IMMIGRATION AND NATURALIZATION SERVICE
PASSENGER ACCELERATED SERVICE SYSTEM PILOT PROGRAM

Audit Report 95-8, (3/95)

Prepared by Office of the Inspector General, Audit Division

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EXECUTIVE DIGEST

The Office of the Inspector General, Audit Division, has completed an audit of the Immigration and Naturalization Services Passenger Accelerated Service System (INSPASS) pilot program. This pilot program was established by the Immigration and Naturalization Service (INS) in order to assess the feasibility of automating the immigration inspection process and used, as its first test group, low risk frequent business travelers. Our review focused on the overall system concept and implementation of the pilot program.

INSPASS currently operates as a pilot project in three international airports: John F. Kennedy International in New York; Newark International in New Jersey and Lester B. Pearson International in Toronto, Canada. There are approximately 27,000 travelers enrolled at these pilot sites. From fiscal year 1992 through fiscal year 1994, INS estimates INSPASS expenditures of about $3 million for hardware, software, systems development, installation, and technical support.

Our audit disclosed that:

•INSPASS, in concept, has the potential to be a cost effective means of reducing processing time for frequent travelers by automating the primary inspection process without sacrificing security. If properly implemented, INSPASS can assist INS in achieving its portion of the Congressional mandate to provide required Federal inspection services to passengers upon arrival in the U.S. on scheduled airline flights within 45 minutes of their presentation for inspection.

•INS has not currently met all elements necessary for successful INSPASS implementation. Before INSPASS can be considered for nationwide expansion, INS needs to address and correct several weaknesses. These include: (1) improving the INSPASS kiosk design, (2) processing automated inspections within 30 seconds, (3) ensuring accurate data entry of participant's enrollment data, (4) increasing enrollment through promotion, (5) selecting a reliable and secure biometric identifier, (6) selecting an appropriate identity card, and (7) dedicating adequately trained and committed INS staff.

TABLE OF CONTENTS

INTRODUCTION

The Inspection Process

FINDINGS AND RECOMMENDATIONS

1. THE SYSTEM CONCEPT

Cost Effectiveness

Potential Time Savings For INSPASS and Non-INSPASS Users

Technology

System Security

Feedback From System Users

Replication of INSPASS Technology

Recommendation

INSPASS IMPLEMENTATION

The Kiosk Design Needs To Be Improved

INSPASS' 30 Second Processing Requirement

INSPASS Enrollment Database Accuracy

Recruiting INSPASS Users Through Promotion

Selecting a Reliable and Secure Biometric Identifier

Alternative Data Cards

INSPASS Staffing

Recommendations

OTHER MATTERS

BEST PRACTICES

STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS

STATEMENT ON INTERNAL CONTROL STRUCTURE

APPENDIX I - USER SURVEY QUESTIONNAIRE AND SUMMARY OF

RESULTS

APPENDIX II - IMMIGRATION AND NATURALIZATION SERVICE'S

RESPONSE TO DRAFT REPORT

APPENDIX III - AUDIT DIVISION ANALYSIS AND SUMMARY OF

ACTIONS NECESSARY TO CLOSE REPORT 44IMMIGRATION AND NATURALIZATION SERVICE

PASSENGER ACCELERATED SERVICE SYSTEM PILOT PROGRAM

INTRODUCTION

The Office of the Inspector General, Audit Division, has completed an audit of the Immigration and Naturalization Services Passenger Accelerated Service System (INSPASS) pilot program. This pilot program was established by the Immigration and Naturalization Service (INS) in order to assess the feasibility of automating the immigration inspection process and used, as its first test group, low risk frequent business travelers. Our review focused on the overall system concept and implementation of the pilot program.

OBJECTIVES

The objectives of the audit were to: (1) determine if INS should implement INSPASS on a national basis, (2) determine the progress and status of the pilot program by evaluating the results of system testing at the three test sights, and (3) identify alternative technologies and methodologies which should be considered for testing prior to implementation of the system.

SCOPE AND METHODOLOGY

The audit was performed in accordance with generally accepted government auditing standards and, accordingly, included such tests and procedures as were considered necessary to accomplish our objectives.

The scope of our audit was the pilot program at the three test sites. The program was implemented at these sites as described below.

•Newark International Airport in Newark, New Jersey on May 24, 1993.

•John F. Kennedy (JFK) International Airport in Jamaica, New York as follows:

- International Arrivals Building (IAB) on June 1, 1993;

- British Airways/United Airlines Terminal on August 10, 1993; and

- American, Delta and TWA Terminals on September 7, 1993.

•Lester B. Pearson International Airport in Toronto, Canada on December 3, 1993.

During our audit, work was performed at INS Headquarters and the three pilot sites. To accomplish our objectives, we:

•interviewed responsible headquarters personnel to determine how the program was initiated and planned;

•researched the technology to assess the feasibility of using a biometric identifier as part of an automated inspection process;

•interviewed contractor personnel to obtain an overview of the architecture used for the system;

•reviewed documents provided by INS personnel at headquarters and at pilot program sites related to pilot program planning, administrative and operational procedures established, pilot program accomplishments, and system problems;

•interviewed port of entry personnel to determine how the program was implemented at each test site;

•observed the INSPASS enrollment and inspection process at the three test sites;

• verified that information from sampled enrollment records was accurately entered into the enrollment database and that only eligible travelers were enrolled in the system;

•verified from sampled recent admissions that only eligible and admissible travelers were admitted to the U.S. through the system; and

•conducted a user satisfaction survey of travelers enrolled in INSPASS.

To conduct the user survey, we selected 670 system users from the universe of 9,387 cardholders who had used INSPASS at least one time, through April of 1994. We selected 345 who had used the system seven or more times and an additional 325 based on a random sample of all users. We sent questionnaires to 670 INSPASS users and received responses from 399 (59.6 percent). A complete survey questionnaire with results can be found in Appendix I of this report. Selected user comments are also contained throughout the report.

Because the universe of system users was not static during the audit period, we used a judgmental rather than a statistical sample. Therefore we could not project the specific results of the survey to the universe of INSPASS users as a whole. The primary purpose forconducting the survey was to obtain feedback from INSPASS users on the strengths and weaknesses of the system.

BACKGROUND

INSPASS was developed as an alternative to meet the requirements established in 8 U.S.C. Section 1356, as modified by Public Law 101-515, which mandates immigration services be provided to passengers upon arrival in the U.S. on scheduled airline flights within 45 minutes of their presentation for inspection. This mandate requires all Federal agencies involved to process each plane load of arriving passengers through all required inspections within this 45 minute timeframe. The INSPASS pilot program was designed to permit travelers to enter the U.S. without being inspected by an immigration inspector. By using a test population of low risk frequent business travelers who bypass the manual primary inspection process, INS hoped to reduce processing time and processing backlogs for all travelers.

