INS User Fees: INS Working to Improve Management of User Fee Accounts
(Letter Report, 04/12/94, GAO/GGD-94-101).

This report provides information on the Immigration and Naturalization
Service's (INS) two major user fee accounts: the Immigration
Examinations Fee Account and the Immigration User Fee Account.  GAO
discusses (1) the methods INS used to set its fees, (2) if the fees
reflected the actual costs of providing services, (3) if the
expenditures from fee accounts were consistent with the purposes of the
accounts and management and control of the fees were enough to prevent
misuse of fee revenue, and (4) whether staff were allocated in
proportion to workload among the districts providing services that were
financed by the fees.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-94-101
     TITLE:  INS User Fees: INS Working to Improve Management of User 
             Fee Accounts
      DATE:  04/12/94
   SUBJECT:  Use taxes
             Funds management
             Immigration or emigration
             Human resources utilization
             Accountability
             Fees
             Accounts receivable
             Internal controls
             Federal agency accounting systems
             Accounting procedures
IDENTIFIER:  INS Immigration Examination Fee Account
             INS Immigration User Fee Account
             
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Cover
================================================================ COVER


Report to Congressional Requesters

April 1994

INS USER FEES - INS WORKING TO
IMPROVE MANAGEMENT OF USER FEE
ACCOUNTS

GAO/GGD-94-101

INS User Fees


Abbreviations
=============================================================== ABBREV

  EOIR - Executive Office for Immigration Review
  INS - Immigration and Naturalization Service
  JMD - Justice Management Division
  OIG - Office of Inspector General
  OMB - Office of Management and Budget

Letter
=============================================================== LETTER


B-255085

April 12, 1994

The Honorable Edward M.  Kennedy
Chairman, Subcommittee on Immigration
 and Refugee Affairs
Committee on the Judiciary
United States Senate

The Honorable Romano L.  Mazzoli
Chairman, Subcommittee on International Law,
 Immigration, and Refugees
Committee on the Judiciary
House of Representatives

The Honorable Neil Abercrombie
House of Representatives

The Honorable Gary L.  Ackerman
House of Representatives

The Honorable George E.  Brown, Jr.
House of Representatives

The Honorable Ronald D.  Coleman
House of Representatives

The Honorable Don Edwards
House of Representatives

The Honorable Eliot L.  Engel
House of Representatives

The Honorable Benjamin A.  Gilman
House of Representatives

The Honorable Marcy Kaptur
House of Representatives

The Honorable Matthew G.  Martinez
House of Representatives

The Honorable Bill Orton
House of Representatives

The Honorable Major R.  Owens
House of Representatives

The Honorable Nancy Pelosi
House of Representatives

The Honorable Charles B.  Rangel
House of Representatives

The Honorable Bill Richardson
House of Representatives

The Honorable Illeana Ros-Lehtinen
House of Representatives

The Honorable Patricia Schroeder
House of Representatives

The Honorable Charles E.  Schumer
House of Representatives

The Honorable Josï¿½ E.  Serrano
House of Representatives

The Honorable Cliff Stearns
House of Representatives

The Honorable Edolphus Towns
House of Representatives

This report responds to a joint request from two Judiciary
Subcommittee chairmen and 20 Members of Congress for information on
the Immigration and Naturalization Service's (INS) 2 major user fee
accounts--the Immigration Examinations Fee Account and the
Immigration User Fee Account.\1 The 20 Members of Congress were
particularly interested in naturalization fees, which are deposited
in the Immigration Examinations Fee Account. 

Specifically, we agreed to determine the following for both fee
accounts: 

  the method INS used to establish its fees,

  if fees reflected actual costs of providing services,

  if the expenditures from fee accounts were consistent with the
     purposes of the accounts and management and control of the fees
     were sufficient to prevent misuse of fee revenue, and

  whether staff were allocated in proportion to workload among the
     districts providing services that were financed by the fees. 

To meet the above objectives we did the following: 

  We reviewed the methodology used by INS to calculate the
     application fees in effect as of January 1994 (effective April
     1991), reviewed the legislation establishing the application and
     passenger inspection fees, and determined how some application
     fees may have changed if indirect costs were prorated. 

  We reviewed applicable legislation and guidance regarding the costs
     to be funded from the fee accounts. 

  We reviewed (1) INS expenditures to determine if in our view they
     were consistent with the purposes of the fee accounts on the
     basis of the criteria for acceptable expenditures set forth in
     the legislation governing these accounts and (2) INS procedures
     for fee collection and deposit. 

  We observed application fee collections at selected offices. 

  We collected and analyzed data on staffing and application
     inventories and determined the expected waiting times for
     processing selected types of applications and compared the
     staffing levels at airports and seaports to the number of
     inspected passengers in seven INS districts that carry out the
     most inspections. 

We conducted this review between October 1992 and January 1994 using
generally accepted government auditing standards.  In carrying out
our objectives, we used the results of recent Department of Justice
Office of Inspector General (OIG) reports.  Appendix I contains
details of our objectives, scope, and methodology.  We provided a
draft of this report to the Department of Justice for its oral
comments.  We met with its representatives, including the Acting
Executive Associate Commissioner for Management who is responsible
for the INS fee accounts.  Their comments are presented on page 25. 


--------------------
\1 INS has two other fee accounts--the Land Border Inspection and
Legalization Fee Accounts. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

INS established its application fees by identifying certain direct
labor costs for processing each type of application.  To this amount,
INS added a fixed amount to recover its indirect processing costs. 
INS then added a surcharge to each application, principally to cover
the cost of processing asylum applications for which it does not
charge a fee.  The fees are generally intended to recover full costs
by reflecting both direct and indirect costs for each application as
provided in Office of Management and Budget (OMB) guidance.  However,
in allocating indirect costs INS applied the same amount of indirect
cost to each type of application regardless of direct cost.  INS did
not prorate the indirect costs in relation to direct cost.  Prorating
the indirect costs might result in more accurately setting fees in
relation to costs.  In addition, all of the fees did not reflect full
cost because INS lowered some of the naturalization-related fees due
to concerns about fairness to aliens. 

Congress established a $5 inspection fee in 1986 and required the
Attorney General to report to Congress biennially on the fee's
adequacy and recommend any adjustment in the fee that may be required
to ensure that the receipts collected cover the cost of providing
services.  INS reviewed and reported on the adequacy of its
inspection fees in 1988, concluding that the $5 fee was adequate. 
According to INS officials, INS did not conduct the required reviews
for 1990 and 1992.  However, in response to a 1993 recommendation
from the Attorney General, the administration proposed raising the
fee to $6.  The 1994 Department of Justice Appropriation Act
increased the fee to $6. 

With respect to both application and inspection fees, we could not
determine the extent to which INS identified the full costs of
providing services because INS had not defined the specific
activities and associated costs that should be charged to the fee
accounts.  However, it appears that INS did not include all costs in
its initial fees since subsequent INS and OIG studies identified
additional costs that could have been reimbursed out of the accounts. 

