Alien Applications: Processing Differences Exist Among INS Field Units
(Letter Report, 05/20/97, GAO/GGD-97-47).

GAO reviewed whether significant differences in production rates and
processing times existed among Immigration and Naturalization Service
(INS) field units in alien application processing, focusing on what
factors INS officials believe could have caused the differences. GAO did
not attempt to do the more detailed analyses that would be necessary to
determine actual causes.

GAO noted that: (1) its analyses of INS data for the 25-month period of
June 1994 through June 1996 showed that statistically significant
differences existed in the production rates for the five predominant
types of applications processed by INS' district offices and the three
predominant types of applications processed by its service centers; (2)
large differences also existed in the projected processing times for the
two types of applications for which these data were readily available;
(3) the data showed that INS district offices' projected processing
times ranged from 112 to 678 days to process naturalization applications
and from 36 to 799 days to process adjustment-of-status applications;
(4) GAO found no significant statistical relationship between production
rates and projected processing times among the district offices; (5)
while GAO did not determine directly what caused the differences, the
wide range in rates and times suggests that opportunities may exist to
improve the production and timeliness of some of the INS field units;
(6) to that end, GAO asked INS officials what factors they believed
could potentially have caused the differences in the production rates
and processing times; (7) they suggested a number of potential factors,
including the following: (a) differences in the way the field units
reported the data GAO used to calculate the production rates and
processing times; (b) assistance provided by community-based service
organizations in some districts to aliens when filling out their
applications; (c) the use of outside agencies for conducting
naturalization testing by some district offices; (d) the authorization
of increased overtime for some districts' employees; (e) the varying
experience levels and degrees of specialization of district office and
service center adjudications officers; and (f) differences in the
staffing levels among some district offices; (8) GAO did not attempt to
determine whether or to what degree the factors suggested by the
officials may have affected the individual field units' production rates
and processing times; (9) however, differences in processing times mean
that aliens in different INS districts have had to wait disparate
amounts of time for their applications to be processed; and (10) thus,
the need to treat applicants fairly and use government resources
efficiently makes both determining the causes of the production and tim*

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

 REPORTNUM:  GGD-97-47
     TITLE:  Alien Applications: Processing Differences Exist Among INS 
             Field Units
      DATE:  05/20/97
   SUBJECT:  Aliens
             Naturalization
             Productivity
             Statistical methods
             Human resources utilization
IDENTIFIER:  INS Direct Mail Program
             
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Cover
================================================================ COVER


Report to the Attorney General

May 1997

ALIEN APPLICATIONS - PROCESSING
DIFFERENCES EXIST AMONG INS FIELD
UNITS

GAO/GGD-97-47

INS Processing of Alien Applications

(183605)


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

  INS - Immigration and Naturalization Service

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


B-275114

May 20, 1997

The Honorable Janet Reno
The Attorney General
 of the United States

Dear Madam Attorney General: 

The Immigration and Naturalization Service (INS) collects fees for
processing aliens' applications (and petitions) for such immigration
benefits as naturalization and adjustment of status (to become
permanent residents).\1 Eighteen percent ($566 million) of INS'
fiscal year 1997 budget of $3.09 billion is allocated for processing
applications. 

The number of applications received by INS has been growing and there
are indications that some INS field units are faster than others at
application processing.  In fiscal year 1996, INS received almost 5.4
million new applications and completed about 5.6 million total
applications, which is about a 115 percent increase over the number
of applications received and completed in fiscal year 1989.  At the
end of fiscal year 1996, INS had a pending caseload inventory of
about 1.7 million applications to be processed.  This represented an
increase of about 2.5 times the pending caseload at the end of fiscal
year 1989.  A recent INS report\2 indicated differences in
application production rates and projected processing times among its
district offices. 

Because of the large volume of applications and indications of
differences in processing times across INS field units, we initiated
a review under our basic legislative authority to determine if
significant differences in production rates and processing times
existed among field units in application processing.\3 Because we
found differences, we also asked officials at the nine district
offices and two service centers that we visited what factors they
believed could have caused the differences.  We did not attempt to do
the more detailed analyses that would be necessary to determine
actual causes.  This report presents the results of our work. 


--------------------
\1 Until recently, INS was to deposit the revenue from all of these
fees into the Immigration Examination Fee Account.  The 1989
Department of Justice Appropriation Act established the account to be
used to reimburse any appropriation for expenses in providing
immigration and naturalization services.  P.L.  100-459, 102 Stat. 
2186, 2203 (1988).  In the fall of 1996, the Illegal Immigration
Reform and Immigrant Responsibility Act established a new account,
the Immigration Detention Account, into which certain additional fees
for adjustment of status are now deposited.  P.L.  104-208, 110 Stat. 
3009, 3009-648, 3009-649 (1996). 

