I appreciate the opportunity to comment on the subject draft report and solicited input from the senior management official who is most significantly impacted -- the Executive Associate Commissioner for Management. I reviewed the response and concur with the conclusions, observations, and recommendations.

The Executive Associate Commissioner for Management has given an explanation of the proposed plans to address your findings. Considering the INS reorganization and move to Homeland Security on March 1, I can not specifically give you projected completion dates for the specific recormmendations.

If you have any questions, please contact Kathleen Stanley, Audit Liaison, at (2O2) 514-8800.

Attachment

cc: Vickie L. Sloan, DOJ Audit Liaison

This memorandum responds to the U.S. Department of Justice's Inspector General Draft Report on reemployment of annuitants by the Immigration and Naturalization Service (INS) forwarded to the iNS on February 24,2003. The INS concurs with the recommendations in the report submitted by the 010 and will work to implement the recommendations wider the new Department oIHomeland Security. Below are our responses to the recommendations 1,2, and 4 addressed to the INS.

RECOMMENDATION 1: We recommend that the INS Commissioner ensure that the INS: Has procedures in place to identify the names, series, and compensation paid to rehired annuitants who receive waivers and ensure that this information reconciles with data provided to the NFC.

INS STATUS: Concur, we agree with the comments and recommendations that the INS develop specific procedures (i.e., development of a database), practices, and associated quality control measures that will allow easier identification of annuitants with waivers to dual compensation regulations by name, series, and compensation paid.

RECOMMENDATION 2: We recommend that the INS Commissioner: Ensure that rehired annuitant files include statements that the appointees would not accept the position without waivers being granted.

INS STATUS: Concur, we agree with the recommendations that INS improve its procedures and practices for maintaining records associated with the employment of annuitants. It is our position, however, that INS does maintain the official bard copy files, folders and spreadsheets necessary to generally fulfill Office of Personnel Management reporting requirements for the period 1996-2000. However, we recognize that the quality of these records may not meet the expectations of the Office of Inspector General.

RECOMMENDATION 4: We recommend that the INS Commissioner: In collaboration with JMD (or the successor component in the DHS), ensure that an acceptable long-range hiring and training strategy is implemented that establishes viable alternatives to the use of reemployed annuitauts using offset waivers.

INS STATUS: Concur, the INS's long-term strategy to address the instructor staffing shortage at the Academies is to dedicate a combination of additional FTE positions and 3-year term positions to increase the instructor capacity resources. In addition, the Office of Training and Career Development is exploring the use of contracted instructors to supplement the staffing shortage during the increased hiring demands for border patrol agents and immigration inspectors.

If you have any questions or require additional information, please contact Ms. Jill Drury, Acting Assistant for the Office of Training and Career Development, at 202-616-2674.