The Inspection Process

The objective of all immigration inspections is to determine the admissibility of the traveler seeking entry into the U.S. For the routine manual primary inspection, the traveler seeking entry into the U.S. must be inspected by an immigration inspector. The immigration inspector determines the admissibility of the traveler seeking entry by examining the traveler's documents, observing the traveler's demeanor, asking questions regarding the purpose for seeking entry, and querying several enforcement databases to determine if the traveler is subject to any legal action which would effect admissibility. If the inspector determines that the traveler is not suspect, the traveler is then admitted to the U.S.

Enrollment in INSPASS requires one face to face inspection for the system user at the time of enrollment. During the enrollment process, the potential system user is examined by an immigration inspector to determine if the user is admissible to the United States and to determine if the potential user is eligible to enroll in INSPASS. Subsequent inspections are conducted using the INSPASS card at the INSPASS kiosk. Once enrolled, the system user must be re-examined by an immigration inspector at least once per year. The INSPASS kiosk is similar in appearance to a bank automated teller machine. A Photograph of the INSPASS kiosk is not included.

To use the INSPASS kiosk:

•the traveler inserts his or her card into the card reader,

•the system reads the user's INSPASS card obtaining the user's identification data,

•the system activates the hand geometry (or fingerprint in Toronto) reader and the user is instructed to place their hand on the reader,

•the system calculates user's hand geometry or fingerprint biometric and compares it to either the hand geometry code on the INSPASS card or the fingerprint contained in a user database,

•the system then queries enforcement databases to determine if any of these sources contain information which would effect the admissibility of the user,

•the system prompts the user to enter their airline and flight number,

•the system prints either a receipt for U.S. citizens and foreign nationals with certain visa classifications or an I-94 (Arrivals and Departure Record) for other foreign nationals, and

•the INSPASS kiosk gate opens automatically and allows the traveler to proceed to U.S. Customs with the receipt or I-94 documenting that the traveler has cleared immigration and can enter the U.S.

Pilot Program

The INSPASS pilot program was jointly developed by INS' Office of Inspections and the Office of Information Resource Management. During our audit, INS had assigned one chief inspector and two assistant chief inspectors from the Office of Inspections and one senior systems analyst from the Office of Information Resource Management to develop and manage the pilot program.

Key tasks for implementing the pilot program were to: (1) identify the universe of potential users, (2) select the test sites, (3) select a biometric identifier for testing, (4) select a data card which would contain the user's personal data and biometric identifier, (5) establish a timeframe for conducting the pilot program, and (6) develop a test system which included work stations to enroll users, monitor the inspections process, and accomplish the automated immigration inspection. For the automated INSPASS inspection, the major difference is that once enrolled, a traveler can bypass the manual primary inspection to enter the U.S.

The pilot program team decided to limit the program testing to frequent business travelers who enter the U.S. three or more times per year and who are citizens of the U. S., Canada, Bermuda or those countries that are included in the Visa Waiver Pilot Program. [ Andorra, Austria, Belgium, Brunei, Denmark, Finland, France, Germany, Iceland, Italy, Japan, Liechtenstein, Luxembourg, Monaco, Netherlands, New Zealand, Norway, San Marino, Spain, Sweden, Switzerland, United Kingdom.] INS selected this universe because they considered these travelers to be a low security risk to the U.S. The team established a target of 50,000 enrolles for the pilot program from an estimated 3.5 million [ "Abstract of International Travel To and From the U.S." Office of Research, U.S. Travel and Tourism Administration, U.S. Department of Commerce.] frequent business travelers.

The pilot program team determined that the first two test sites should consist of one large and one small international airport. The pilot program team selected the Newark International Airport as the small site and the JFK International Airport as the large site. However, the pilot program was expanded to the Lester B. Pearson International Airport (Toronto, Canada) because enrollment at the first two sites was not sufficient to provide adequate test data for evaluation. The Toronto site was chosen due to the large number of qualifying business travelers traveling to the U.S. from this airport. INS and U.S. Customs, in Toronto, complete their inspections for U.S. bound travelers prior to the aircraft's departure to the U.S. Thus, the need for inspection upon arrival in the U.S. is eliminated.

Funding

The funding for INSPASS was taken out of the INS budget for the Interagency Border Inspection System, which is made up of appropriated funds and user fees. Through the end of FY 1994, INS estimates it will have spent approximately $3 million on INSPASS. For FY 1992 and FY 1993, INS reported expenditures of $970,000 on software and $1,050,000 for hardware. Projected spending for FY 1994 is $661,000 for development and technical support, $211,000 for hardware and software, and $124,000 for systems installation for total projected FY 1994 spending of $996,000.

FINDINGS AND RECOMMENDATIONS

1. THE SYSTEM CONCEPT

INSPASS, in concept, has the potential to be a cost effective means of using existing technology to reduce processing time for travelers by automating the primary inspection process without sacrificing security. If properly implemented, INSPASS can assist INS in achieving the Congressional mandate to provide required Federal inspection services to passengers upon arrival in the U.S. on scheduled airline flights within 45 minutes of their presentation for inspection. INSPASS user comments we received indicated enthusiasm for the concept as well as hope that the system can be perfected and expanded. Our observations, interviews, and testing of the system confirm that the concept is viable if it is implemented properly.

8 U.S.C. Section 1356, as modified by Public Law 101-515, states, "The immigration services required to be provided to passengers upon arrival in the United States on scheduled airline flights shall be adequately provided, within forty-five minutes of their presentation for inspection, when needed and at no cost (other than the fees imposed under subsection (d)) to airlines and airline passengers at:

(1) immigration serviced airports and

(2) places located outside of the United States at which an immigration officer is stationed for the purpose of providing such immigration services."

The 45 minute time limitation applies to all Federal inspections including inspections by INS, U.S. Customs, and the U.S. Department of Agriculture (USDA). This is evidenced by House of Representatives Report 102-106, dated June 11, 1991, which states: "The committee notes that the 45 minute standard is meant to include inspection by all federal Agencies and not just INS. The Committee expects the INS to work with the Customs Service and other Federal agencies in achieving the standard."

All incoming travelers are required to undergo some form of immigration inspection. Customs and agricultural inspections are performed only on a random basis; therefore, many travelers are permitted to bypass these inspections. In order for us to assess whether INSPASS is a viable option for facilitating the inspection process for low risk, frequent business travelers to the U.S. we: (1) reviewed INSPASS cost data included in the INSPASS feasibility study, (2) assessed whether potential time savings over manual inspections were achievable, (3) assessed whether technology was available to support automation of the inspection process, (4) evaluated the impact of automating the inspection process on security, and (5) obtained and evaluated feedback from system users.

Cost Effectiveness

Our audit disclosed that automation of the inspection process, through INSPASS, can be a cost effective alternative to the primary manual inspection. The system, in concept, is designed to allow one immigration inspector to monitor multiple inspection stations thus permitting INS to reduce backlogs without hiring more immigration inspectors. Based on the INSPASS Feasibility Report, the incremental cost for the average INS inspector is approximately $50,000 per year which includes salary, fringe benefits, and related overhead. The initial cost of an INSPASS kiosk is a one time cost of approximately $45,000 based on the current configuration for the pilot program. Additional costs would include the cost of maintaining the system software and hardware.