\2 INS Benefits Division Production Report, Fiscal Years 1996-1997. 

\3 We analyzed the production rates and projected average processing
times for each of 25 months in 33 INS districts.  We did a Pearson
correlation coefficient analysis to determine if statistical
relationships between production rates and projected average
processing times existed (e.g., was an increase in production rates
statistically related to an increase in projected average processing
times).  We calculated "production rates" as the number of completed
applications divided by the productive processing staff hours for
each field unit (district office and service center).  We calculated
monthly projected average processing times by dividing the number of
applications pending at month's end by the number of applications
completed for the month and multiplying this product by the number of
calendar days in the month. 


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

Our analyses of INS data for the 25-month period of June 1994 through
June 1996 showed that statistically significant differences existed
in the production rates for the five predominant types of
applications processed by INS' district offices and the three
predominant types of applications processed by its service centers. 
For example, the district offices' average production rates for
naturalization applications for that period ranged from 0.35
completions per hour to 1.83 completions per hour.  The service
centers' average production rates for employment authorization
applications ranged from 3.11 completions per hour to 5.79
completions per hour. 

Large differences also existed in the projected processing times for
the two types of applications for which these data were readily
available.  The data showed that INS district offices' projected
processing times ranged from 112 to 678 days to process
naturalization applications and from 36 to 799 days to process
adjustment-of-status applications.  We found no significant
statistical relationship between production rates and projected
processing times among the district offices. 

While we did not determine directly what caused the differences, the
wide range in rates and times suggests that opportunities may exist
to improve the production and timeliness of some of the INS field
units.  To that end, we asked INS officials what factors they
believed could potentially have caused the differences in the
production rates and processing times.  They suggested a number of
potential factors, including the following: 

  differences in the way the field units reported the data we used to
     calculate the production rates and processing times;

  assistance provided by community-based service organizations in
     some districts to aliens when filling out their applications;

  the use of outside agencies for conducting naturalization testing
     by some district offices;

  the authorization of increased overtime for some districts'
     employees;

  the varying experience levels and degrees of specialization of
     district office and service center adjudications officers; and

  differences in the staffing levels among some district offices
     (e.g., some offices were staffed above their authorized levels,
     while other offices temporarily lost staff to larger offices). 

We did not attempt to determine whether or to what degree the factors
suggested by the officials may have affected the individual field
units' production rates and processing times.  We note, however, that
differences in processing times mean that aliens in different INS
districts have had to wait disparate amounts of time for their
applications to be processed.  Thus, the need to treat applicants
fairly and use government resources efficiently makes both
determining the causes of the production and timing differences and,
if feasible, improving production and timeliness, important goals for
INS. 


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

INS processes applications for aliens seeking immigration
benefits--such as naturalization and adjustment of status--within its
33 district offices' jurisdictions and 4 service centers located in
cities throughout the United States. 

INS collects fees for processing applications.  The fees are
generally set on the basis of the approximate cost that INS
determines it incurs to process the type of application filed.\4

The revenue from the fees is to be used for expenses incurred in (1)
processing applications and (2) collecting, safeguarding, and
accounting for the fees.  In general, INS processes applications that
require aliens to be interviewed (i.e., those for naturalization and
adjustment of status) at its district offices.  However, at four of
its largest district offices, the service centers perform preliminary
processing of applications that require aliens to be interviewed. 
Applications that do not require aliens to be interviewed (e.g.,
those for employment authorization) are processed at its service
centers and district offices.\5


--------------------
\4 An exception is the adjustment-of-status application fee, which is
set by statute at $1,000 for certain aliens. 

\5 In addition, INS processes applications for asylum at eight
offices nationwide.  Because such applications are not processed at
the district offices or the service centers, we excluded them from
our review. 


      INCREASED VOLUME OF
      APPLICATIONS
---------------------------------------------------------- Letter :2.1

While experiencing some fluctuations, the overall number of
applications received, completed, and remaining in INS' ending
inventory significantly increased between fiscal years 1989 and 1996,
as shown in table 1. 