On the basis of our analysis, we determined that fiscal year 1992
expenditures seemed consistent with the purposes of the accounts, and
management controls over fee revenue to prevent misuse appeared
adequate for both fee accounts.  However, INS did not properly
account for fees that it collected for another Justice office.  INS
deposited those fees into the examination fee account, and procedures
have not been established to make these funds available to that other
Justice office. 

Our analysis of INS' workload at its four largest districts showed
that INS did not allocate its adjudications and naturalization staff
in proportion to its estimated workload.  Further, in some cases the
processing time for the same application varied among those four
districts.  INS explained that significant changes in district
workloads are occurring as more work is shifted to the service
centers.  INS added that this causes temporary distortions in
district staffing levels. 

INS generally allocated staff who processed asylum applications and
inspected air and sea passengers in proportion to workload. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Two appropriation acts established INS' two major user fee accounts. 
The 1989 Department of Justice Appropriation Act established the
Immigration Examinations Fee Account\2 and provided that the account
was to be used to reimburse any appropriation for expenses in
providing immigration adjudication and naturalization services.  In
1990, Congress added a provision allowing the fees for providing
adjudication and naturalization services to be set at a level that
would ensure recovery of the full costs of providing all such
services, including the cost of similar services provided without
charge to asylum applicants or other immigrants.\3 In addition, INS
relies on 31 U.S.C.  9701, frequently referred to as the "user fee
statute,"\4 in setting fees.  The statute provides the general
authority for all agencies to assess fees. 

The Immigration Examinations Fee Account contains revenues from the
fees INS collects for processing 36 types of applications and
petitions for immigration benefits, such as naturalization and
permanent resident status.  We refer to these fees as application
fees throughout this report.  The application fees range from $30 to
$140.  (See app.  II.) Application fee revenues are to be used for
expenses in providing immigration adjudication and naturalization
services and in collecting, safeguarding, and accounting for fees. 
INS collects fees and processes applications at 4 regional service
centers and 33 district offices.  INS processes almost all
applications that require an interview with the alien (e.g.,
naturalization) at its district offices.  Generally, applications not
requiring an interview are processed at its service centers.  In
addition, INS processes applications for asylum at seven offices
nationwide.\5

Justice's Executive Office for Immigration Review (EOIR) consists
primarily of (1) immigration judges who conduct hearings to consider
aliens' applications for relief from exclusion or deportation; and
(2) the Board of Immigration Appeals, which hears appeals of
decisions by immigration judges and INS district directors.  EOIR
charges aliens fees for adjudicating their applications, and INS
collects these fees for EOIR and deposits them into the Immigration
Examinations Fee Account.  A House Report stated that it is
appropriate to reimburse EOIR from the Immigration Examinations Fee
Account for the costs associated with the adjudication and
naturalization of aliens.\6

The 1987 Department of Justice Appropriation Act established the
Immigration User Fee Account.\7 It authorized the Attorney General to
collect a $5 fee for inspection services from certain international
travelers arriving at U.S.  airports and seaports.  Ticket issuers,
such as commercial carriers and travel agents, are to collect the
fees and remit the fees to INS quarterly.  The fee proceeds are
generally to be used to pay for the costs associated with inspecting
arriving passengers.\8 The 1994 Department of Justice Appropriation
Act increased the fee to $6.\9 The conference committee expected the
increase to result in an estimated $50 million.  It expected the
Department to use the $50 million to expand and improve its ability
to prevent excludable aliens from entering the United States.\10 We
refer to these fees as inspection fees throughout this report. 

In fiscal year 1992, INS collected about $265 million from
application fees and $214 million from inspection fees, for a total
of $479 million.  These fee revenues made up approximately one-third
of INS' total budget of over $1.4 billion. 


--------------------
\2 Public Law No.  100-459, 102 Stat.  2186, 2203 (1988). 

\3 Department of Justice Appropriation Act, 1991, Public Law No. 
101-515, 104 Stat.  2101, 2121 (1990). 

\4 The statute provides for federal agencies to define special
services provided to unique segments of the population and to charge
fees for those services instead of supporting them through general
tax revenues.  Section 9701 of title 31 provides that "...  each
service or thing of value provided by an agency ...  to a person ... 
is to be self-sustaining to the extent possible." In addition, the
provision requires that each charge shall be (1) fair and (2) based
on cost to the government, and other factors. 

\5 In October 1991, the Attorney General established a separate
asylum officer corps to process asylum applications.  The offices
report directly to headquarters and, therefore, are not under the
districts' direction. 

\6 H.R.  Rep.  No.  102-918, 102d Cong., 2d Sess.  at 32 (1992). 

\7 Public Law No.  99-591, 100 Stat.  3341, 3341-53 (1986). 

\8 Revenues may also be used for pre-inspection, overtime, debt
recovery, information systems for nonimmigrant control, detection of
fraudulent documents, and providing detention and deportation
services for excludable aliens arriving on commercial aircraft and
vessels. 

\9 Public Law No.  103-121, 107 Stat.  1153, 1161 (1993). 

\10 H.R.  Conference Rep.  No.  293, 103d Cong., 1st Sess.  at 30, 31
(1993). 


   HOW FEES WERE ESTABLISHED
------------------------------------------------------------ Letter :3

In 1991 INS established most of its application fees on the basis of
the estimated cost to process the applications.  In January 1994 INS
proposed to increase some of the fees.  INS' inspection fee was
statutorily set in 1986 and increased in 1993.  INS reported to
Congress on the adequacy of its inspection fee once in 1988. 


      APPLICATION FEES
---------------------------------------------------------- Letter :3.1

INS established its current application fees in April 1991 by
calculating and adding together three cost components:  direct costs,
indirect costs, and a surcharge.  First, INS determined the direct
labor cost using the average time to process a specific type of
application.  Second, INS added a $43 charge to each application to
cover such indirect costs as supervision, management and
administration, general expenses, training, information systems,
records management, and legal proceedings.  Third, INS added a $9
surcharge to each application to cover the cost of (1) processing
refugee and asylum applications and (2) international operations. 