The Office of Management and Budget Circular No. A-25 states, "When a service (or privilege) provides special benefits to an identifiable recipient beyond those that accrue to the general public, a charge will be imposed (to recover the full cost to the Federal Government for providing the special benefit, or the market price). Based on this criteria, we believe that any additional cost can be recovered by INS applying a user fee to help finance the costs of implementing and operating INSPASS. Additionally, some of the system costs may be picked up by the airlines or the host airports. For instance, as a courtesy to their Concorde passengers, British Airways financed the cost of the British Airways terminal kiosk at JFK International Airport.

Potential Time Savings For INSPASS and Non-INSPASS Users

For INSPASS and non-INSPASS users, processing time can be reduced through automation of the primary inspections. INSPASS has the potential to reduce processing backlogs if the INSPASS inspection can be made to take significantly less time than the manual primary inspection and if sufficient INSPASS kiosks are available to system users. Time savings for non-INSPASS users is accomplished by taking the INSPASS users out of the manual inspection lines, thereby, reducing the waiting times for all travelers.

INS has established a goal of 30 seconds to complete an INSPASS inspection. However, based on INS staff and our observations from the three pilot program test sites, INSPASS inspections currently take 1 or more minutes to complete. According to a 1992 study conducted by American Airlines Decision Technologies (AADT), the manual primary inspection takes an average of 58 seconds from the time that the inspector calls the traveler into the inspection booth to start the inspection process until the time that the inspector admits the traveler into the U.S. and clears the traveler to proceed to U.S. Customs. [ The benefits derived from reducing backlogs for INSPASS and manual primary inspection may be limited by factors outside the control of INS. AADT's study of processing time at JFK and Miami International Airports concluded that some of the time saved by streamlining the immigration inspection process may be lost while passengers wait for baggage. Consequently, time sav ings may vary among travelers.] The AADT study was prepared for our audit of INS' Pre-inspection of U.S. Bound Travelers Program, Report Number 93-16, dated September 1993.

Although the current version of INSPASS has not met INS' 30 second goal, we believe the 30 second inspection is attainable through improvements to system hardware, software, communications, and through enhanced user training. These are discussed in more detail in Finding 2.

If INS can attain the 30 second goal for INSPASS inspections, they will reduce the time of the actual INS inspection by nearly 50 percent. If sufficient INSPASS kiosks were installed, the combination of an accelerated inspection process and the addition of inspection stations would reduce processing backlogs for immigration inspections. Non-INSPASS users would benefit from the reduction in the number of travelers requiring the manual primary inspection. Such a reduction could alleviate some of the backlogs which occur during peak periods.

The impact of nationwide implementation of INSPASS on reducing processing backlogs for manual primary inspections at busy U.S. airports will depend upon the degree to which the system can be expanded. In order to materially reduce overall processing backlogs, INS must increase the percentage of INSPASS inspections by: expanding the universe of eligible users, enrolling significant numbers of potential users, and providing travelers with an automated inspection process that is significantly faster than the manual primary inspection.

Technology

Our audit disclosed that INS is testing both the hand geometry and the fingerprint biometric identifiers within the pilot program. We found that these technologies allow for automation of the inspection process. We found both the hand geometry and fingerprint biometric identifiers can be used to verify the identity of travelers for immigration inspectionpurposes. Currently, hand geometry is being used by the Colombian government to verify the identity of Colombian Senators and Representatives for vote casting purposes. Hand geometry has also been used to verify the identity of students who are enrolled in the University of Georgia's food plan at the campus cafeteria. The fingerprint biometric identifier has been successfully used by Los Angeles County in California to reduce fraud and verify the identity of welfare recipients.

We also found that "smart cards" are currently available which can store historical and biographical information which can be used to enhance the automated inspection process (This is further discussed in Finding 2). INS currently uses a machine readable card, which requires reissuance to be updated. The smart card has the ability to be read and written to and can be updated without reissuing the card.

In our judgment, INS can use either of these technologies to develop an operational system that can perform the immigration inspection within INS' 30 second goal. However, INS must assure that the biometric identifier selected for the system is reliable and secure.

System Security

Our audit disclosed that INSPASS has the potential to provide reasonable assurance that travelers who may not be admissible will be identified by the system. We base our conclusion on: (1) the comprehensive enrollment inspection, (2) automated queries of law enforcement databases during each INSPASS inspection, and (3) random, manual checks of travel documents to deter misuse of the system.

The INSPASS enrollment process is designed to be a more comprehensive examination of the applicant than is possible during a manual primary inspection. Our audit disclosed that the INSPASS enrollment process takes between 10 and 15 minutes. During the enrollment process, an immigration inspector reviews the application and interviews the applicant for enrollment or re-enrollment. The inspector then queries law enforcement databases through the Interagency Border Inspection System gateway [ The Interagency Border Inspection System gateway is accessed through the port of entry's inspections local area network. This gateway allows INSPASS to interact with the : (1) Consular Lookout and Support System, (2) Naturalization Automated Immigration Lookout System, (3) National Crime Information Center, (4) Non-Immigrant Information System (NIIS), and (5) Treasury Enforcement Communications System. These sources are queried electronically to determine if the applicant is eligib le for INSPASS and admissible to the U.S.] to determine admissibility and eligibility.

In addition to queries during the enrollment process, INSPASS automatically queries the law enforcement databases each time it is used. If there is prejudicial information on any of these sources, INSPASS alerts an immigration inspector of the

problem and denies the traveler admission into the U.S. The traveler is then referred to an immigration inspector for processing.

As an additional test of system security, INS has begun random, manual checks of travel documents to deter misuse of the system. During our audit, we observed that the INSPASS team in Toronto routinely selected six INSPASS admissions per day for random, manual testing. These tests consisted of performing a manual primary inspection of the traveler to include a review of documents (passport, visa, resident alien card, etc.) and a brief interview. The compliance tests were performed on a random basis and were intended to serve as an additional deterrent to misuse of the system. INS informed us that these compliance checks are now routinely performed at all test sites. Subsequent to our field work, the software was updated to randomly select users for testing according to INS.

In order to test whether the INSPASS security features were effective, we selected a judgmental sample of 105 INSPASS inspections. Our objective was to determine if these sources contained prejudicial information which would effect the admissibility of the travelers tested. Our test consisted of manually querying the law enforcement databases through the Interagency Border Inspection System gateway to verify INSPASS admissions. Our test did not disclose any information that would have affected the admissibility of the travelers tested.

Feedback From System Users

Our user survey disclosed that current system users are enthusiastic about INSPASS and want to see the system perfected and expanded. From the results of the user survey, we concluded that users felt that INSPASS saved them time because they could bypass long primary inspection lines during peak periods. This is reflected by the following survey results and actual user comments.

•"On several occasions, I was able to catch my flight because I did not have to wait in the line-ups to be processed."

•"I think it is an excellent idea and one that has definitely speeded up the process."

•"This is a good program and I have told other frequent business flyers to join it. This program should be expanded and more machines installed."