                                Table 1
                
                    Number of Applications Received,
                 Completed, and Remaining in Inventory,
                     Fiscal Years 1989 Through 1996


                                                           Fiscal year
                                                                ending
Fiscal year                   Received       Completed       inventory
----------------------  --------------  --------------  --------------
1989                         2,510,015       2,585,478         658,399
1990                         2,963,428       2,971,300         540,830
1991                         3,359,869       3,379,383         568,189
1992                         4,234,980       4,207,968         656,067
1993                         4,498,208       4,288,643         679,982
1994                         4,137,660       3,911,697        987,485\
1995                         4,976,716       4,265,463      1,765,999\
1996                        5,393,501\      5,557,102\      1,673,163\
----------------------------------------------------------------------
Source:  INS budget data for fiscal years 1989 to 1991 and INS G-22.2
and G-22.3 reports for fiscal years 1992 to 1996, dated January 1997. 

According to INS officials, the significant increase in the number of
applications INS has received since fiscal year 1989 can be
attributed to (1) aliens' reactions to proposed changes in state and
federal laws that would have denied aliens benefits (e.g., proposals
to prohibit children of illegal aliens from attending public
schools); (2) aliens having to replace their alien registration
receipt cards; and (3) legal aliens becoming eligible to become
naturalized and having an incentive to do so because of the benefits
that could be derived from their status as citizens.  INS officials
said that naturalization and adjustment-of-status applications
reached record levels in fiscal year 1996.  For example,
naturalization applications rose from about 423,000 in fiscal year
1989 to over 1.2 million in fiscal year 1996.  The officials also
said that the level of applications is expected to remain high. 

According to INS officials, the waiting time needed to process an
application in fiscal year 1995 had increased.  For example, the
projected processing time for naturalization applications exceeded 2
years in several of INS' largest districts.  INS added that this
increase in processing time was due to (1) the tremendous growth in
application receipts, combined with the speed at which the increase
occurred; and (2) the lag time to obtain additional resources through
the reprogramming process. 


      CHANGES IN APPLICATION
      PROCESSING
---------------------------------------------------------- Letter :2.2

In 1986, INS began requiring that some applications, other than those
requiring interviews (e.g., those for naturalization and adjustment
of status), be mailed directly to service centers for processing,
rather than to the district offices.\6 INS called this the "Direct
Mail Program." Under a change to the Direct Mail Program, which was
effective February 1996, aliens who would have mailed their
naturalization applications to one of INS' four largest district
offices (Chicago, Los Angeles, Miami, and New York) are required to
mail their naturalization applications directly to a designated
service center.  The service centers are to perform the preliminary
processing of the applications in support of these four district
offices.\7 The district offices are to complete the processing of
these applications by doing additional work (e.g., interviewing the
aliens).  According to INS officials, INS expects to continue with
its plan to expand the Direct Mail Program to include other district
offices and application types.  The officials added that the Direct
Mail Program has greatly assisted these district offices in reducing
the large pending workload of naturalization applications. 

In addition to expanding its Direct Mail Program, during fiscal year
1996 INS directed more resources to processing naturalization
applications.  It concentrated its additional staff and other
resources primarily in Los Angeles, San Francisco, Miami, Chicago,
and New York.  These district offices' workloads together comprised
75 percent of pending naturalization applications in fiscal year 1995
and, according to INS officials, this was the reason they were chosen
for the Direct Mail Program. 

According to INS officials, as a result of these efforts, the number
of naturalization applications completed increased by about 166
percent between fiscal years 1995 and 1996, and the pending balance
was reduced by about 13 percent over the same time period.  The
officials said that INS received more applications but its capacity
to handle applications increased at the same time.  However, its
pending balance of adjustment-of-status applications increased by
about 37 percent.  The pending balance for all types of applications
decreased by 17 percent.  (See table 2.)



                                     Table 2
                     
                      Changes in Receipts, Completions, and
                       Pending Balances for Adjustment-of-
                         Status, Naturalization, and All
                     Application Types for Fiscal Years 1995
                                     and 1996

                                          Percen          Percen          Percen
                          Fiscal  Receip       t  Comple       t  Pendin       t
Application type            year      ts  change     ted  change       g  change
------------------------  ------  ------  ------  ------  ------  ------  ------
Naturalization              1995  1,057,          505,91          803,06
                                     759               3               2
                            1996  1,220,    15.4  1,344,   165.7  701,48  (12.6)
                                     517             412               7
Adjustment of status        1995  577,75          357,56          320,77
                                       9               7               0
                            1996  649,79    12.5  541,86    51.5  438,54    36.7
                                       2               7               6
All types                   1995  3,341,          3,401,          642,16
                                     198             983               7
                            1996  3,523,     5.4  3,670,     7.9  533,13  (17.0)
                                     192             823               0
--------------------------------------------------------------------------------
Source:  INS G-22.2 and G-22.3 reports for fiscal years 1995 and
1996, dated January 1997. 


