Background and Operating Procedures
Miami had 25,739 certificates on-hand as of June 1, 1995. Between June 1, 1995, and June 1, 1997, the district received 165,000 additional certificates, and had 40,758 certificates on-hand at the time of our visit.
The Miami CUSA office, located in the Customs House a few miles from the district office, had access to RNACS. Applicants for naturalization sent their application packages to the Texas Service Center in Dallas, Texas, for preliminary processing. The Service Center scheduled applicants for their initial interviews. Frequently, however, the appointment notices for the scheduled interviews arrived in Miami too late to mail to the applicants, and the Miami staff had to reschedule the interviews.
Until June 12, 1996, the bulk supply of N-550s was stored at the district office, and intermediate supplies were stored at the CUSA office. After June 1996, the bulk supply was transferred to the CUSA office for storage. The certificates were housed at the CUSA office in metal filing cabinets secured by combination locks, and employees had sole access to the certificates for which they were accountable, in compliance with AM Section 2117 requirements. We confirmed, from entries in handwritten log books, that all the N-550s sent by the forms center to Miami were received.
In Miami, bound log books were maintained, listing the certificate numbers and name of accountable employee, at every step from receipt to disposition, in accordance with AM Section 2117. Each supervisor and clerk who handled the certificates kept separate log books. The log books recorded receipt in the bulk storage area of the N-550s from the Eastern Forms Center, the receipt and issue of the N-550s from bulk storage to the supervisors, and the reissue of smaller blocks of certificates to clerks for preparation.
Except for a six-week period in mid-1996, when automated RNACS reports were used in lieu of log books, each clerk listed the certificate number, date of issue, and the name and A-number of the applicant issued the certificate in his/her log book. The clerks annotated the log books to show disposition of N-550s--issued or voided.
If a certificate was voided, the clerk noted the reason for voiding and the certificate number of any replacement certificate issued. The issuing clerk also listed the certificate number of the voided forms in the back of the log book. The supervisor who originally issued the blank certificate to the clerk also listed information in a separate section of his/her log book when the certificate was voided. The supervisor listed the date of the void, certificate number, applicant name and A-number, and the replacement certificate number.
Other than the brief period in 1996 (mid-July to late August), when the number of naturalizations taking place was increasing rapidly under the CUSA program, the manual log book procedures prescribed in the AM were followed strictly. Taken together, the log books provided a complete record of each certificate from receipt to disposition, and associated the accountable employee with the certificate at each phase. During the period we reviewed, a total of 11 supervisors and 32 clerks worked with the certificates and used the prescribed handwritten log book records even though they were time-consuming and labor-intensive to maintain.
During the six-week period in 1996, INS Headquarters permitted districts to use automated reports derived from the RNACS data base in lieu of handwritten log books. The automated reports listed the certificate number, A-number, name of applicant, certificate issue date, and identified the supervisor and clerk who prepared the certificate. Four naturalization ceremonies were conducted in Miami during this six-week period, but the automated report for only one ceremony was retained. Miami CUSA officials said that when they realized the automated reports omitted some entries and did not constitute accurate records, they returned to using the handwritten log books. INS Headquarters recognized that RNACS was not providing accurate data and has been trying since then to correct deficiencies in the system.
On a rotating basis, district adjudications officers (DAO), who were not otherwise accountable for the N-550s, conducted weekly inventories of the N-550s. The inventory included checking the voided certificates, shredding them, and certifying their destruction. While AM Section 2117 requires only biweekly inventories, Miami managers chose to have the inventories done weekly. The managers said if the inventories were performed biweekly, it took about a week to complete them because of the high volume of transactions that would occur. However, if inventories were conducted weekly, an officer could complete the inventory in about two days, resulting in less time overall for this collateral duty.
The officer conducting the inventory only checked the accuracy of entries in each individual clerk's log book. The officer was not cross-checking between the supervisors' and clerks' books to verify that the same quantities and certificate numbers were listed. Miami officials told us this omission of cross-checking records was corrected, and inventories were now tracking the certificates from initial receipt to final disposition.