In the case of certain naturalization-related fees, INS set the fees
at a level lower than the original cost calculation.  For example,
INS determined the average labor cost to process an application for
naturalization was $62.  Under its normal process INS would have
added the indirect cost of $43 and the $9 surcharge for a total
charge of $114.  However, INS set the fee at $90.  According to an
INS official, while INS calculated its fees to recover full costs, it
considered the fairness and equity of the calculated fee.\11 He added
that in setting the fee for naturalization applications, INS believed
that $114 would not have resulted in a fair or equitable fee because
it could discourage aliens from applying for naturalization. 
Accordingly, INS reduced the fee by $24.\12

INS did not prorate its indirect costs.  Although direct costs varied
among application types, INS applied the same indirect cost of $43 to
each type of application.  In our view, INS' use of the fixed-dollar
method to allocate indirect costs to different types of applications
may not have resulted in an optimum measure of the total application
processing costs.  According to the Cost Accounting Standards Board's
principles, indirect costs should be prorated to cost objectives
(e.g., an application fee) in proportion to the resources consumed
(i.e., direct costs).\13 For example, INS could use direct labor
costs as the basis on which to prorate indirect costs.  Thus,
applications with higher direct labor costs would bear a larger
proportion of indirect costs than applications with lower direct
labor costs.  The reallocation of indirect costs could reduce or
increase individual application fees.  Further, this could also
result in changes to the total amount of application revenue
collected.  The Department of Justice's guidance,\14 which was issued
subsequent to INS' April 1991 fee schedule, suggests that indirect
costs be allocated on the basis of relative labor costs. 

As shown in table 1, prorating indirect costs using direct labor
costs would change some individual application fees significantly. 
Since there are various ways to prorate indirect costs, we do not
know specifically what the fees would have been if they had been
prorated.  However, we present these examples to show how the fees
established in 1991 could have changed if total indirect costs were
allocated in proportion to the direct labor cost for each
application. 



                           Table 1
           
              Revised Application Fees Based on
            Prorating Indirect Cost in Relation to
                         Direct Cost

Application (form          Fee as of     Revised
number)                    Jan. 1994       fee\a  Difference
------------------------  ----------  ----------  ----------
Extend or change              $70.00      $80.00      $10.00
 nonimmigrant status (I-
 539)
Status of alien relative       75.00      100.00       25.00
 (I-130)
Nonimmigrant worker (I-        80.00      110.00       30.00
 129)
Permanent resident            120.00      195.00       75.00
 status (I-485)
Naturalization (N-400)         90.00      195.00    105.00\b
Employment authorization       60.00       55.00      (5.00)
 (I-765)
Replace certificate of         50.00       45.00    (5.00)\b
 naturalization (N-565)
Replace alien                  70.00       60.00     (10.00)
 registration receipt
 card (I-90)
Re-entry permit (I-131)        65.00       50.00     (15.00)
------------------------------------------------------------
\a Rounded to the nearest $5.00. 

\b Differences were determined on the basis of the charged fee, not
on INS' calculated costs.  As previously discussed, the INS charges
for some applications are lower than the calculated costs. 

Source:  GAO analysis of INS data. 

In discussing a draft of this report, INS officials agreed that INS
needs to reexamine the method it uses to allocate its indirect costs. 
According to INS officials, INS plans to revise its fee-setting
methodologies to ensure that fees are set fairly and reasonably. 


--------------------
\11 The individual requesting Members asked whether or not INS
determined the impact of Executive Order 12606 (September 2, 1987) in
setting naturalization fees.  The order provides that when
formulating and implementing policies and regulations that may have
significant impact on family formation, maintenance, and general
well-being, agencies must assess whether the proposed actions
increase or decrease family earnings and whether the anticipated
benefits justify the impact on the family budget.  According to INS
officials, this order was not explicitly considered when the fees
were set in 1991.  However, they said that INS considers the general
impact of its fees on applicants and can reduce the fees to levels
below full costs when it considers them to be unfair. 

\12 INS does have discretion in setting fees.  Section 1356(m) of
title 8 indicates that fees for providing adjudication and
naturalization "may" be set at a level that will ensure recovery of
full costs of providing such services.  INS is not mandated to set
the fees at such a level.  In addition, the user fee statute, 31
U.S.C.  9701, requires that user fees be "fair." Therefore, the
setting of such fees is not based solely on the cost to the
government.  As the U.S.  District Court for the District of Columbia
stated in Ayuda v.  Attorney General, 661 F.  Supp.  33, 36 (D.D.C. 
1987), a user fee need only bear a reasonable relationship to the
cost of the services rendered by the agency. 

\13 Federal Cost Accounting Standards, developed by the Cost
Accounting Standards Board under the purview of OMB's Office of
Federal Procurement Policy, apply only to federal negotiated
contracts.  However, we believe they are relevant by analogy to
determining indirect costs for the INS fees here involved. 

\14 U.  S.  Department of Justice, Justice Management Division, User
Fee Programs, April 1993. 


      PROPOSED APPLICATION FEE
      INCREASE
---------------------------------------------------------- Letter :3.2

In January 1994 INS proposed changes for 30 application fees to cover
the costs of providing services.\15 It determined that generally a
7.5-percent increase is needed.  For 15 fees, including
naturalization, the proposed increase is $5.  The largest proposed
increase of any of the fees is $25.  Subsequently, a Department of
Justice official said that INS will propose a fee for asylum
applications. 

INS pointed out that future adjustments will reflect efforts to
refine direct and indirect cost definitions and measurements and will
address alternative approaches to the allocation of indirect costs
among applicants for services. 


--------------------
\15 Federal Register, Vol.  59, No.  6, Monday, January 10, 1994,
1308. 


      INSPECTION FEE
---------------------------------------------------------- Letter :3.3

The 1987 Department of Justice Appropriation Act established a $5
inspection fee for individuals aboard commercial aircraft and vessels
who arrive at a port of entry in the United States or who are
inspected outside the United States prior to their arrival.\16 The
legislation requires the Attorney General to report to Congress
concerning the adequacy of the fee every 2 years and to recommend to
Congress any adjustments to ensure that receipts equal as closely as
possible the cost of providing the services. 

INS first reviewed the Immigration User Fee Account in 1988 and
published its report in the Federal Register.\17 However, according
to INS officials, INS did not conduct the 1990 and 1992 biennial
reports for the Immigration User Fee Account.  The administration
proposed raising the fee to $6 on the basis of a 1993 recommendation
by the Attorney General.  Justice Management Division (JMD) officials
we spoke with were unaware of the requirement for a biennial report. 
JMD guidance on user fees issued in April 1993 requires JMD to review
all Department fees at least once every 2 years. 


--------------------
\16 The 1994 Department of Justice Appropriation Act increased the
fee to $6. 

\17 The 1988 INS report stated that the $5 fee was adequate. 


   FEES MAY NOT COVER ALL COSTS OF
   PROVIDING SERVICES
------------------------------------------------------------ Letter :4

The user fee statute, as well as OMB and Justice Department guidance,
states that user fee programs are intended to be
"self-sustaining."\18 The general policy is that fees should be set
at levels to recover full costs to the federal government of
rendering a service that provides specific benefits to an
identifiable recipient above and beyond those that accrue to the
public at large.  However, the user fee statute also requires the
fees to be fair to the recipients. 

We could not determine the extent to which INS application and
inspection fees reflected the relevant costs of providing services
because INS had not clearly defined the specific activities that
should be funded by the fee accounts.  For example, INS had not
determined which types of enforcement activities and associated costs
should be funded by the Immigration Examinations Fee Account. 
Enforcement-related expenditures had been approved on a case-by-case
basis, but INS had not defined the specific types of enforcement
activities that are properly funded by the fee account. 