•"Excellent System -- Expansion to other airports and terminals would be great."

•"This has got to be the best program ever designed by the U.S. Government (except say the Marshall Plan)! The application procedure prescreens the INSPASS user to meet INS requirements, yet still allows the business traveler rapid processing. The older lineup system invariably had regular business travelers waiting in line behind visitors with language difficulties and or with suspicion arousing stamps in their passports. The INSPASS' greatest benefits is the separation of the business traveler from these other difficult cases."

•"I believe the system offers a cost savings and time saving for both the traveler and the INS."

•"Use even for trips as a tourist."

•"Need INSPASS at LAX Los Angeles, and all major city airports, INSPASS is a great time saver."

•"Please extend to other airports as soon as you can."

•"INSPASS has made my travel very easy. Thank You!"

Replication of INSPASS Technology

In addition to the INSPASS pilot program at the three test sites, INS is planning to test an automated inspection process based on hand geometry at Hidalgo, Texas. INS will test the system using frequent border crossers as a test universe. If the test is successful, INS plans to implement an automated inspection system at high traffic northern and southern land border crossings.

Conclusion

We found that INSPASS has the potential to: (1) reduce inspection time in a cost effective manner; (2) reduce long lines during peak periods; (3) allow automation of the inspection process through technology; and (4) provide a level of reliability and security comparable to that provided by the manual primary inspection process. However, before INSPASS can be implemented nationally, INS must address the system deficiencies discussed in finding 2 of this audit report.

We also believe that INS should formally solicit INSPASS user feedback during the pilot process to achieve greater customer satisfaction. In our judgment, users of the system provide the best feedback on what is good about the system and what needs to be improved because users have a vested interest in making the system work. Such a mechanism could be implemented in the form of a user satisfaction questionnaire, periodic user interviews or having a group of users volunteer to meet with INS inspectors to discuss suggestions for improving the system.

Recommendation:

We recommend the Commissioner, INS:

1.establish a formal mechanism for obtaining user feedback.

2. INSPASS IMPLEMENTATION

INS has not currently met all elements necessary for successful INSPASS implementation. Before INSPASS can be considered for nationwide expansion, INS needs to address and correct several weaknesses. These include: (1) improving the INSPASS kiosk design, (2) processing automated inspections within 30 seconds, (3) ensuring accurate data entry of participants' enrollment data, (4) increasing enrollment through promotion, (5) selecting a reliable and secure biometric identifier, (6) selecting an appropriate identity card, and (7) dedicating adequately trained and committed INS staff.

The INSPASS Feasibility Report dated October 30, 1992 contains the following objectives:

•Improve the immigration inspection time for all international air travelers without compromising security.

•Provide the capability to handle an increased number of travelers despite facility constraints or heavy peak periods.

•Enhance public satisfaction with the inspection activity.

•Establish and confirm the identity of the enrolled international air traveler.

•Provide assurance that the enrolled international traveler is admissible.

•Ensure the consistency between the INSPASS traveler, their travel documents, and the retrieved information from databases.

•Allow INSPASS travelers to be processed in such a manner that an individual inspector can monitor multiple lanes at the same time.

•Produce a system that is easy to use by both the INSPASS traveler and the Immigration and Naturalization Service personnel involved in the enrollment, oversight, and operation of the system.

•Process each individual INSPASS air traveler through INS primary inspections within 30 seconds. (The individual immigration processing time will be measured from the time the person crosses the line in front of theinspection station until they are released.)

•Provide a receipt of inspection, which will also serve as a departure record to satisfy departure manifest requirements (when required).

•Provide a link between the INSPASS system and the Non-Immigrant Information System database.

•Process a plane load of passengers through the Immigration area within the Congressionally mandated time.

In order to test INSPASS implementation, we compared the criteria contained in INS' feasibility study and measured it against current system performance. Our audit determined that INS has met their objectives relating to: (1) establishing the identification of the air traveler, (2) providing assurance that the enrolled traveler is admissible, (3) providing a receipt of inspection which will also serve as a departure record to satisfy manifest requirements, and (4) providing a link between INSPASS and the Non-Immigrant Information System database. However, we identified several weaknesses which have prevented INS from meeting the other objectives described in their feasibility study. INS needs to correct these weaknesses prior to implementing INSPASS on a nationwide basis. These areas are discussed below.

The Kiosk Design Needs To Be Improved

Our audit disclosed that the INSPASS kiosk design can be improved. Specifically:

•The system monitor and the hand geometry reader are not logically arranged. The system monitor which provides the user with interactive prompts is placed to the extreme left of the kiosk. The hand geometry reader, which contains indicator lights for proper hand placement and a small display screen which tells the user when to remove their hand from the reader, are at the extreme right. During the hand geometry reading, many users do not hold their hand in the proper position because they are trying to follow the prompts on the system monitor.

•All system prompts should be displayed on the system monitor. Currently, hand geometry readings are provided on a separate display located above the hand geometry reader rather than on the system monitor. This situation is confusing to the inexperienced user who logically would expect all prompts to be displayed on the system monitor. We found that these design deficiencies sometimes result in user errors which cause the system to ultimately reject the traveler and refer them to the manual primary inspection line.

•Alternative interactive interfaces such as a multi-lingual interface, touch-screens, and voice prompts have not been tested. Such interfaces can minimize user error and thus speed up the INSPASS inspection process. Currently, INSPASS prompts only in English, while the program is available to qualifying foreign travelers. Further, touch-screens similar to those currently used for automated teller machines, have not been tested within the pilot program. Although INS purchased touch screen equipment for testing in May of 1994, the equipment has not been installed. Use of alternative interfaces would support the objective to produce a system that is easy to use.

•A more effective warning system needs to be developed to assist immigration inspectors monitoring the INSPASS kiosk. Currently, the primary device for monitoring kiosk activity is the system printer. However, we found that the system printer was not always on-line. This printer is the only means for alerting INS inspectors that a user is either having a problem with the inspection or has been rejected by the system. We believe that a warning system based on an audible or visual alarm, in a manned inspection station, would be more reliable and less prone to malfunction. This will become essential when the system is expanded and where one immigration inspector is assigned to monitor multiple INSPASS kiosks. The system printer can be an effective back up device for recording system problems and can be used as the primary source for documenting system problems through an error printout; however, it should not be the primary warning system.

Our analysis of user comments obtained through our survey as well as our observations at the three test sites confirm that some enhancement to the current INSPASS kiosk is necessary. Select user comments included:

•"Instructions how to use the machine are not clear. They should be more simple and understandable to any card holder."

•"Use of 'touch screen' would be a great advantage to this program."

•"It is difficult to correctly position hand on the plate."

•"Center the key pad -- difficult for right handers."

•"I have tried to use this system at least 6 times and it never works. The system at JFK - Delta, and American - do not operate properly. I now avoid the machine and go through the normal procedure. A great idea. Terrible execution. I suggest you first fix the system before you consider charging a fee. I suggest you audit the operation of the system to determine how it can beimproved."