While Miami complied with inventory requirements, neither INS regional nor Headquarters employees conducted any audits or reviews of the N-550s during the period we reviewed. The district director failed to prepare the annual report to certify that the district was in compliance with AM Section 2117. Also, we found no records to show that employees were signing the Accountable Employee Certification forms, or receiving the formal training specified. On the other hand, the employees said they were very aware of their responsibilities for controlling and safeguarding certificates, and potential liability for their misuse.
We tested a sample of 990 certificate numbers, selected randomly from the universe of 149,981 certificates. Our sample came from three groups:
From our sample of 990 certificates, we were able to find documentation indicating disposition, i.e., issued or voided, for all certificates. Finding documentation was often difficult due to clerical errors in log books or in RNACS.
In reviewing the documentation for our sample, we found 226 naturalization cases that were closed in RNACS, but applicable naturalization information was not in the CIS. If our sample is representative of the entire universe of 149,981 certificates, we estimate that Miami may have as many as 34,200 closed cases in RNACS that have not been updated in CIS for the two-year review period.
Background and Operating Procedures
Based on records available, Chicago had 66,500 certificates on-hand as of June 1, 1995. Between June 1, 1995, and June 1, 1997, the district received 45,000 additional certificates, and had 26,672 certificates on-hand at the time of our visit.
The Chicago CUSA office has access to RNACS, and naturalization applications for applicants within the jurisdiction of the Chicago district are initially screened and processed by the Nebraska Service Center located in Lincoln, Nebraska. All remaining naturalization activities, e.g., interviews, English testing, and preparation of certificates for naturalization ceremonies, were conducted at the CUSA office located about two blocks from the district office.
The bulk supply of N-550s was maintained in a locked room in the district office. Log books and record keeping for the bulk supply of N-550s were not in compliance with the AM. None of the 45,000 certificates received from the forms center during our review period was listed in the bulk inventory records by certificate number. Nevertheless, by examining on-hand inventories and other records, such as court lists, we were able to determine that the district received all of the certificates sent from the forms center. In addition, only 10,000 of the 86,000 certificates issued to the CUSA office during our review period were identified by certificate number.
Physical inventories of the bulk supply were conducted about once a month, rather than biweekly, as required by the AM. However, the physical inventories were merely counts of the supply on-hand and not reconciled with inventory records. For example, one entry in the inventory records showed 6,000 certificates issued, but listed only 5,500 certificate numbers. The 500 certificate discrepancy was never explained in the records, even though subsequent physical inventories were taken. In our test sample, we selected 30 certificate numbers from this box of 500 certificates and verified disposition for all certificates except one.
Working supplies of N-550s were kept in safes at the CUSA office. However, no log books were maintained from at least the beginning of our review period (June 1995) until April 1997. When the CUSA office started maintaining log books, the log books were not in compliance with the AM. Certificate numbers were not listed for receipts and issuances. CUSA officials said the volume of work increased so quickly that time did not permit the immediate recording of the required information into a log book, i.e., date, alien name, A-number, and certificate number. Instead, CUSA employees made photocopies of the certificates, to transcribe the information into log books later. The photocopies were only maintained by fiscal year, and not in any sequential order such as A-number, certificate number, or date.
When the transcription from the certificate photocopies to the log books became backlogged, CUSA officials started using a computerized list to keep track of the increasing number of photocopies. However, information in the list could not be sorted automatically. As a result, for at least a two-year period, the information needed to match certificates to individual aliens could be: (1) contained in the tens of thousands of certificate photocopies, (2) included in the computerized list, or (3) possibly neither. Therefore, matching the certificates to individual aliens was almost impossible. Also, because log books were not maintained, we do not have any records to show that supervisors were verifying the accuracy of certificates prepared by employees. AM Section 2117 requires a daily verification by the supervisor.
We do not have assurance that all voided certificates could be accounted for and were actually destroyed. Whenever an applications clerk voided a certificate, it was given to a designated clerk who entered the certificate number into her own computerized list. Similar to the computerized list for the photocopies of certificates, this computerized list of voided certificates had no sort capability and no management controls were built into it to provide an audit trail, if the clerk should later add to, delete, or otherwise change data. While the list of voided certificate numbers was maintained by fiscal year, there was no overall sequential order in listing the certificates. Therefore, it was extremely difficult in reviewing the lists to determine if a specific certificate was voided.