INS and OIG studies have stated that user fees were not adequate to
recover full costs and should be raised.  A 1992 INS study estimated
that in fiscal year 1993, $35 million in costs that should have been
funded by application fees would instead be funded by INS' basic
appropriation.  The study recommended increases in application fee
revenues to cover program costs.  The study also estimated that an
additional $11 million would be needed to cover inspection fee
program costs and recommended a $1 increase in the inspection fee.  A
December 1992 OIG report recommended that INS identify all user fee
program costs to be charged to the fee accounts and revise fees to
recover the full costs of providing services.\19 The inspection fee
was increased to $6 by Justice's 1994 Appropriation Act. 

In addition, some INS managers told us that their units provided more
fee-related services than were funded from the fee accounts.  For
example, an official in the Administrative Services Unit estimated
that about 35 percent of its costs were related to application or
inspection fee programs and therefore properly chargeable to the fee
accounts.  However, only 17 percent of the unit budget was funded by
the fee accounts. 


--------------------
\18 31 U.S.C.  9701, OMB Circular A-25, User Charges, July 1993; and
User Fee Programs, Justice Management Division, April 1993. 

\19 Department of Justice, Office of Inspector General, Audit
Division, Controls Over Established User Fee Accounts in the
Immigration and Naturalization Service, December 1992. 


      INS WORKING TOWARDS
      IDENTIFYING FULL PROGRAM
      COSTS
---------------------------------------------------------- Letter :4.1

INS plans to determine the full cost of providing fee-related
services.  In October 1992, INS established a Fee Analysis and
Operations Branch within its Office of Finance.  Its primary mission
is to develop policies and procedures to ensure that fees are
sufficient to cover associated costs.  Its responsibilities also
include developing policy guidance for INS program managers on
preparing budgets for fee-supported activities; developing policies
for measuring the cost of fee-supported activities; and establishing
cost accounting, workload, and performance measures for fee-related
activities.  As of December 1993, this office was working with INS
program managers to determine methods to identify and measure the
specific costs to be charged to the fee accounts. 


   FEE ACCOUNT BUDGETS HAVE GROWN
   SINCE FISCAL YEAR 1990
------------------------------------------------------------ Letter :5

The budgets for both fee accounts have grown significantly over the
past 3 fiscal years.  Appendix III presents both fee account budgets
by INS unit from fiscal year 1990 to 1993. 


      SUPPORT COSTS IN THE
      IMMIGRATION EXAMINATIONS FEE
      ACCOUNT HAVE GROWN
---------------------------------------------------------- Letter :5.1

Each year, support unit costs have made up a larger portion of the
Immigration Examinations Fee Account budget.  Figure 1 illustrates
the growth in support unit costs budgeted to the fee account.  This
growth is due to (1) the identification of additional support costs
that should be paid out of the account; (2) increases in program
costs, including support costs; and (3) the policy not to charge
asylees and refugees for their initial applications but to pay for
the costs out of the account.  For example, in fiscal year 1990, the
Information and Records Management Unit accounted for about 2 percent
of the budget.  In 1993, this unit accounted for 17 percent of the
budget.  The budget for the Adjudication and Naturalization Unit, the
primary unit responsible for application processing, has grown at a
much smaller rate. 

   Figure 1:  Support Units Made
   Up a Larger Portion of the
   Examinations Fee Account Budget
   Each Year

   (See figure in printed
   edition.)

Note:  Support units include Administrative Services, Executive
Direction, Field Management and Support, Intelligence, Legal
Proceedings, Investigations, Training, Data and Communications,
Information and Records, and Construction and Engineering. 

Source:  GAO analysis of INS data. 

INS officials told us that since implementing the user fee programs,
INS has identified additional support costs that are more properly
charged to the Immigration Examinations Fee Account rather than to
INS' basic appropriations.  For example, INS began charging the costs
associated with training adjudications and naturalization personnel
to the Immigration Examinations Fee Account in fiscal year 1992. 
However, INS has not completely identified all of the costs that are
properly chargeable to the fee account, according to INS officials. 

In addition to support unit costs growing, the asylum and refugee
programs have increased program costs.  In fiscal year 1991, at
congressional committee direction, INS began charging all costs for
the International Affairs and Outreach Unit's program, which
processes asylum and refugee applications, to the Immigration
Examinations Fee Account rather than to appropriations.\20 In fiscal
year 1991, the unit's budget was about $25 million from this account;
in fiscal year 1992, its budget grew to over $35 million.  For both
years the unit's budget accounted for about 13 percent of the
Immigration Examinations Fee Account budgets. 

In connection with a 1992 review of the fee accounts, INS program
officials asked the INS Office of General Counsel whether the unit's
program expenses other than those associated with adjudication or
naturalization could be reimbursed from the Examinations Fee Account
under 8 U.S.C.  1356(n).\21 The Office of General Counsel concluded
that such expenses are not reimbursable under the terms of 8 U.S.C. 
1356(n), even though committee report language indicated an intent
that the full costs of the unit's program be funded by the
Examinations Fee Account. 

On the basis of the advice of the INS Office of General Counsel, INS
plans to analyze the expenses incurred by the unit to determine if
any expenses are outside the scope of those properly reimbursable
under the statute.  If so, INS plans to seek an amendment to section
1356(n) to authorize reimbursement from the fee account for all the
unit's activities. 

On July 27, 1993, the President announced his intention to increase
the number of asylum officers and to expedite the asylum process.  As
of December 1993, INS did not know what impact this decision might
have on program costs and other application fees. 


--------------------
\20 S.  Rep.  No.  515, 101st Cong., 2d Sess.  at 50 (1990). 

\21 The statute provides that the Examinations Fee Account may be
used to reimburse costs associated with "adjudication and
naturalization services" and "similar services provided without
charge to asylum applicants or other immigrants." The statute also
provides for reimbursement of expenses associated with administration
of the fees collected.  8 U.S.C.  1356(m) and (n). 


      IMMIGRATION USER FEE ACCOUNT
---------------------------------------------------------- Letter :5.2

The budget associated with the Immigration User Fee Account increased
about $137 million between 1990 and 1993, from $104 million to $241
million (see app.  III).  Nearly two-thirds of this increase was due
to growth in the Inspections Unit budget, which increased $87 million
over this 3-year period.  Over 80 percent of the remaining increase
of $50 million was due to growth in the budgets of three other INS
units--Detention and Deportation ($25 million), Data and
Communications ($11 million), and Administrative Services ($6
million).  In fiscal year 1993, these four units made up 94 percent
of the Immigration User Fee Account budget. 


   EXPENDITURES SEEMED APPROPRIATE
   AND MANAGEMENT CONTROLS
   GENERALLY APPEARED ADEQUATE
------------------------------------------------------------ Letter :6

For both fee accounts, INS expenditures seemed consistent with the
purposes of the accounts, and management controls over fee revenue to
prevent misuse generally appeared adequate.  However, INS has not
properly accounted for fees that it collected for EOIR. 