--------------------
\6 The applications were to be mailed to designated remote
adjudications centers, which have since been replaced by the four
service centers. 

\7 Under the Direct Mail Program, the California Service Center
supports the Los Angeles District Office, the Nebraska Service Center
supports the Chicago District Office, the Texas Service Center
supports the Miami District Office, and the Vermont Service Center
supports the New York District Office. 


      INS APPLICATION PROCESSING
      GOALS
---------------------------------------------------------- Letter :2.3

INS' goal is that the application process will be timely, consistent,
fair, and of high quality.  In addition, INS officials stated that a
quality decision includes a timely decision.  During fiscal year
1996, INS made processing naturalization and adjustment-of-status
applications among its highest priorities and INS' Commissioner set
6-month and 4-month goals, respectively, for processing these two
types of applications.\8 According to INS officials, INS has not
established production rate goals. 


--------------------
\8 A processing time frame of 90 days for interim employment
authorization applications also exists. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :3

To determine the production rates and projected processing times for
selected application types at INS' district offices and service
centers, we collected and analyzed INS application processing
workload summary data and projected processing time reports by
application type and by month for the 25-month period ending June
1996.  We then compared the production rates and projected processing
times for applications among district offices and the production
rates for applications among service centers.  After identifying
differences, we attempted to identify possible reasons for the
differences in production rates and processing times.  We did this by
asking INS officials in headquarters and 11 selected field units what
factors they believed could have caused the differences.\9 On the
basis of our analyses of production rates and projected processing
times, we chose the nine district offices and two service centers we
visited because they had a range of production rates, processing
times, and application volumes.\10 At these field units and INS
headquarters, we discussed application processing procedures,
staffing changes, production rates, and application processing times
for the period of June 1994 through June 1996.  Their comments are
not generalizable to other field units.  Also, we reviewed an INS
report that showed differences in production rates and projected
processing times among its field units.\11

Using INS' methodology, we calculated "production rates" as the
number of completed applications divided by the productive processing
staff hours for each field unit (district office and service
center).\12 This is a measure of how many applications were completed
per hour.  According to INS guidance, the projected processing time
for a particular month is to be calculated by dividing the number of
applications pending at month's end by the number of applications
completed for the month and multiplying this product by the number of
calendar days in the month.  This is a projection of how long INS
will take to complete action on an application received on the last
day of the month if the current month's completion rate is
maintained.  This is a proxy measure of how long the "wait time"
would be from receipt of an application to the completion of its
processing, per month.  INS used this methodology to calculate
projected processing times for selected application types by month
over the 25-month period of June 1994 through June 1996. 

Since the fall of 1996, reports by us and others and congressional
oversight hearings have provided evidence that INS' efforts to reduce
backlogs in naturalization application processing resulted in serious
internal control and other weaknesses that led to improper
naturalization actions in some cases.\13 Reviews of these problems,
by ourselves and others, are currently ongoing.  The scope of the
work that was undertaken to address our objectives for this
report--to determine whether significant differences in production
rates and processing times existed among INS' field units--did not
include an assessment of whether INS' naturalization processes were
being carried out in accordance with INS' policies and procedures. 

We conducted our review from March 1996 to April 1997 in accordance
with generally accepted government auditing standards.  We provided
the Attorney General and the INS Commissioner with a draft of this
report for their review and comment.  The Commissioner provided
written comments for the Attorney General, which are discussed and
evaluated at the end of this letter.  The INS comment letter is
reprinted in appendix III.  Appendix I provides a more detailed
description of our objectives, scope, and methodology.  INS also
provided separately some technical comments.  We discussed these
comments with INS officials and agreed on appropriate changes. 


--------------------
\9 We met with Assistant District Directors for Examinations and
Service Center Directors, except when they suggested that we speak
with someone else on their staff. 

\10 See app.  I for a list of locations we visited. 

\11 The data source for this report was the same source that we used
for our analysis.  INS' report excluded data on returned
applications, while we included these data. 

\12 Productive processing staff hours do not include staff time spent
on any administrative functions (e.g., training, travel, supervision,
and record keeping). 