•"The INSPASS computer application is basically a text based application which runs under a Windows environment. But, it does not use many of the Windows graphics features. I suggest the DOJ/INS hire a user interface design expert/consultant for a few days to optimize the interface. This does not indicate dissatisfaction just suggestions for improvement."

•"Confusing to get directions from two screens - keep all instructions on main screen, not hand reader screen."

•"Tilt the keyboard and screen or put them higher. The machine seems to be made for people that are only 4 feet tall!"

•"Info screen should be moved up closer to eye level."

•"Machine could be made easier by using voice recognition."

•"I have seen many people maintaining their hand identification throughout the entire process. 'Remove your hand' sign can maybe appear on the main screen. System also doesn't say clearly to press the keys, enter, or down, or other. Menus should include more explanation . . ."

•"Many times I have to put the card through 3 times before it's accepted and have to place my hand 2-3 times to get an OK."

Such system weaknesses tend to frustrate and discourage travelers from using the system, particularly new users. They also negate the time saving aspects of the INSPASS inspection. In our judgment, although some of the weaknesses can be

attributed to a lack of training, INS should make improvements to INSPASS before nationwide implementation rather than requiring users to adjust to the current system.

INSPASS' 30 Second Processing Requirement

We found that the INSPASS inspection currently takes at least as long as the manual primary inspection. Our audit disclosed current INSPASS inspections (from the time the traveler crosses the line in front of the inspection station until the time that the traveler is released by the immigration inspector) were taking at least 60 seconds while manual inspections average about the same (see Finding 1). Currently, the only major benefit to the user is that they do not have to stand in line for a manual primary inspection and do not have to be interviewed by an immigration inspector each time INSPASS is used.

The volume of comments from our user survey indicated that the slow processing time for the INSPASS inspection was a significant weakness. Select user comments are as follows:

•"INSPASS takes too long - if there is no lineup - it is faster to use manual system."

•"If there was no line-up at the agent it would have been faster to go to him/her."

•"It takes the same time as manual inspection -- just depends which line is shorter."

•"The system is too slow for heavy usage."

•"INSPASS is fine when there is a long line waiting to speak with the immigration office, it saves time in these circumstances."

•"On numerous occasions the printing of the receipt (and sometimes the computer access time) is slow enough that it would have been faster to go through the manual process."

•"Savings is a result of fewer people in the INSPASS line than Manual line."

In addition to other factors discussed in the report, we identified two major reasons for the system's slow performance. First, the system does not have its own dedicated local area network; therefore, the system must be integrated into the existing inspections network, which slows INSPASS processing. Second, the dot matrix printer used to print the INSPASS receipt or I-94 is too slow.

The port of entry's immigration inspection local area network is used to perform all the data processing functions required for all inspections. The main function is to query the enforcement databases through the Interagency Border Inspection System gateway. Since INSPASS is integrated into the immigration inspection's local area network, INSPASS queries through the Interagency Border Inspection System gateway compete with the large volume of queries made for all other inspections.

We found that integration of INSPASS with the immigration inspection network results in delays when the queries are made. We believe that INS can solve this problem by either upgrading the current network or by providing INSPASS with a dedicated local area network. We also found that the slow processing time of the dot matrix printer increases the time it takes to complete an INSPASS inspection. As a result of the slow time for INSPASSinspections, the system has not yet met INS' objective to process each individual INSPASS air traveler through INS primary inspections within 30 seconds.

INSPASS Enrollment Database Accuracy

Our audit disclosed that procedures for assuring the accuracy of information entered into the INSPASS enrollment database were not sufficient. We selected a sample of 150 enrollment applications to test the accuracy of the INSPASS enrollment database and compared the information on the application with the user's record stored within the INSPASS system. We found that 75 of the 150 applications had significant discrepancies including: incorrect sex, incorrect or incomplete address, incorrect country or state of residence, incorrect date of birth, incorrect passport number, incorrect or missing passport expiration date, incorrect or missing VISA issue date, and misspelled last name.

These discrepancies occurred because: (1) immigration inspectors did not always adequately review their work while they were inputting the data, (2) supervisors did not adequately review data periodically as a quality control procedure, and (3) the system lacked automated edit checks, where possible, which could prevent some input errors. In our judgment, the system would be strengthened by performing verification of the information entered into the database against the user's application, with the emphasis upon the immigration inspector's visual comparison of data as it is entered. Therefore, weaknesses identified in our audit indicate that INS has not met its criteria to ensure the consistency between the INSPASS traveler, their travel documents, and the retrieved information from databases.

Recruiting INSPASS Users Through Promotion

In order to adequately test INSPASS before proceeding with national implementation, INS established a goal of 50,000 users for the pilot program. During our audit, we determined that INS has recruited only about 27,000 INSPASS users from May 1993 through June 1994. [ As described earlier, only 9,387 cardholders had used INSPASS at least one time through May 1994. ] According to INS, INSPASS kiosks have been used 35,248 times in this time period. A recent Department of Commerce study, which was published in 1994, indicates that potential frequent business travellers to the U.S. number about 3.5 million annually. A breakdown of enrollment for the three test sites appears in the following table:

INSPASS ENROLLMENT, INCEPTION THROUGH JUNE 1994

Our audit also determined that usage of INSPASS at the three pilot sites has been extremely low. Enrollment and average participation to date reflects the limited nature of pilot program testing. The current average daily use at the three test sites, is only about 200 times per day out of an average of 34,725 daily manual inspections for the three sites. The following graphs show enrollment levels during May and June of 1994 and the average daily kiosk activity for this period.

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The recent trend for both enrollment and usage is positive. [ Enrollment for the month of June 1994, indicated increases of 206, 1868, and 426 new enrolles for Newark, JFK, and Toronto respectively. Usage for the month of June 1994, was 5455 for the three test sites.] However, in order for INSPASS to have a significant effect on reducing congestion for both INSPASS and non-INSPASS travelers, it must be used by a much higher percentage of frequent business travelers. INSPASS usage at the three test sites appears in the following table.

INSPASS USAGE, INCEPTION THROUGH JUNE 1994

As detailed in the preceding tables, the Toronto test site has proven to be very effective in enrolling users and in getting them to use INSPASS. Toronto is the newest test site yet it has averaged 23 new enrolles per day and 71 actual uses per day. Further, INSPASS is operational at only one of the three busy terminals at Toronto. JFK in New York has about 15,000 more enrolles than Toronto, yet averaged from 3 to 19 INSPASS uses per day at each of the five terminals. Newark, with 3,227 enrolles was only used an average of nine times per day. Based upon the variances at the three test sites, we wanted to determine why test results in Toronto for enrollment and usage were more successful than in New York or Newark. Our reviews at the three test sites revealed the following:

•Recruitment procedures were similar at the Newark and New York test sites. When a frequent business traveler was identified by either airline or INS personnel, the traveler was encouraged to enroll in INSPASS. If the traveler was interested in enrolling in INSPASS, he or she had to go to the enrollment office. We found that at Newark and New York, the remote location of the enrollment offices tended to discourage enrollment. At both sites, enrollment offices were located away from the inspections area. The enrollment offices were located in the departures (check-in) area. At the Newark test site, there was one enrollment office. At the New York test site, there were five separate enrollment offices; one at each airline terminal. We found that recruitment efforts varied between terminals. For instance, at the Delta terminal at JFK, INS personnel were aggressive in their recruitment efforts. The effort is evidenced by the 27.1 enrolles per day on average; the highest of all INS test sites. At the Newark and New York test sites, airline and INS personnel were the main sources for identifying potential INSPASS users.