In December 1992, the OIG reported that adequate controls were in
place to ensure that only valid program costs were charged to the
user fee accounts.\22 The OIG reviewed selected fiscal year 1991
expenditures and determined that INS used the fee revenues for their
intended purposes.  In addition, we reviewed all fiscal year 1992
expenditures from both fee accounts.  Our review did not reveal any
expenditures that were inconsistent with the purposes of the funds. 
In doing our review, we asked INS to explain the basis for some of
its expenditures.  In those cases, INS' rationale seemed reasonable. 

To evaluate the management controls, we followed up on fee-related
weaknesses discussed in our prior report.\23 We found that INS
improved its fee collection and deposit procedures.  For example, INS
revised its procedures to prohibit INS staff from sending cash
through the mail.  Procedures now require that application fee
deposits be made daily through commercial lockboxes.  Our review of
application fee revenue collection and deposit procedures at INS' Los
Angeles and Washington Districts and Western Service Center indicated
these procedures were being followed.  With regard to inspection
fees, beginning in fiscal year 1992, INS and the U.S.  Customs
Service instituted joint audits of commercial carriers to ensure they
remit the proper amount of inspection fee revenue. 


--------------------
\22 Department of Justice, Office of Inspector General, Audit
Division, Controls Over Established User Fee Accounts in the
Immigration and Naturalization Service, December 1992. 

\23 Financial Management:  INS Lacks Accountability and Controls Over
Its Resources (AFMD-91-20, Jan.  24, 1991). 


   IMPROVEMENT NEEDED IN
   ACCOUNTING FOR EOIR FEES
------------------------------------------------------------ Letter :7

One area needing improvement is INS' collection and disbursement of
EOIR fees.  In the conference report for the 1993 Justice
Appropriations Act, the conferees stated that it is appropriate to
reimburse EOIR from the Examinations Fee Account for the cost
associated with the adjudication and naturalization of aliens.\24

INS does not identify the fees it collects for EOIR but deposits them
with its own fee receipts in the Immigration Examinations Fee
Account.  Once deposited, the EOIR fees cannot be separately
identified.  Consequently, INS cannot determine the amount of EOIR's
fees it collected and the amount that it can make available to EOIR. 

Our analysis of completed cases for fiscal years 1989 through 1992
indicated that EOIR could have received more funds from INS than it
actually did.  We estimated EOIR's fee revenue using a schedule of
EOIR completed applications for this period.  The total applications
by type were multiplied by the fee in effect for each year.  Adding
the total annual revenue for those years indicated that INS collected
about $9 million in EOIR fees.  In April 1993, when we did our
analysis, INS had reimbursed EOIR $615,000 for those years.\25

In addition, INS and EOIR do not have policies or procedures for
managing these funds.  For example, there are no policies or
procedures for identifying all EOIR fees when they are received, when
and how often INS should transfer these funds to EOIR, or whether INS
should charge EOIR an administrative fee for collecting the funds and
expenses associated with INS trial attorney functions performed in
connection with EOIR adjudication and naturalization activities. 


--------------------
\24 H.R.  Rep.  No.  102-918, 102d Cong., 2d Sess.  at 32 (1992). 

\25 In fiscal year 1993, INS reimbursed EOIR $550,000. 


   ALLOCATION OF STAFF
------------------------------------------------------------ Letter :8

INS did not allocate its adjudications and naturalization staff in
proportion to its estimated workload at its four largest districts. 
In addition, expected application waiting times varied among
districts in some cases.  Generally, INS allocated staff who process
asylum applications in its seven offices and staff who inspect air
and sea passengers in seven districts in proportion to workload. 


      ADJUDICATION AND
      NATURALIZATION STAFF
---------------------------------------------------------- Letter :8.1

INS used a staffing model to determine the appropriate number of
adjudication and naturalization staff for each district.  The
staffing model determines the needed staff to process application
workload using such factors as estimated workload and application
processing times.  However, some districts received a greater
percentage of their staff on the basis of the model than others.  As
shown in table 2, for the four districts we reviewed, funded
positions ranged from 71 percent to 92 percent of the staffing model. 



                           Table 2
           
            Staffing Model and Funded Staff at the
            Largest Four Districts in Fiscal Year
                             1993


                                           Funded as percent
District                 Model    Funded            of model
--------------------  --------  --------  ------------------
Los Angeles                237       211                 89%
New York                   237       168                 71%
Miami                      153       140                 92%
San Francisco              137       115                 84%
------------------------------------------------------------
Source:  GAO analysis of INS data. 

An INS official told us that INS does not want to fund the model
number of positions at districts in all cases because it is planning
to reduce district workload.  According to the official, once staff
are assigned to a location, it is difficult to transfer them should
the workload decrease.  The official added that INS is working
towards centralizing its application processing operations at the
four large service centers.  INS is shifting most of its application
processing workload from the districts to the service centers, and in
doing so changing the district workloads significantly.  This shift,
according to INS, is causing distortions in district staffing levels. 

On February 3, 1994, the INS Commissioner announced efforts to
promote naturalization through education and to streamline INS'
procedures and processes.  Appropriated funds of $30 million have
been requested for these efforts. 


      APPLICATION PROCESSING
      WAITING TIMES
---------------------------------------------------------- Letter :8.2

As a way of gauging the overall impact of staff allocations, we
determined expected application waiting times on the basis of INS'
workload and application processing times.  INS' goal is to process
all applications within 4 months.  In our analysis of waiting times
for selected applications and locations as of February 1993, we
determined that about 80 percent of applicants could expect to wait 4
months or less for their applications to be processed (see fig.  2). 
Our analysis included selected applications at the four service
centers and the four districts receiving the most applications (Los
Angeles, New York, Miami, and San Francisco.) See appendix I for the
specific applications included in our analysis. 

   Figure 2:  Most Applicants
   Would Wait 4 Months or Less

   (See figure in printed
   edition.)

Note 1:  This represents 55.5 percent of total INS initial
application receipts in the first 5 months of fiscal year 1993. 

Note 2:  Our sample included 76.9 percent of the initial application
receipts at the four service centers and the largest four districts. 
These entities received 72.1 percent of total INS application
receipts. 

Source:  GAO analysis of INS data. 

INS' use of the four service centers to process applications has
helped it to meet its 4-month goal, and the centers are processing a
larger proportion of applications.  For example, in fiscal year 1990,
service centers processed 31 percent of all new applications.  As of
February 1993, the service centers received 48 percent of all new
applications.  On the basis of our analysis of selected applications,
those applicants whose requests were processed by the service center
as of February 1993 had expected waiting times of less than 4 months. 