\13 Naturalization of Aliens:  Assessment of the Extent to Which
Aliens Were Improperly Naturalized (GAO/T-GGD-95-51, Mar.  5, 1997);
KPMG Peat Marwick LLP.  Naturalization Quality Procedures
Implementation Review (Washington, D.C.:  Apr.  17, 1997);
Naturalization of Aliens:  INS Internal Controls (GAO/T-GGD-97-57,
Apr.  30, 1997); Naturalization of Aliens:  INS Internal Controls
(GAO/T-GGD-97-98, May 1, 1997). 


   VARIANCES IN PRODUCTION RATES
------------------------------------------------------------ Letter :4

Our analyses of INS monthly workload summary data for the period of
June 1994 through June 1996 showed that statistically significant
differences existed in production rates for each of the five
predominant types of applications among INS district offices and
service centers.  This is consistent with the INS report that also
showed differences in production rates among its district offices and
among its services centers for fiscal years 1994, 1995, and 1996.  In
discussing our analyses with INS officials, they pointed out that
anomalies in some district offices explain some of the differences. 
However, INS did not provide any examples of these anomalies. 


      PRODUCTION RATES DIFFERED
      SIGNIFICANTLY
---------------------------------------------------------- Letter :4.1

Our analyses of the production data for district offices and service
centers showed that statistically significant differences existed in
average production rates by application type (as measured by
applications completed per productive hour) for the 25-month period
ending June 1996.  (See table 3.) See appendix II for a schedule by
field unit and application type.\14



                                Table 3
                
                  Range of Average Per Hour Production
                   Rates for INS District Offices and
                  Service Centers for Five Application
                   Types, June 1994 Through June 1996


Application type                     Low      High       Low      High
------------------------------  --------  --------  --------  --------
I-90                                0.04      3.94      3.17      6.69
I-130                               0.32      1.26      2.85      4.20
I-485                               0.32      1.28        \a        \a
I-765                               0.76      4.55      3.11      5.79
N-400                               0.35      1.83        \a        \a
----------------------------------------------------------------------
Legend:
I-90 = replacement of alien registration card
I-130 = immigrant visa for alien relative
I-485 = registration for permanent residency or adjustment of status
I-765 = employment authorization
N-400 = naturalization

\a Generally, the service centers do not adjudicate the I-485 and
N-400 applications. 

Source:  GAO analyses of INS data. 

In comparing production rates among district offices for the five
application types, some district offices tended to be more productive
for all application types, others were comparatively less productive
for all application types, while other district offices' production
rates varied by application type.  For example, one district office
had one of the highest production rates for one application type but
the lowest production rate for two other application types.  Another
district office had one of the highest production rates for two
application types but the next to lowest rate for another application
type. 

We also analyzed the production data to determine if either the
proportion of naturalization applications and adjustment-of-status
applications or the volume of naturalization and adjustment-of-status
applications completed by district offices was related to their
production rates for these two application types.\15 We did not find
a statistically significant relationship.  We did find, however, a
statistically significant, positive relationship between the
production rate for naturalization applications and the production
rate for adjustment-of-status applications.\16 That is, district
offices with high production rates for naturalization applications
also tended to have high production rates for adjustment-of-status
applications.  In other words, we found a tendency for some district
offices to have more completions per hour than others for these two
application types. 


--------------------
\14 In our analyses, we compared monthly production rates (completed
applications divided by productive hours) by application type for
each district office and service center.  In this report, we used the
25-month average by application type for each unit.  This was done
for presentation purposes because of the complexity of the data for
33 district offices and 4 service centers by month, for 25 months,
for 5 separate application types. 

\15 Naturalization and adjustment-of-status applications accounted
for about one-half of all completed applications in fiscal year 1996. 

\16 For the average production rate for the 33 districts, the Pearson
correlation coefficient between the two application types was 0.58
(the probability that the relationship was due to chance was less
than 5 percent). 


      INS' REPORT CONTAINING
      PRODUCTION DATA ALSO SHOWED
      VARIANCES
---------------------------------------------------------- Letter :4.2

According to the INS Benefits Division Production Report, average
production rates agencywide for all application types decreased from
1.67 completions per hour in fiscal year 1995 to 1.45 in fiscal year
1996.  Across INS, during the same time period, average
naturalization application completions increased from 0.66 to 0.84
per hour, while completions of adjustment-of-status applications
decreased from 0.74 to 0.70 per hour.  The report further stated
that, in fiscal year 1996, field units' average production rates
ranged from 0.42 to 2.11 completions per hour for all application
types combined, from 0.21 to 2.30 completions per hour for
naturalization applications, and from 0.30 to 1.88 completions per
hour for adjustment-of-status applications.  The INS report did not
include a statistical analysis of the differences in production
rates. 

