY

Audit Objectives We conducted an audit of the INS’s Premium Processing program.  The audit objectives were to determine if:  (1) the INS was achieving the Premium Processing program goals for processing employment-based petitions and applications; (2) the processing times for similar routine petitions and applications had changed significantly since the implementation of the Premium Processing program; and (3) the implementation of the mandated IBIS check procedures impacted the Premium Processing service.  The original objectives of our audit were broadened to include IBIS checks because of the clear impact they are having on premium and routine adjudications.  We performed our audit in accordance with the Government Auditing Standards issued by the Comptroller General of the United States and, accordingly, included such tests of the records and procedures that we considered necessary. Scope The scope of the audit encompassed the Premium Processing program for the period June 2001 through October 2002.  Our primary focus was on the Premium Processing activities at the INS Headquarters in Washington D.C., and at the four service centers:  St. Albans, Vermont; Dallas, Texas; Laguna Niguel, California; and Lincoln, Nebraska.  We conducted fieldwork at these five locations from February 2002 through July 2002. As part of our audit process, we routinely ask management of the organization audited to furnish us with a signed management representation letter.  In this letter, INS management would certify to us that:  (1) they provided us with all standards, internal reports, memoranda, and other documentation associated with the Premium Processing program; and (2) there are no relevant management and internal control matters, compliance matters, contingencies, irregularities, or subsequent events of which our staff has not been aware.  As of the date of issuance of this report, the INS Executive Associate Commissioner for Management declined to sign the letter.  Therefore, our findings are qualified to the extent that we may not have been provided with all relevant information by INS management. Methodology We conducted 87 interviews with 82 management and staff personnel from the INS (including the Information Services Division, Budget Office, Financial Management Division, Office of Policy and Planning, and the Office of the General Counsel).  We also interviewed personnel from the contracted Service Center Operations Teams (SCOT), and PricewaterhouseCoopers.  Additionally, we analyzed 154 documents including legislative information, budget material, organizational charts, staffing plans, statistical data, survey samples, and contract data. Our audit work included identifying laws and regulations relevant to Premium Processing; obtaining an understanding of the INS’s Premium Processing procedures for employment-based petitions and applications; determining the INS’s performance in providing premium service; and assessing the implementation and impact of the INS’s mandated IBIS check procedures. To determine whether the INS was achieving its Premium Processing program goals, we worked with the INS’s Headquarters management and staff to obtain general program information, including total receipts data for each Form I-129 classification eligible for Premium Processing, along with refund information.  The receipts data were arranged by service centers and included servicewide totals.  Refund information was tracked under five categories, which enabled us to determine the most common causes for refunding the premium fee.  We also evaluated the INS’s plans to expand Premium Processing to include the Form I-140, Petition for Alien Worker.  Related work included reviewing the budgeting and staffing allocations for the Premium Processing program. In verifying whether the Premium Processing service has impacted processing times for similar routine petitions, we visited each service center to interview management and staff.  We documented the Premium Processing operations and procedures, reviewed service center staffing allocations for the premium service and compared the allocations to the actual number of staff working on Premium Processing petitions, and obtained available data regarding the average processing times for premium and routine cases.  The service centers’ management preparations for the anticipated increases in premium service applications, once the program is expanded to include the Form I-140 applicants, were also discussed.  Lastly, we documented the differences in the program management and processing procedures among the service centers, and compared contractor services, such as data processing and mailroom operations. During our audit, the INS implemented mandatory IBIS check procedures for all benefit petitions and applications, including Premium Processing.  Because of the impact the new IBIS check requirement was having on the service centers’ operations, for both the premium and routine processing, we documented this process.  We evaluated the changes in premium and routine receipt totals, additional processing times, and the service centers’ procedures for conducting IBIS checks.  In addition, we reviewed the INS’s policy regarding the use of IBIS checks in granting immigration benefits.