Approximately 3,700 voided certificates were listed for fiscal years 1995, 1996, and 1997 through April 28, 1997. After entering the numbers of the voided certificates into the computerized list, the clerk gave them to the employee accountable for maintaining the interim supply of blank certificates, to hold until they were picked up for destruction. Approximately every six months, a district employee, usually from the INS investigations branch, picked up the voided certificates and took them for destruction. However, no documentation existed for the transfer of the voided certificates between employees and no destruction document, as required by AM Section 2117, existed. Therefore, there is no assurance that certificates were actually destroyed.
Because of the aforementioned problems in maintaining log books properly, not using log books for an extended period of time, not conducting biweekly audits, not verifying the accuracy of issued certificates daily, and not accurately identifying and then verifying the destruction of voided certificates, we have no assurance that certificates were adequately controlled and accounted for in the Chicago district.
Physical security of the bulk supply of N-550s needed strengthening. The bulk supply was kept in one room that was inside another room. The outside room had a push-button locking mechanism, and the inner room containing the bulk supply had a key-locking mechanism. The key lock, however, did not meet AM Section 2117 requirements. In addition, at the time we reviewed the bulk supply, the key to the bulk supply room was kept on a nail behind a desk in the outer room.
We also found that neither INS regional nor Headquarters employees conducted any audits of the N-550s during the time period of our review. AM Section 2117 requires an audit of secure documents, including N-550s, at least annually by the region, and an audit by Headquarters when visiting a field location. While we found that employees were signing the Accountable Employee Certification form, they were not always made aware of the requirements contained in AM Section 2117. Employees were not always cognizant of their responsibilities, were unfamiliar with their liability for non-compliance with the AM, and did not receive adequate training. There was also no evidence that the district director prepared the required annual report in 1996 and 1997 that certified that the district was in compliance with AM Section 2117. Because of the problems we identified in this inspection report, we question the validity of the district director's annual certification report for 1995.
We tested a sample of 490 certificate numbers, selected randomly from Chicago's universe of 84,828 certificates. Our sample came from five groups:
From our sample of 490 certificates, we could not find any evidence that 54 were either issued or voided. We also found no evidence for 15 issued certificates that should have been voided when another certificate was issued. If our sample is representative of the entire universe of 84,828 certificates, we estimate that Chicago has no documentation to support the disposition of as many as 9,300 certificates, and has no documentation to verify that as many as 2,600 certificates were actually voided and subsequently destroyed for the two-year review period.
Within our sample, we also identified 45 cases that were closed in RNACS and applicable naturalization information was not in CIS. Again, projecting our sample to the universe, Chicago may have about 7,800 naturalized aliens who are not shown in CIS as being naturalized for the two-year period.
Background and Operating Procedures
Omaha had 1,350 certificates on-hand as of June 1, 1995. Between June 1, 1995, and June 1, 1997, the district received 7,500 additional certificates, and had 4,325 certificates on-hand at the time of our visit.
Omaha did not have access to RNACS, and Omaha employees performed all naturalization work, from receiving the initial naturalization application to issuing the N-550 at the naturalization ceremony. Although some temporary employees have been added to the staff to handle the increasing volume of naturalization work, a backlog has been growing in this area. District managers also attributed the backlog to a turnover in permanent personnel.
The bulk supply of N-550s was kept in a safe to which only one employee had access. While the employee responsible for the bulk supply was not always following the procedures prescribed in AM Section 2117, we were able to account for the 7,500 certificates sent to Omaha from the forms center. We were also able to account for the 5,350 certificates transferred to the working supply kept by the applications clerk in the naturalization unit, even though procedures did not meet AM requirements. We found that log books were not kept in compliance with the AM, no inventory was taken when there was a change in accountable employees, the combination to the safe was not changed annually, and no biweekly inventories were conducted in 1996. In addition, the supervisor did not verify daily the accuracy of the certificates prepared by the applications clerk.
