We initiated this follow-up inspection to determine whether INS developed and implemented procedures to flag automated database records of aliens suspected of obtaining immigration documents and benefits fraudulently and whether the recommendation had the intended effect. We found that INS did comply with our recommendation to institute flagging procedures by flagging the records provided by the OIG as a result of our 1996 inspection. However, the flagging procedures are not complete. We discovered that neither the flagging procedures nor the boilerplate language include steps adjudicators must follow to have the NAILS records and flags removed. INS adjudicators are either not checking CIS, or are not following through with steps that would have the NAILS record and flag removed, therefore defeating the purpose of the flagging procedures. Finally, INS has not made adequate efforts to obtain information from the OIG for INS personnel to effectively investigate aliens associated with OIG cases where genuine immigration documents and benefits were obtained fraudulently. In an effort to assist INS in addressing these issues, we propose that INS take the following measures.

The OIG, Inspections Division recommends that the Commissioner, INS:

1. Ensure that each record that contains the "NAILS-X" flag in CIS is also accompanied with a corresponding record in NAILS.

2. Ensure that inspectors forward memoranda to Field Operations explaining the results of record reviews as required by INS procedures and dictated in the corresponding NAILS record.

3. Direct INS personnel and contractors to conduct searches in CIS for all applications and petitions before INS benefits are granted or any INS actions taken, as required by INS's "Flagging of Fraudulent Records in INS Automated Systems" policy.

4. Develop procedures for adjudicators to forward memoranda to Field Operations explaining the results of the records review as required of inspectors.

5. Reach agreement with the OIG Investigations Division outlining specifically what information is required when the OIG is reporting to INS the names and A-numbers of aliens allegedly involved in schemes where aliens obtain genuine immigration documents and benefits fraudulently.