•Recruitment procedures were different in Toronto because the inspection process at Toronto was performed prior to, rather than after, arrival in the U.S. At Toronto, immigration personnel, while performing primary inspections, identified potential INSPASS users and referred them to the INSPASS unit located in the primary inspection area. There, a member of the unit performed the enrollment process, issued the INSPASS card, trained the traveler on the INSPASS kiosk, and monitored the traveler's first use of the system. We believe that a portion of Toronto's success is attributable to the location of the enrollment office within the inspections area.

We realize that the Toronto test site facility is unique because travelers are inspected prior to arrival in the U.S. and the enrollment office is located within the primary inspection area. However, we believe that locating the enrollment booth within the primary inspections area may facilitate the recruitment process by bringing the process closer to the potential user. We discussed this with INS project personnel who did not consider this to be a viable plan. They contended that the plan requires the elimination of some inspections booths due to space considerations in inspection areas. INS believed it would result in a negative public perception. In our judgment, no inspection booths needed to be eliminated. Experimenting with this approach at other sites will permit potential users to be immediately referred to and enrolled in INSPASS. Users can also be trained to use INSPASS immediately.

Currently, INS leaves some inspection booths unmanned during peak periods because of staffing limitations. Therefore, we don't agree that replacement of an empty inspection booth with an INSPASS kiosk would have a negative impact on the public's perception of the inspection process. We believe that installation of additional INSPASS kiosks may generate increased interest and enrollment in INSPASS. Therefore, we believe that INS should experiment with an enrollment booth within other primary inspection areas, at least on a test basis. This could be accomplished in place of or in addition to current enrollment offices. As depicted in the tables, the enrollment and usage figures are considerably lower than would be acceptable for a fully implemented project. While the actual figures to date are disappointing, a side benefit to INS of the low enrollment and usage figures is that they have been able to address system problems while inconveniencing relatively few travelers. With r egard to the low enrollment, INS has not performed a major marketing campaign to attract users while in this pilot phase of the program. However, if full implementation is decided upon, a more aggressive campaign to enroll travelers will have to be pursued. Options for INS should include: (1) involving the airlines more to promote INSPASS via air magazines, in-flight promotional videos, etc. (2) soliciting potential users at primary inspections by experimenting with locating enrollment booths in the primary inspection area, and (3) promotional efforts aimed at the frequent business traveler.

Selecting a Reliable and Secure Biometric Identifier

As discussed in Finding 1, biometric technology can be used successfully to identify individuals. Various types have been in existence for about 20 years. The more widely used biometrics include fingerprint, hand geometry, and retinal scan. For INSPASS, the pilot program team considered three dimensional hand geometry and fingerprint as the biometric identifiers to be tested. Three dimensional hand geometry was selected as the primary biometric, however, the team decided to conduct a limited test of the fingerprint biometric at the Toronto site. Currently, hand geometry is the only biometric used in New York (19,661 enrolles) and Newark (3,227 enrolles). Hand geometry (2,761 enrolles) and fingerprints (1,572 enrolles) are both used in Toronto.

INS selected three dimensional hand geometry because its biometric identifier can be encrypted into a nine character data code. The fingerprint identifier requires more data for identification and cannot be reduced to a nine character data code. The nine character data code can be used with any type of identity card and printed in a font which is compatible with the machine readable optical standard used for U.S. passports. In addition to hand geometry requiring less storage space, INS was reluctant to use fingerprints because the pilot program team originally

believed that there would be user resistance to the use of a fingerprint biometric identifier. Our survey results did not confirm this. Contrary to INS' belief, 89 percent of the respondents to our user survey indicated they would not object to the use of their fingerprint as a biometric identifier. Select user comments appear below.

•"No objection in principle. I agree, provided that technology is reliable enough to allow fast control."

•"Go with fingerprints! Most Americans are hyper against fingerprinting. Those of us who travel widely are used to it and will not object. Saving time is our #1 priority."

•"By using only fingerprints versus having to line up the hand steady...will save time and you will still be able to identify the person."

In order to test fingerprint biometrics, Toronto INSPASS enrolles were allowed to choose between the hand geometry and fingerprint biometric identifiers to confirm their identity at the time of inspection. This choice was available to enrolles between December 3, 1993 and February 15, 1994. During this period, 1,572 enrolles (75 percent) chose the fingerprint as their primary biometric identifier. After February 15, 1994, INS stopped permitting new enrolles to select the fingerprint biometric identifier, due to a high rate of false rejections. For those enrolled with the fingerprint biometric, INS is accumulating statistics to determine the effect of user experience on the rate of false rejections. In our judgement, INS' current rejection rate may be attributable to its current micro computer based hardware design rather than the fingerprint biometric.

Hand geometry uses the hand outline measurements made in three dimensions. A solid state camera is used to capture an image of the hand. Both a top view, which gives length and width information, and a side view which gives a thickness profile are obtained. During the enrollment process, various dimensional measurements of the hand are made from these images, then coded and printed on a machine readable card, in the last nine characters of the first line (see photograph on page 27). During identity verification, the user places their card in a card reader which reads the code. The user then places their hand on a reading device which takes a reading of the user's hand measurements. The code contained on the user's card is translated back into hand measurements and compared with the user's hand measurements from the reading device. If the two measurements fall within a predetermined tolerance, the user continues processing and passes through inspections. If not, the user is referred to an inspector for a routine primary inspection.

Fingerprint technology as a biometric has been evolving since 1973. Its main advantages over the hand geometry biometric identifier are speed and accuracy. During the enrollment process, the enrollee's fingerprint is read by a fingerprint reader. The reader takes a high-resolution, electronic picture of the fingerprint. The picture contains up to a quarter million pieces of information which are digitized and converted to a mathematical characterization called a template. The template can be stored within the micro chip of a smart card or on a database. [ Since INS is using a machine readable card, the fingerprint application in Toronto requires the users fingerprint to be stored in a database contained in the kiosk micro computer.] Subsequent identity verification takes on the average of 1-2 seconds. In order to be identified, the user places a finger on the scanning lens of a fingerprint reader. The user's template is retrieved from the smart card or database and compare d to the current reading. If there is a match between the current reading and the template stored in the smart card or database, identification is then verified.

In our judgment, an alternative to the hand geometry biometric has not been adequately tested within the pilot program. The fingerprint biometric has only been tested on 6% of current INSPASS enrollees. The National Security Agency (NSA) has performed an analysis of three dimensional hand geometry in order to assess its reliability. As of the writing of this report, the results of the NSA study have not been released. If the NSA does not find hand geometry sufficiently reliable, implementation of INSPASS on a nationwide basis may be seriously delayed because INS has not adequately tested an alternative biometric identifier.