The controls over N-550s and procedures followed in their preparation, in the past, were more informal than those prescribed in the AM. In 1995 and 1996, with a smaller staff and lower volume of work, naturalization adjudicators took blank certificates for applicants to sign from a working supply left in an interview room by the applications clerk. The adjudicators entered the date, alien's name, A-number, certificate number, court, their initials, and the balance of certificates on-hand in the log book that the clerk left with the blank certificates. At the end of the day, the clerk locked both the signed N-550s, placed by the adjudicators in the applicant's A-file, and the unused blank certificates, in the safe.
District officials said the above procedure worked well when there were only one or two adjudicators using the certificates. As more adjudicators were hired, a problem developed in ensuring that certificate numbers were recorded in the log books in sequential order. As a result, officials changed the procedure to have the applications clerk responsible for the N-550s keep them locked in the safe until it was time to prepare them for the hearing.
At times throughout our review period, employees from the naturalization unit, other than the accountable applications clerk, obtained N-550s from the bulk supply and gave them to the applications clerk. While this procedure relieved the applications clerk from getting the N-550s, it caused a break in accountability. The employees obtaining the N-550s from the bulk supply did not keep log books or show the transfer of the N-550s to the applications clerk. In addition, the supervisor was not verifying the accuracy of log books on a daily basis, biweekly inventories were not conducted, and no inventory was taken when there was a change in the accountable employee.
The Omaha staff was not destroying voided certificates and still possessed certificates dating back at least to June 1995. While AM Section 2117 delineates the requirements for destruction of voided certificates, it does not require an office to actually destroy them. We selected a sample of 23 voided certificates listed in the applications clerk's log book during the period June 1995 to May 1996. We were able to find all of them. However, by properly destroying voided certificates, storage space and the time involved in accounting for them could be saved.
We found that the district was not providing the training needed to ensure that employees handling blank certificates were aware of the procedures and their responsibilities contained in AM Section 2117. As a result, Accountable Employee Certifications were not available for these employees. We also found that audits had not been conducted, on an annual basis, by regional or Headquarters personnel, and the district director had not prepared the required annual certification that the district was in compliance with the AM.
We tested a sample of 180 certificate numbers, selected randomly from the universe of 4,525 certificates. Four employees were responsible for the certificates between June 1, 1995, and June 1, 1997. We took a sample of 30 certificates each from two of these employees who were responsible for the certificates at one time during this period, and two sets of 30 certificates each from the other two employees who were responsible at different times during the period.
By checking CIS, court lists, and A-files, we were able to account for all except one certificate contained in our sample.
Because Omaha did not have access to RNACS, employees had to manually update the CIS
with the naturalization information. From our sample, we found that 26 cases had not been
updated in CIS. If our sample is representative of the entire universe, Omaha could have
as many as 650 cases that were not updated in CIS for
the two-year review period.
Background and Operating Procedures
Portland had 850 certificates on-hand as of June 1, 1995. Between June 1, 1995, and June 1, 1997, the district received 12,000 additional certificates, and had 1,377 certificates on-hand at the time of our visit.
As it did in the other districts, the CUSA program resulted in increased naturalization activity. According to INS records, naturalization applications received in the district increased from less than 2,800 in fiscal year 1994 to more than 7,300 in fiscal year 1996. In order to keep pace with the increase in workload, the number of officers assigned to adjudicate naturalization applications, at least part-time, increased from three to nine officers. However, the number of clerical employees assigned to this task remained essentially the same resulting in increased work for the support staff.
The amount of work required of the sole naturalization clerk in Portland was actually much more than that of clerks in larger districts because the INS service centers did not perform the preliminary processing of naturalization applications, schedule appointments, and send call-in letters to the applicants who applied at the Portland district. The Portland naturalization clerk had to perform these duties. In addition, Portland did not have access to RNACS. Without RNACS, naturalization information had to be manually updated in the CIS. Additional clerical help for this Records branch function had not been obtained to meet the increased demand for this task; therefore, a backlog of cases without CIS updates existed.