While a majority of all INS applicants in our analysis would expect
to wait 4 months or less, expected waiting times for some
district-processed applications were longer.  Also, expected waiting
times varied among districts for the same applications.  For example,
as of February 1993, expected waiting times for naturalization
applications ranged from about 3 to 14 months at the four districts
selected.  Expected waiting times for permanent resident status
applications ranged from about 5 to 10 months (see figs.  3 and 4). 

INS officials told us that waiting times for naturalization
applications had changed in two districts as of August 1993.  In New
York the waiting time increased from 3 to 7 months.  In San
Francisco, the waiting time decreased from 14 to 10 months.  The
waiting times did not change for Los Angeles and Miami. 

   Figure 3:  Naturalization
   Applications Would Take
   Generally Longer Than 4 Months
   but Varied Among Districts

   (See figure in printed
   edition.)

Note:  As of February 1993. 

Source:  GAO analysis of INS data. 

   Figure 4:  Permanent Resident
   Status Applications Would Take
   Longer Than 4 Months but Varied
   Among Districts

   (See figure in printed
   edition.)

Note:  As of February 1993. 

Source:  GAO analysis of INS data. 

INS officials cited several reasons why district processing took
longer than the service centers.  Generally, service centers were
more efficient because of enhanced automation and the economies of
scale realized through centralized processing.  Also, as INS shifted
workload from the districts to the service centers, the districts
were left with the applications that took longer to process, such as
naturalization, which required applicant interviews.  In addition,
the New York and Los Angeles districts received a larger number of
applications for special programs such as temporary protected status
for El Salvadorans.\26


--------------------
\26 Nationals from certain countries with political or social unrest
may apply for temporary protected status.  An alien who qualifies may
be granted a temporary stay of deportation and work authorization (8
U.S.C.  Section 1254a). 


      ASYLUM STAFF
---------------------------------------------------------- Letter :8.3

Our review of INS staffing at its seven asylum offices showed that it
allocated staff roughly in proportion to actual workload, as shown in
table 3.  As of March 1993, the seven offices had filled over 80
percent of their authorized positions. 



                           Table 3
           
            Comparison of Application Receipts and
                  Authorized Asylum Staffing

                              Percent of
                        applications (FY    Percent of staff
Offices                            1992)        (as of 3/93)
--------------------  ------------------  ------------------
Los Angeles                           40                  35
San Francisco                          8                  12
Houston                                3                   4
Chicago                                4                   5
Miami                                 15                  15
Newark                                23                  15
Arlington                              8                  13
------------------------------------------------------------
Note:  Percents do not total 100 due to rounding. 

Source:  GAO analysis of INS data. 

Since fiscal year 1989, application backlogs have increased
dramatically while application processing has lagged (see fig.  5). 

   Figure 5:  Asylum Application
   Backlog Has Increased
   Dramatically

   (See figure in printed
   edition.)

Note:  INS estimated 1993 data. 

Source:  GAO analysis of INS data. 

An INS official told us that without any staff increase, INS expected
to process about one-third of the total applications received in
fiscal year 1993.  Consequently, INS expected the asylum backlog to
increase to nearly 300,000 by the end of fiscal year 1993, a
threefold increase since 1990.  At the fiscal year 1993 staffing
level and completion rate of about 40,000 applications per year, INS
would take over 7 years just to eliminate the existing backlog and
not process any new applications. 

On July 27, 1993, President Clinton announced that the Department of
Justice and INS would develop a plan to reduce the asylum application
backlog.  On February 3, 1994, the Commissioner of INS announced a
comprehensive reform of asylum.  She said the soon-to-be published
regulations, coupled with $54.1 million in additional resources, will
establish a fair, timely asylum decision system.  The funds are to be
used to increase the number of asylum officers, immigration judges,
and adjudication attorneys.  According to INS, this will enable INS
to become current with new applications and to handle the backlogged
cases.  The $54.1 million is included in the fiscal year 1995 budget
request. 


      INSPECTIONS STAFF
---------------------------------------------------------- Letter :8.4

INS used computer staffing models to determine the number of
inspections staff needed at airports and seaports.  The airport
staffing model takes into account the number of anticipated passenger
arrivals and the need to process passengers within 45 minutes, as
required by law.\27

As shown in table 4, INS staffing and workload at airports and
seaports in the seven INS districts that inspect the largest number
of passengers showed that INS allocated its inspection staff
approximately in proportion to its actual workload.  During fiscal
year 1992, INS' seven busiest districts performed about two-thirds of
all air and sea passenger inspections.  As of June 1993, these
districts had about two-thirds of the authorized staff. 



                           Table 4
           
           Comparison of Inspections and Authorized
                            Staff

                      Percent of air and          Percent of
                         sea inspections          authorized
INS district                   (FY 1992)        staff (6/93)
--------------------  ------------------  ------------------
Miami                                 20                  16
New York                              14                  18
Los Angeles                           10                   9
Buffalo                                8                   6
Honolulu                               7                   8
Chicago                                4                   4
San Francisco                          4                   4
------------------------------------------------------------
Source:  GAO analysis of INS data. 

According to an INS report, as of July 1993 airport inspectors were
processing more than 98 percent of arriving passengers within the
45-minute standard. 


--------------------
\27 8 U.S.C.  1356(g). 


   CONCLUSIONS
------------------------------------------------------------ Letter :9

We believe that INS could improve its method of allocating indirect
costs in establishing its application fees.  Individual application
fees might better reflect actual processing costs if indirect costs
were allocated in proportion to direct costs. 

We could not determine the extent to which the current application
and inspection fees reflected the actual costs of providing services
because INS had not identified all costs to be charged to the two fee
accounts.  INS is aware of this problem and is in the process of
identifying and measuring the specific costs that should be charged
to the fee accounts. 

Management controls to prevent misuse of fee revenues appeared
adequate.  However, INS needs to account for the EOIR fee revenue it
collects.  To ensure EOIR fee revenues are appropriately made
available to EOIR, the Department of Justice needs to develop
procedures to reimburse EOIR. 

Although adjudications and naturalization staff allocations to the
four largest districts were not in proportion to current estimated
workloads, most applications in our analysis would be processed
within INS' goal of 4 months.  Generally, asylum staff at the seven
asylum offices and inspections staff were allocated according to
workload. 

At fiscal year 1993 levels of asylum application receipts and
resources, INS could take over 7 years to process the existing
backlog.  Since the asylum program was funded from application fee
revenue, providing additional resources to reduce the existing
backlog could contribute to an increase in the application fees. 
This increase could be offset if funds for additional resources were
provided from other sources, such as appropriated funds or fees
charged for asylum applications. 


   RECOMMENDATIONS
----------------------------------------------------------- Letter :10

In order to improve the methods INS uses to set its applications fee
schedule, we recommend that the Attorney General direct the INS
Commissioner to select a method that allocates indirect costs among
application types such as in proportion to direct costs rather than
using the fixed-dollar method that INS presently uses. 

We also recommend that the Attorney General establish policies and
procedures for (1) accounting for the EOIR fee revenues INS collects
and (2) making these funds available to EOIR, as appropriate. 