We compared the results of our analyses with the data in INS' report
and found that our results were similar to INS' results.  Differences
in how we aggregated data for analyses caused our figures to differ
somewhat from INS' figures, but the overall pattern of differences
across district offices is evident in both analyses.\17 INS excluded
returned applications, while our analyses of the data included
returned applications.  According to INS officials, this inclusion
would not significantly affect our analyses. 

According to INS officials, although INS had not compared the reasons
or studied the causes for differing production rates, it has been
working to address differences in processing times. 


--------------------
\17 INS' report provided data from 65 units, including district
offices and suboffices within the district offices.  Naturalization
data for two units were zero.  The data were for fiscal years 1994,
1995, and 1996.  For fiscal years 1995 and 1996, INS also reported
the data by quarters.  Our analyses were done by month for the
25-month period ending June 1996 for the same two application types
as well as for the other three major application types. 


   VARIATION IN PROJECTED
   PROCESSING TIMES
------------------------------------------------------------ Letter :5

Our analyses of INS workload summary and projected processing time
data for the 25-month period ending June 1996 showed that differences
existed among district offices concerning projected processing times
for the two predominant types of applications.\18

Furthermore, INS' report also showed variances in projected
processing times among its district offices. 


--------------------
\18 As with production rates, we used the 25-month average for
projected processing times for naturalization and
adjustment-of-status applications.  This was done for presentation
purposes because of the complexity of displaying the data for 33
district offices by month for the 25 months for 2 application types. 


      PROJECTED APPLICATION
      PROCESSING TIMES DIFFERED
      SIGNIFICANTLY AMONG INS
      DISTRICT OFFICES
---------------------------------------------------------- Letter :5.1

Our analyses of projected processing time data for
adjustment-of-status and naturalization applications showed that
significant differences existed among INS district offices.\19 For
example, the projected average processing time for
adjustment-of-status applications from June 1994 to June 1996 was 357
days for all district offices combined, with a low of 36 days and a
high of 799 days\20 (see table 4). 



                                Table 4
                
                 Average Projected Processing Times for
                Adjustment-of-Status Applications at 32
                District Offices, June 1994 Through June
                                  1996

INS district office                                     Number of days
----------------------------------------------  ----------------------
St. Paul, MN                                                        36
Portland, ME                                                        69
Buffalo, NY                                                        102
Cleveland, OH                                                      107
Honolulu, HI                                                       110
Denver, CO                                                         141
Anchorage, AK                                                      147
Baltimore, MD                                                      151
Helena, MT                                                         163
Philadelphia, PA                                                   180
Detroit, MI                                                        197
Dallas, TX                                                         208
Boston, MA                                                         209
Miami, FL                                                          221
Seattle, WA                                                        228
New Orleans, LA                                                    237
Kansas City, MO                                                    244
Atlanta, GA                                                        273
San Antonio, TX                                                    311
Portland, OR                                                       316
Newark, NJ                                                         347
Omaha, NE                                                          348
San Francisco, CA                                                  353
Washington, D.C.                                                   359
Chicago, IL                                                        424
New York, NY                                                       456
San Diego, CA                                                      504
San Juan, PR                                                       521
Phoenix, AZ                                                        608
El Paso, TX                                                        669
Los Angeles, CA                                                    770
Houston, TX                                                        799
======================================================================
INS average                                                        357
----------------------------------------------------------------------
Note:  According to INS officials, as part of a pilot of the Direct
Mail Program, the Vermont Service Center has been performing the
preliminary processing of adjustment-of-status applications in
support of the Baltimore District Office.  The officials added that
this initiative could affect the district office's projected
processing times and production rates for this application type. 

Source:  GAO analyses of INS data. 

For naturalization applications, the average projected processing
time from June 1994 to June 1996 was 373 days across all district
offices, with a low of 112 days and a high of 678 days.  (See table
5.)



                                Table 5
                
                 Average Projected Processing Times for
                   Naturalization Applications at 32
                District Offices, June 1994 Through June
                                  1996