Alternative Data Cards

Our audit determined that INS should consider experimenting with alternate INSPASS identification cards before proceeding with nationwide expansion. INS is considering two card options. The first option is a machine readable identification card which contains basic information including the travelers name, passport number, period valid, where the card was issued, and an encrypted code which identifies the user's biometric identifier. The data is printed on the card. The card does not contain a magnetic strip and does not have any other data storage capability. The machine readable card can only store the data that can be printed on the face of the card (in the readable zone) and cannot be updated without producing a new card. (Photograph of data card not included.)

The second option is a "smart card" similar to cards used for employee access to secure facilities. Smart cards contain a micro chip which is capable of mass storage and the user's data stored within the card can be updated without producing a new card. Smart cards are currently being used, for example, to verify the identity of authorized subscribers for direct satellite television services.

The decision on whether to adopt a machine readable card or a smart card involves a trade off of cost versus functionality. INS selected a machine readable identification card rather than the smart card for two reasons. First, the machine readable card was less expensive than the smart card. The current machine readable card used by INS can be produced for approximately 40 cents per card, while the smart card costs from $4.00 to $10.00, depending upon the level of functionality. Second, the machine readable card was compatible with the machine readable font used in U.S. passports.

Our audit disclosed that the long term benefits of adopting a smart card may be more cost effective and offset the short term additional costs. For example:

•Smart cards are capable of augmenting the identification process. The smart card can electronically store additional identifying information such as images, as well as historical and biographical information that is specific to the user. For example, smart cards can store digitized pictures of the cardholder which can be used for identification purposes during compliance checks or if the user is referred to secondary inspection.

•The machine readable card is not capable of storing the biometric identifiers for the fingerprint; therefore, INSPASS must query a separate database to obtain the biometric identifiers in order to verify the identity of those users in Toronto who are participating in the fingerprint test. The smart card can store the biometric identifiers for either hand geometry or the fingerprint.

•The smart card is updatable. Changes in the user's biographical data or subtle biometric adjustments for users can be made when the card is used for admission. The current machine readable card cannot be updated and must be replaced when defective and upon annual re-enrollment.

•The use of a smart card may produce the time savings which would assist INS in meeting its 30 second goal. The additional cost of the smart card could be recovered through user fees. Our survey results indicated that 52 percent of users would be willing to pay a fee for INSPASS; however, many indicated that the fee should be contingent upon improvements to the current system.

•The printer that produces the machine readable card did not always print data clearly or completely on the card. As a result, many cards had to be reprinted before they would be read properly by the INSPASS card reader. We also found that over time, skin oils and smudges on the card sometimes caused the card to be rejected by INSPASS and a replacement card is necessary.

Based upon our audit, we believe INS should consider testing smart card technology before proceeding with nationwide INSPASS implementation. The inclusion of the traveler's hand geometry in the available machine readable zone of the passport, may no longer be a consideration. We found that a user's hand geometry changes over time. Therefore, the current machine readable card's compatibility with the State Department's format for U.S. passports may no longer be a consideration since the information on the machine readable card (or incorporated on the passport) cannot be updated. If a fingerprint biometric identifier is selected, this biometric identifier cannot be stored on a machine readable card or within the machine readable zone of the passport. Since the smart card can be updated and has enhanced storage capabilities, it could be used as the primary storage source for much of the user's identifying data, thus eliminating the need for time consuming queries to the INSPASS d atabase. The smart card's features also have the potential to increase security and enhance INS' ability to more efficiently meet the INS objective to establish and confirm the identity of the enrolled international air traveler through their use of INSPASS.

INSPASS Staffing

There are two current approaches to staffing of INSPASS within the pilot program. At the Newark and New York test sites, there are no specific INSPASS teams. At these test sites, INSPASS is managed by port of entry personnel as an additional task. However, at the Toronto test site, a separate INSPASS unit has been created. At the Toronto test site, immigration inspectors are selected by port of entry management for the INSPASS unit. Currently, the unit is made up of 11 inspectors, who rotate between INSPASS and normal inspection duties. The Unit is responsible for enrolling travelers in INSPASS, monitoring the INSPASS kiosk, training and assisting INSPASS users, performing quality control checks on enrollment applications, maintaining the system hardware and software, and performing the compliance checks on INSPASS users. Our audit determined that the dedicated INSPASS unit concept enhanced implementation of the system at the Toronto site. The INSPASS unit consists of volun teer immigration inspectors who can be adequately trained in all aspects of INSPASS, are familiar with the INSPASS enrollment and inspection process, and dedicated to making the pilot program work. At the Newark and New York test sites, we found that many immigration inspectors were not always adequately trained on INSPASS and some inspectors assigned to monitor the INSPASS kiosk were not thoroughly familiar with INSPASS procedures.

There are also security-related benefits to dedicating full time inspectors to INSPASS. Our audit disclosed weaknesses with the kiosk monitoring procedure at Newark and New York. While monitoring the kiosk and system printer, the immigration inspector was responsible for performing standard primary inspections. The inspector was also responsible for assisting INSPASS users experiencing problems with the kiosk, and performing inspections of users who were rejected by the system. If the printer used to monitor the INSPASS kiosk was either taken off line or turned off, there would be no way for the immigration inspector to identify travelers who were rejected by the system or experiencing problems with the system.

While at Newark and New York, we observed instances where the INSPASS printer was either turned off, taken off line, or not adequately monitored. In one instance, we found that a traveler had attempted to use an INSPASS card which had been reported lost. However, no action was taken because the INSPASS system printer was not monitored at the time this transaction took place. We found that at the Toronto test site the INSPASS kiosk and system printer were monitored at all times by a dedicated immigration inspector assigned to the INSPASS unit. The inspector monitors the INSPASS kiosk from the enrollment station which is in close proximity to the kiosk. Therefore, when an INSPASS user experiences a problem at the kiosk, a member of the INSPASS unit can immediately provide assistance and check for potential security problems.

Our audit also disclosed that INS needs to take steps to facilitate the sharing of information between inspectors at all three test sites. For example, a method for reprocessing the current INSPASS data card to improve the print quality was discovered by an inspector at one of the three test sights; however, our audit disclosed that other inspectors at the other test sights were not aware of this method. As a result, many INSPASS cards which could have been salvaged were discarded because this information was not shared.

We believe that for at least the pilot program and the initial stages of implementation of INSPASS, the dedicated unit concept would be the most effective approach to staffing. In our judgment, this could be accomplished with existing resources without increasing personnel. The dedicated unit approach can: (1) assure that an individual inspector can monitor multiple kiosks at the same time and (2) assure that those immigration inspectors assigned to INSPASS would be adequately trained, familiar with the enrollment and inspection process, and committed to the success of the system. We believe that the dedicated approach can address INS' objective to produce a system that is easy to use by both the INSPASS traveler and INS personnel.