Naturalization branch employees attributed the breakdown of controls over certificates to the shortage of support personnel. We do not, however, believe the shortage of personnel can be an excuse for the apparent disregard of prescribed procedures that we observed. We found a lack of effective controls at all stages, from receipt of certificates from the forms centers, to further receipt, distribution, and issuance of certificates, and ultimately to the destruction of voided certificates.
The log book for the bulk supply was poorly maintained and was not kept in accordance with AM Section 2117. One shipment of 1,000 certificates received from the Western Forms Center in 1995 was not recorded as received until May 1996 when the certificates were audited by the district security officer. A total of 6,000 certificates, sent in three separate shipments, was never entered in the log book. In addition, although the AM requires biweekly inventories, inventories of the bulk supply were taken only once a year.
The naturalization clerk kept an intermediate supply of the N-550s, and gave working supplies to the nine district adjudications officers (DAO), who prepared the certificates for issuance. The clerk issued the N-550s by having the DAOs sign the label that secures the bundle of 50 certificates (each sealed box of 500 has 10 bundles of 50 certificates). The naturalization clerk kept one central log book to record the disposition of the N-550s, but did not keep her log book in the prescribed manner of receipt, issuance, and balance on-hand. The clerk attempted to list each certificate number received from the bulk supply individually in her book before the actual assignment of the certificate numbers to specific applicants. At the time of our visit, 340 certificate numbers had not yet been listed in her log book.
When DAOs used the certificates, they noted the certificate numbers on their daily appointment schedules, thereby associating a certificate with the name and A-number of the applicant who would receive it. If clerical time was available later, the applicant's name and A-number corresponding to the certificate was copied by the clerk into the log book from the daily schedules kept by the DAOs. Because of her other responsibilities, the naturalization clerk could not keep the log book current. We found about 1,750 of the certificate numbers in the clerk's log books did not have corresponding names or A-numbers to show the applicants who were supposed to have received the certificates.
We also noted that 563 certificate numbers were skipped when the individual certificate numbers were listed in the naturalization clerk's log book. To verify the disposition of all the skipped numbers, we either checked them in CIS or matched them to other documentation. We were able to account for 552 of the skipped certificate numbers, but were unable to account for 11 certificates.
Biweekly inventories were not conducted as required. The naturalization clerk and eight DAOs had private safes to store the certificates in their custody. The one DAO who did not have a storage container was an inspector from the airport. On a rotating basis each month, inspectors from the airport were assigned as a DAO. The inspector would return unused certificates to the naturalization clerk each evening for safekeeping, but no record of this transfer was made.
We could not verify that voided certificates were actually voided and destroyed. A line was drawn through the certificate number in the log book and the word "VOID" was written over the entry. No initials appeared in the log book indicating the person voiding the certificate, and no number of the replacement certificate was inserted. There were no destruction records identifying which certificates were destroyed. During the two-year period reviewed, 546 certificate numbers in the application clerk's log book were marked void.
We also found no evidence of the required supervisory review of issued certificates, and no records existed regarding training for those employees who handled naturalization certificates. When we discussed our findings with the district director, he immediately directed that training start for those persons who handled naturalization certificates, and log books be issued to each accountable employee.
We chose a random sample of 424 certificate numbers from the universe of 11,473 certificates. The sample was selected from certificate numbers listed in the clerk's log book:
From our sample of 424 certificates, we could not find any evidence in log books or CIS that 68 were either issued or voided. If our sample is representative of the entire universe of 11,473 certificates, we estimate that Portland has no documentation to support the disposition of as many as 1,800 certificates for the two-year review period.
We also found no documentation verifying that the 41 certificates listed as voided in our sample, or the entire number of 546 listed voids, were actually voided and destroyed.
Because Portland did not have RNACS, district employees had to enter the new citizen's naturalization status manually into CIS. From our sample, we found documentation to confirm 90 applicants who were naturalized but their naturalization status was not in CIS. Therefore, we estimate that as many as 2,400 naturalized citizens may not show a correct status in CIS for the two-year review period.
Background and Operating Procedures
Based on records available, Los Angeles had 28,500 certificates on-hand as of June 1, 1995. Between June 1, 1995, and June 1, 1997, the district received 619,500 additional certificates, and had 233,430 certificates on-hand at the time of our visit.