INS district office                                     Number of days
----------------------------------------------  ----------------------
Portland, ME                                                       112
Buffalo, NY                                                        130
Baltimore, MD                                                      138
Washington, D.C.                                                   140
Anchorage, AK                                                      159
Cleveland, OH                                                      167
St. Paul, MN                                                       170
Helena, MT                                                         171
Kansas City, MO                                                    185
Philadelphia, PA                                                   188
San Antonio, TX                                                    196
Portland, OR                                                       196
Honolulu, HI                                                       218
New Orleans, LA                                                    259
New York, NY                                                       261
Atlanta, GA                                                        265
Omaha, NE                                                          265
Boston, MA                                                         274
Denver, CO                                                         287
San Diego, CA                                                      294
El Paso, TX                                                        295
Harlingen, TX                                                      308
Newark, NJ                                                         331
San Juan, PR                                                       339
Seattle, WA\a                                                      344
Los Angeles, CA                                                    369
Detroit, MI                                                        379
Dallas, TX                                                         455
Chicago, IL                                                        526
San Francisco, CA                                                  552
Miami, FL                                                          578
Houston, TX                                                        615
Phoenix, AZ                                                        678
======================================================================
INS average                                                        373
----------------------------------------------------------------------
\a An official in the Seattle District Office said that its
processing time for naturalization applications did not exceed 196
days.  According to the official, the difference between the average
data INS and we used and its data resulted from the fact that INS and
we used a formula (which is a proxy on the basis of the aggregate
flow of applications) to calculate average projected processing
times, whereas the Seattle District Office used the actual processing
times spent to complete individual naturalization applications each
month.  We did not verify Seattle's calculation. 

Source:  GAO analyses of INS data. 

To determine whether a statistical relationship existed between
production rates and projected processing times, we analyzed data for
adjustment-of-status and naturalization applications for all district
offices that completed at least 100 of either type of application per
month during the 25-month period ending June 1996.\21 We found no
significant relationship between production rates and projected
processing times among the district offices.\22


--------------------
\19 Because staff at INS service centers generally did not adjudicate
naturalization and adjustment-of-status applications, we did not
analyze the processing times for INS' four service centers.  Also,
data on processing times for other types of applications were not
readily available.  Therefore, we only analyzed naturalization and
adjustment-of-status applications. 

\20 We eliminated the Harlingen District Office (Texas) from our
computation of INS' average because its reported projected processing
time appeared to be an anomaly.  Doing further analyses to determine
whether the time reported was an anomaly or an error was not
practical. 

\21 To detect a possible relationship between the two application
types, we needed a sufficient number of completed applications.  On
the basis of our review of the data, 100 completed applications per
month were adequate for our purpose--29 and 30 district offices had
completed an average of 100 naturalization and 100
adjustment-of-status applications per month, respectively.  At the
time of our review, data from the New York District Office were not
available.  Because of data problems, we excluded the Harlingen
District Office (Texas). 

\22 The Pearson correlation coefficient was less than 0.1 (with a
probability greater than 0.8). 


      INS' REPORT CONTAINING
      TIMELINESS DATA SHOWED
      VARIANCES
---------------------------------------------------------- Letter :5.2

According to the INS Benefits Division Production Report, during
fiscal year 1996, the average projected processing times of reporting
field units for completing all types of applications ranged from 45
days to 296 days.  The average projected processing time for
naturalization applications ranged from 22 days to 383 days. 
According to the INS report, 53 percent of its reporting field units
had average projected processing times for their naturalization
applications of less than or equal to 183 days (6 months), which was
INS' processing goal.  The projected processing times for the field
units to complete adjustment-of-status applications ranged from 38
days to 998 days.  Twenty-eight percent of the field units completed
processing of adjustment-of-status applications within 122 days (4
months), which was INS' processing goal.  As in the case of INS'
production data, its projected processing time data were consistent
with our analyses.\23


--------------------
\23 The same previously discussed reasons explain the differences
between INS' report and our analyses. 


   POSSIBLE REASONS FOR
   DIFFERENCES IN PRODUCTION RATES
   AND PROCESSING TIMES
------------------------------------------------------------ Letter :6

To identify factors that may have contributed to the differences in
production rates and processing times, we met with officials at INS
headquarters, nine district offices, and two service centers.\24
Generally, these officials' comments focused on the data used to
compare the field units' rates and times, as well as on other factors
that may have affected the units' production and timeliness.  With
the exception of comparability of data issues, we were not able to
gain insight into the extent to which these factors actually affected
the production rates and processing times.  Such an assessment would
require a more thorough review and analysis of the field units'
procedures and practices for processing applications than we could
complete within a reasonable period of time. 

In our discussions about factors that the officials said could have
affected differences in production rates and processing times, the
issues they identified tended to be interrelated.  Therefore, in the
following discussion, we do not separate production rate and
processing time issues. 


--------------------
\24 Before meeting with these officials, we provided them with our
analyses of production rates and projected processing times. 