   AGENCY COMMENTS
----------------------------------------------------------- Letter :11

On March 7, 1994, we discussed a draft of this report with Department
of Justice, EOIR, and INS officials, including two associate
commissioners.  They agreed with our findings, conclusions, and
recommendations and provided clarifications and technical
corrections, which we included in the report.  In a subsequent letter
dated March 11, 1994, (see app.  IV) the Commissioner of INS added
that INS intends to procure an assistance and advisory services
contract to address fee-setting and fee structures. 


--------------------------------------------------------- Letter :11.1

We are providing copies of this report to the Attorney General,
Commissioner of INS, Director of OMB, and other interested parties. 
Copies will also be made available to others upon request.  Major
contributors to this report are listed in appendix V.  If you need
any additional information or have any further questions, please
contact me on (202) 512-5156. 

Henry R.  Wray
Director, Administration
 of Justice Issues


OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix I

This report responds to 2 separate requests for information on INS
user fees:  1 from 2 Judiciary Subcommittee Chairmen and 1 from 20
Members of Congress who were specifically interested in
naturalization fees.  Naturalization fee revenues are included in the
Immigration Examinations Fee Account and are not accounted for
separately.  Therefore, we combined the request from the 20 Members
into our review of the fee accounts.  Throughout this report we
provided examples using naturalization fees in instances where
applicable.  The 20 requesters agreed that this report would satisfy
their request. 

Our objectives were to determine (1) the method INS used to establish
its fees, (2) whether fees reflected actual costs of providing
services, (3) whether the expenditures from fee accounts were
consistent with the purposes of the accounts and management and
control of the fees were sufficient to prevent misuse of fee revenue,
and (4) whether staff were allocated in proportion to workload among
the districts providing services that were financed by the fees. 

To meet the above objectives we did the following: 

(1) We reviewed the methodology INS used to calculate the application
fees in effect as of January 1994 (effective April 1991). 
Documentation for prior fee calculations was not available from INS. 
We reviewed the legislation establishing the application and
passenger inspection fees.  To determine how some application fees
may have been affected if indirect costs were prorated, we used the
direct salary cost for each application and total indirect costs
determined by INS when it calculated applications fees in 1991.  We
divided total indirect costs by total direct salary costs to
determine a rate for applying indirect cost to direct salary cost. 
The calculated rate was $3.25.  We then applied that rate ($3.25 of
indirect cost to each dollar of direct salary cost) to individual
types of applications to arrive at the revised fees. 

(2) We reviewed applicable legislation and guidance regarding the
costs to be funded from the fee accounts.  We reviewed a May 1992 INS
study that estimated the costs properly chargeable to the fee
accounts.  We also reviewed relevant OIG reports and discussed the
findings of one report with the auditors who performed the work. 

(3) We determined if expenditures, in our view, were consistent with
the purposes of the fee accounts on the basis of the criteria for
acceptable expenditures set forth in the legislation and guidance
governing these accounts.  We reviewed (a) the legislation governing
the fee accounts to determine the criteria for acceptable
expenditures and (b) all fiscal year 1992 expenditures for the fee
accounts.  Since INS had not clearly defined the specific activities
that should be funded from the fee accounts, we used our own
judgment.  We asked INS to explain the basis for some expenditures
and we analyzed its responses.  In its report for fiscal year 1991
expenditures for both accounts, OIG did not question any of the
expenditures. 

We interviewed INS officials to determine procedures for authorizing
expenditures from the fee accounts.  We reviewed INS procedures for
fee collection and deposit and observed application fee collections
at the Washington District, the Los Angeles District (the largest
district in terms of application receipts), and the Western Service
Center. 

At EOIR we obtained data on applications processed by EOIR and fee
revenues reimbursed to EOIR by INS.  We did not (a) review the basis
on which EOIR's fees were set or (b) determine how EOIR used the
funds that INS provided or the impact on its appropriations.  This
was not part of the request. 

In addressing this objective, we also reviewed the same OIG reports
and followed up on fee-related weaknesses discussed in our prior
report. 

(4) We collected and analyzed data on staffing and application
inventories at the four INS districts receiving the most applications
(Los Angeles, New York, Miami, San Francisco) and application
inventories at the four service centers (Western Service Center in
Laguna Niguel, CA; Northern Service Center in St.  Paul, MN; Southern
Service Center in Dallas, TX; and Eastern Service Center in
Burlington, VT).  These four districts and four service centers
processed about 70 percent of all INS applications for the first 5
months of fiscal year 1993.  We determined the expected waiting times
for processing six types of applications at the districts (I-90,
I-130, I-485, I-539, I-765, and N-400) and four types of applications
at the service centers (I-90, I-130, I-140, and I-765).  (See app. 
II for application descriptions and fees.) These applications
represented over 90 percent of all applications filed at the four
districts and about 70 percent at the four service centers. 

We defined expected application waiting time as the number of months
it would take to process the ending inventory on the basis of the
average number of monthly completions for the first 5 months of
fiscal year 1993.  For example, if the ending inventory for a
particular application type was 10,000 and that district or service
center was processing an average of 2,000 applications per month, we
assumed it would take INS 5 months to complete the backlog.  Our
calculation assumed a steady stream of application receipts and that
INS processed applications on a first-in, first-out basis. 
Individual application waiting times may have varied from our
calculated expected waiting times.  We categorized the number of
applicants for each type of application as waiting 4 months or less,
4.1 to 8.0 months, and more than 8 months, on the basis of the
expected waiting times we computed.  We calculated the number of
applicants in each category to arrive at an overall percentage for
the category. 

To analyze the staffing levels allocated to process application
workloads, we compared the staffing levels, as determined by INS'
staffing model, with funded positions in the four district offices. 
We did not evaluate the model because we were not asked to determine
the accuracy of its staffing estimates. 

For asylum processing, we compared the staffing for all seven offices
(Los Angeles, San Francisco, Houston, Chicago, Miami, Newark, and
Arlington, VA) with the number of applications received at each
office.  By doing this we could determine if INS allocated staff in
relationship to workload.  We also determined the changes in the
inventory of unprocessed applications between fiscal years 1985 and
1993.  We also computed the time needed to eliminate the application
backlog at the March 1993 staffing level and completion rates. 

We compared the staffing levels at airports and seaports in the seven
INS districts that inspect the largest number of passengers to the
number of inspections carried out. 

In addition, we interviewed INS officials at INS headquarters who
were responsible for setting and managing the fees, as well as
various unit program managers who were responsible for allocating fee
revenues to the various districts and service centers providing
services. 

Subsequent to our review, INS proposed an increase to some of its
application fees in January 1994.  We did not evaluate the basis on
which INS proposed to revise its fees.  On February 1, 1994, the
Department of Justice announced a reorganization proposal that
affects some of the units discussed in our report.  We did not revise
the report to reflect this change because it does not affect our
message. 