Conclusion

We identified a number of weaknesses with the current configuration of the system that need to be addressed. In spite of the identified weaknesses, we believe the INSPASS concept is sound in principle. Further, we credit INS for attempting an innovative approach to reduce inspection-related congestion for frequent business air travelers to the U. S. Given the recommendations below, an efficient and effective system to accomplish the objectives of INSPASS can be developed.

Recommendations:

We recommend the Commissioner of INS take the following steps to design an efficient and effective system which satisfies program objectives before committing to full implementation of the program:

2.improve the current kiosk design to include the testing of other interactive interfaces and a more effective kiosk warning system;

3.meet or exceed the 30 second processing time requirement;

4.improve quality control by performing checks on enrollment database accuracy;

5.promote the system by testing the placement of an enrollment booth within the inspections area of pilot program sites, and/or by other means;

6.pursue expanded testing of fingerprint technology as an alternative biometric identifier;

7.pursue the testing of the smart card technology;

8.pursue the "dedicated unit" staffing concept at pilot program sites; and

9.facilitate the internal sharing of information related to the INSPASS system (eg., inspector user groups, conference calls, newsletter, and technical updates from other inspectors).

OTHER MATTERS

The conclusion of our audit is that the INSPASS concept is viable; however, there are several weaknesses INS needs to correct before expansion. Therefore, we did not specifically address INS' expansion plans. The INSPASS Preliminary Investigation Report prepared by Computer Data Systems, Inc.(CDSI) for the INS Office of Information Systems dated August 12, 1992 and the INSPASS Feasibility Report prepared by CDSI for the INS Data Systems Division dated October 30, 1992 are based on the assumption that full deployment of INSPASS will be at all U.S. International air Ports-of-Entry.

We believe this plan would be too aggressive. Any future expansion should be based upon the cost/benefit of implementing the program at selected airports. INS should also establish minimum volume of international traffic passing through the airports which would be acceptable for the installation of INSPASS.

In their response to the draft report, INS stated they do not intend to expand to all air Ports-of-Entry. We concur with this revised INS position.

BEST PRACTICES

We would like to recognize and report what we deem to be an agency "best practice". In our judgment, the Toronto test facility was administered in a superior manner in comparison to the INSPASS test sites in New York and Newark. Specifically, the "dedicated staffing approach" assured that all INSPASS personnel were courteous, well trained, professional in their dealings with potential and current INSPASS users, and dedicated to making the system work. This practice could be replicated without the requirement of additional personnel.

STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS

We conducted an audit of INSPASS. In connection with our audit we tested transactions and records to obtain reasonable assurance about the INS' compliance with laws and regulations that, if not complied with, could have an adverse material effect on the INS' development and implementation of the INSPASS program.

Generally accepted government auditing standards require a review of the laws and regulations pertaining to the objectives of the entity's programs or activities to gain an understanding of the results expected. Sufficient testing must be conducted to determine whether the programs or activities are being carried out in conformity with these laws and regulations. Our review included the Immigration and Naturalization Act of 1952 (8 U.S.C 1356).

For the transactions tested, nothing came to our attention that caused us to believe that INS was not in compliance with the Act.

With respect to the transactions not tested, nothing came to our attention that caused us to believe that INS was not in compliance with the Act.

STATEMENT ON INTERNAL CONTROL STRUCTURE

In planning and performing our audit of INSPASS, we considered the internal control structure for the purpose of determining our auditing procedures. This evaluation was not made for the purpose of providing assurance on the internal control structure. However, we noted certain matters involving the internal control structure related to the INSPASS enrollment process and INSPASS inspections conducted within the pilot program.

Reportable conditions involve matters coming to our attention relating to significant deficiencies in the design or operation of the internal control structure that, in our judgment, may result in inadmissible or ineligible users being enrolled and inadequate monitoring of the immigration inspections process. These matters are described in the Finding and Recommendations section of the report.

Because we are not expressing an opinion on the internal control structure of INSPASS, this statement is intended solely for the information and use of component management in administering INSPASS. This restriction is not intended to limit the distribution of this report, which is a matter of public record.

APPENDIX I

USER SURVEY QUESTIONNAIRE AND SUMMARY OF RESULTS

U.S. Department of Justice

Office of the Inspector General

INSPASS User Survey

1.How many times have you used the INSPASS system? 9.4 average uses

2.Have you experienced any savings of time using INSPASS versus the

manual primary inspection process?  Yes 89%  No 10%

3.Have you experienced any problems with your use of INSPASS? Yes 46%  No 52%

If yes, please identify on bottom or back of this page.

4.Would you continue to use INSPASS if a fee were charged for this

program? Yes 52%  No 47%

If yes, what would you consider a reasonable fee for this

program? $24.69 average fee

If no, please explain why on bottom or back of this page.

5.Would you object to the use of your fingerprint instead of the hand

identification? Yes 10%  No 89%

6.Is the INSPASS machine easy to understand and use? Yes 92%  No 7%

7.Do you believe that the machine could be made easier to use? Yes 37%  No 55%

If yes, please explain how on bottom or back of this page.

8.Do you use the INSPASS card for all business trips where the system

is available? Yes 87%  No 12%

9.Do you think the INSPASS program should be offered to a wider

range of travelers such as tourists? Yes 29%  No 67%

Percentages may not total 100% because not everyone answered every question.

APPENDIX II - Not Included

APPENDIX III

OFFICE OF THE INSPECTOR GENERAL, AUDIT DIVISION,

ANALYSIS AND SUMMARY OF ACTIONS NECESSARY TO

CLOSE THE REPORT

The INS response to the draft report expressed concern about our interpretation of two issues: the 45 minute inspection standard mandated by PL 101-515, and INS' intention for full implementation of INSPASS. We added language to the final report Finding 1 and the Other Matters section, respectively, to clarify these issues. We maintained our position in both instances.

Recommendation Number:

1. Resolved. In order to close this recommendation, please provide a copy of the survey instrument that will be used to obtain the views of INSPASS customers on various aspects of INSPASS operations and INS' methodology for using the survey instrument.

2.Resolved. In order to close this recommendation, please provide us with a description of the technology selected and the kiosk design for the enhanced version of INSPASS.

3.Resolved. In order to close this recommendation, please provide documentation that demonstrates how the enhanced version of INSPASS will assist users in meeting the 30 second average goal for completing INSPASS inspections.

4.Resolved. In order to close this recommendation, please provide us with a list and description of all software changes that have been implemented to ensure that required data is being entered correctly. Also, please advise us when you implement the System Administrator checks of the INSPASS database at Newark and New York.

5.Resolved. In order to close this recommendation, subsequent to implementing the enhanced version of INSPASS, please provide us with INS' planned efforts to increase enrollment in INSPASS.

6.Closed.

7.Closed.

8.Resolved. In order to close this recommendation, please provide us with the criteria you will use to determine if the dedicated unit staffing concept should be implemented at a pilot site. In addition, please provide training dates and material for sites where the dedicated concept will not be in place.

9.Closed.

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