The Los Angeles district has access to RNACS. The California Service Center located in
Laguna Niguel, California, performs preliminary processing of naturalization applications
for the district.
Because of the large number of applicants, the adjudication of naturalization applications is conducted in various outlying locations throughout the district. In an effort to streamline the citizenship process, most of the functions relating to the storage and preparation of certificates were centralized at the CUSA office located in El Monte, California, about 10 miles from the Los Angeles district office. The district office still maintains a small naturalization unit to process military and continued cases. Therefore, this district unit maintains a small supply of blank certificates for issuance.
The primary bulk supply, where 181,000 certificates were in storage, was located in a warehouse in Bell, California. The secondary bulk supply, which was the only bulk supply before the onset of CUSA, was maintained in a vault in the district office. The vault contained almost 35,000 certificates. Working supplies were located at both the El Monte CUSA office and the continued citizenship unit at the district office. The number of certificates contained in the two working supplies at the time of our visit were 15,500 and 2,000, respectively.
Inventory records for naturalization certificates were not maintained at the Bell warehouse as required by the AM and Security Officer's Handbook. The only documents available were the G-514s and G-504s, and not all were available. As a result, we could not account for 147,500 certificates in the bulk supply. However, we were able to determine from our review of log books at the district and CUSA office, which showed the 147,500 certificates in the working supply, that the Los Angeles district actually did receive the 147,500 certificates in question.
The 181,000 certificates on-hand at Bell were stored in a room that previously had been used as a cold storage facility. We agreed with the security officer that this room did not conform to the security specifications required for secure document storage. In addition, the warehouseman who handled the certificates had not received the background investigations or waivers required for persons who handle secure documents.
The custodian for the bulk supply of N-550s at the district office kept the required log book, but the certificate numbers were not entered in the log book as required by the AM and the Security Officer's Handbook. While inventories were taken, they were not taken biweekly and sometimes computational errors made in the log book were not noted or corrected by the inventory.
Accountable employees in the continued citizenship unit in the district office did not have sole access to the certificates under their control. In addition, certificate numbers were not listed in log books as required, no daily verification of log entries was made by a supervisor, and the required biweekly inventories of certificates were not conducted.
Prior to the move to the El Monte CUSA office, log books were either not kept at all or were kept in such a disorganized manner that tracking certificates was nearly impossible. With the extremely large volume of certificates used by the Los Angeles district and the large number of employees handling them, properly maintaining log books was imperative to establish accountability. After moving to the El Monte CUSA office, log books were better maintained but still not in complete compliance with AM 2117 guidelines and supervisors had not made daily verifications of log book entries. Both these deficiencies were corrected during our inspection. Inventories were not conducted biweekly nor were they reconciled to the previous inventory.
We found that the documents used to certify destruction of voided documents were not properly completed. The destruction official and witness did not attest in writing to the destruction of the certificates. We estimate that about 60,000 certificates were voided during our review period.
Not all employees received the training required for accountable employees or signed the Accountable Employee Certification, and the district director did not annually report that the district complied with the provisions of AM Section 2117.
We randomly selected 1,000 certificate numbers from the universe of 414,570 certificates. Because of the deplorable way in which log books were maintained, we selected our sample from the forms center shipping documents.
From our sample, we found 17 cases where there was no evidence of disposition (issued or voided), and 39 cases where there was no documentation to confirm that a voided certificate was actually destroyed. If our sample is representative of the entire universe of 414,570 certificates, we estimate that Los Angeles has no documentation to support the disposition of as many as 7,000 certificates, and has no documentation to verify that as many as 16,000 certificates were actually voided and destroyed for the two-year review period.
We also noted that in 41 cases the naturalization information in RNACS was not in CIS. The cases were closed in RNACS and, therefore, should have been automatically updated to CIS. If our sample is representative of the universe, Los Angeles may have almost 17,000 cases that are closed in RNACS and not updated in CIS for the two-year review period.
OFFICE OF THE INSPECTOR GENERAL'S ANALYSIS
OF MANAGEMENT'S RESPONSE