We did our work from October 1992 through January 1994 in accordance
with generally accepted government auditing standards.  We did not
verify data we obtained from INS.  After providing the Department of
Justice a draft of this report for comments, we met with officials
from the Department of Justice, including INS and EOIR, who provided
oral comments.  The INS officials included an Acting Associate
Commissioner for Management, who is responsible for the fee accounts. 
Their comments have been incorporated into the report. 


INS APPLICATION FEES SCHEDULE
========================================================== Appendix II

                                          Form        Fee as
                                          number(s   of Jan.
Application description                   )             1994
----------------------------------------  --------  --------
School approval                           I-17      $ 130.00
Replace alien registration receipt card   I-90         70.00
Replace arrival-departure record          I-102        50.00
Nonimmigrant worker petition              I-129        70.00
Classify nonimmigrant as fiancee or       I-129F       75.00
 fiance
Classify status of alien relative for     I-130        75.00
 issuance of immigrant visa
Issuance of reentry permit                I-131        65.00
Classify preference status of an alien    I-140        70.00
 on basis of
 profession or occupation
Advance permission to return to           I-191        90.00
 unrelinquished domicile
Exercise of discretion                    I-192        85.00
Waiver of passport and/or visa            I-193        90.00
Permission to reapply for excluded or     I-212        90.00
 deported alien
Appeal from decision                      I-290A      110.00
                                           I-290B
Special immigrant petition                I-360        75.00
Permanent resident status                 I-485     120.00\a
                                           I-
                                           485A\b
Alien entrepreneur                        I-526       140.00
Extend or change nonimmigrant status      I-539        70.00
Issuance or extension of refugee travel   I-570        45.00
 document
Classify orphan as an immediate relative  I-600       140.00
Advance processing of orphan petition     I-600A      140.00
Waiver of ground of excludability         I-601        90.00
Waiver of foreign-residence requirement   I-612        90.00
Remove conditions on residence based on   I-751        75.00
 marriage
Waiver of requirement to file joint       I-752        85.00
 petition for removal of conditional
 basis of residency
Employment authorization                  I-765        60.00
Voluntary departure under family unity    I-817        75.00
Temporary protected status                I-821      50.00\c
Action on an approved application or      I-824        30.00
 petition
Declaration of intention to naturalize    N-300        70.00
Request for hearing on a decision in      N-336       110.00
 naturalization proceedings
Naturalization                            N-400        90.00
Benefits                                  N-470        90.00
Replace certificate of naturalization     N-565        50.00
Certificate of citizenship                N-600        90.00
Certificate of citizenship on behalf of   N-643        85.00
 an adopted child
Posthumous citizenship                    N-644        60.00
------------------------------------------------------------
\a $95.00 for applicants under age 14. 

\b Cuban refugees file form I-485A. 

\c Nationals of El Salvador pay $75.00.  Family maximum of $225.00. 

Sources:  Code of Federal Regulations, January 1, 1993, and INS. 


FEE ACCOUNT BUDGETS BY UNIT
========================================================= Appendix III



                                   Table III.1
                     
                       Immigration Examinations Fee Account
                        Budget, Fiscal Years 1990 to 1993

                              (Dollars in Thousands)


                                                                          Budget
                      Reprogramm          Reprogramm          Reprogramm  reques
Unit          Budget          ed  Budget          ed  Budget          ed       t
------------  ------  ----------  ------  ----------  ------  ----------  ------
Adjudication  $81,21     109,078  $79,38    $116,387  $121,8    $149,199  $151,0
 s and             2                   6                  31                  58
 Naturalizat
 ion
Information    1,925       2,982   1,925       4,936   9,866      21,503  57,189
 and Records
 Mgmt.
Data and       1,189       4,500   8,689      31,900  31,744      40,342  49,916
 Communicati
 ons
Administrati                 556                 702     731      13,382   7,490
 ve Services
Legal                      1,779               2,379   2,477       2,477   3,071
 Proceedings
Intelligence                 200                 338     352         654     539
Internationa                                  24,676  29,915      35,231  39,422
 l Affairs
 and
 Outreach
Inspections                                                        2,436   8,685
Investigatio                                                       1,697   7,278
 ns
Training                                                           2,363   3,070
Field                                                                850   1,399
 Management
 and Support
Construction                                                         173     173
 and
 Engineering
Executive                                                             75      75
 Direction
 and Control
================================================================================
Total         $84,32    $119,095  $90,00    $181,318  $196,9    $270,382  $329,3
                   6                   0                  16                  65
--------------------------------------------------------------------------------
Source:  INS. 



                                   Table III.2
                     
                       Immigration User Fee Account Budget,
                          Fiscal Years 1990 through 1993

                              (Dollars in Thousands)


                                                                          Budget
                      Reprogramm          Reprogramm          Reprogramm  reques
Unit          Budget          ed  Budget          ed  Budget          ed       t
------------  ------  ----------  ------  ----------  ------  ----------  ------
Inspections   $65,17     $77,148  $74,55    $104,365  $123,3    $130,571  $152,4
                   5                   4                  51                  85
Detention     12,309      12,723  12,892      21,946  30,282      33,882  37,607
 and
 Deportation
Data and      17,858      18,112  18,354      21,572  28,112      30,250  28,850
 Communicati
 ons
Administrati   1,701       1,046   1,060       3,277   3,878       6,649   8,118
 ve Services
Anti-          1,526       1,244   1,377       1,240   1,720       2,072   3,481
 Smuggling
Intelligence   1,237         400     405         365   1,588       1,709   1,821
Legal          2,206       2,206   1,068       1,544   1,600       1,600   1,937
 Proceedings
Information       --          --      --          --      --         838   1,419
 and Records
 Mgmt.
Investigatio     889         736     912         566   1,005       1,005   1,414
 ns
Training         177         485     491         494     502       1,877   2,962
Field             --          --      --         182     247         247     263
 Management
 and Support
Internationa     247         250     255         226      --          --     255
 l Affairs
 and
 Outreach
Executive        106          50      51         146     200         200     211
 Direction
 and Control
Construction      99          50      51          75      94          94     125
 and
 Engineering
================================================================================
Total         $103,5    $114,450  $111,4    $156,000  $192,5    $210,994  $240,9
                  30                  70                  79                  48
--------------------------------------------------------------------------------
Source:  INS. 




(See figure in printed edition.)Appendix IV
COMMENTS FROM THE IMMIGRATION AND
NATURALIZATION SERVICE
========================================================= Appendix III


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix V

GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C. 

James M.  Blume, Assistant Director, Administration of Justice Issues
Jay Jennings, Assignment Manager

OFFICE OF THE GENERAL COUNSEL,
WASHINGTON, D.C. 

Ann H.  Finley, Senior Attorney

LOS ANGELES REGIONAL OFFICE

Michael P.  Dino, Evaluator-in-Charge
Leah Geer Riordan, Evaluator
James R.  Russell, Evaluator
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