      DATA MAY AFFECT COMPARISONS
      OF FIELD UNITS
---------------------------------------------------------- Letter :6.1

INS officials in certain field units said that our comparisons of
field units' production rates and projected processing times could be
affected by two data-related factors. 

  The first factor was the possibility of inaccuracies in the data
     reported by other field units.  For example, officials in two
     field units were concerned that other field units may not have
     accurately reported their production data.  However, none of the
     field units we visited identified problems associated with its
     own production data.  Furthermore, many of the officials told us
     that they reviewed and corrected their units' production data
     before sending the data to their respective regional offices or
     INS headquarters. 

  The second factor, which was cited by several district offices at
     the time of our visit, was inconsistency in defining the point
     when approved naturalization applications were considered
     completed.  For example, five of the nine district offices we
     visited considered an approved naturalization application
     completed after the naturalization interview, and at that point,
     the district offices would approve the application.  The other
     four district offices considered an approved naturalization
     application completed only after the alien was sworn in as a
     naturalized citizen.\25

We agree with INS that the differences in production rates and
processing times could be partly attributed to this inconsistent
definition.  However, as shown in table 6, our analyses indicated
that differences existed in the production rates of the four
districts that considered the naturalization ceremony the point of
completion, as well as among the five district offices that
considered the interview the point of completion. 



                                Table 6
                
                 Ranges of Average Production Rates and
                Projected Processing Times for the Nine
                INS District Offices Broken Out by When
                     in the Process Naturalization
                Applications Were Considered Completed,
                      June 1994 Through June 1996


Naturalization complete                   High     Low    High     Low
--------------------------------------  ------  ------  ------  ------
After ceremony                            1.34    0.82     615     185
After interview                           1.83    0.56     455     130
----------------------------------------------------------------------
Source:  GAO analyses of INS data. 

As shown in table 7, wide variances also existed among these district
offices' per hour production rates for the four types of
applications, other than those for naturalization. 



                                Table 7
                
                  Range of Average Per Hour Production
                Rates for the Nine INS District Offices
                 for Four Application Types, June 1994
                           Through June 1996


Application type                                       Low        High
----------------------------------------------  ----------  ----------
I-90                                                  0.10        3.94
I-130                                                 0.32        1.26
I-485                                                 0.37        1.28
I-765                                                 0.76        3.78
----------------------------------------------------------------------
Legend:
I-90 = replacement of alien registration card
I-130 = immigrant visa for alien relative
I-485 = registration for permanent residency or adjustment of status
I-765 = employment authorization

Source:  GAO analyses of INS data. 

Regarding the nine district offices' projected processing times, data
were readily available for adjustment-of-status applications but not
for other application types.  The nine district offices' projected
processing times for adjustment-of-status applications also varied
widely, ranging from 102 days to 799 days. 

INS headquarters officials were aware of concerns that field units
had about the data we used for our analyses.  However, they pointed
out that the data were the best available and were used by INS for
budgeting and management purposes, such as in INS' previously
mentioned Benefits Division Production Report.  In addition, INS uses
the same data for its report to Congress on the status of
adjudications and naturalization processing. 


--------------------
\25 According to INS officials, INS now requires its field units to
consider a naturalization application completed after the
naturalization ceremony.  The five district office officials said
that they are now following this requirement. 


      OTHER FACTORS THAT MAY
      AFFECT PRODUCTION RATES AND
      PROCESSING TIMES
---------------------------------------------------------- Letter :6.2

During our visits to field units, INS officials identified several
factors that they believed may affect production rates and processing
times.  They pointed out that, in any such work process, an
interrelationship exists among many factors that may affect both
production rates and processing times.  We agree and generally did
not verify whether or to what extent the following factors actually
affected production rates or processing times. 

  An official from one district office said that it must rely on the
     courts to conduct naturalization ceremonies, which can delay the
     naturalization dates and, therefore, increase the time spent to
     complete applications.  An official from another district office
     said that his office conducted the naturalization ceremony on
     the same day the application was approved, thereby shortening
     processing times. 

  According to officials in two district offices, aliens'
     naturalization applications tended to be more accurately
     completed when aliens received assistance from community-based
     service organizations.  As a result, according to these
     officials, INS officers were able to process these applications
     more quickly. 

  According to eight field unit officials, district offices have
     varying degrees of automation.  For example, one district office
     developed a computerized tracking system to enhance the
     recording and processing of adjustment-of-status applications. 
     According to officials in this district, other districts have
     requested and started to use this system to enhance their
     adjustment-of-status application processing.\26

  According to district office officials, in four district offices,
     adjudications staff specialized in certain application types,
     while in the other five district offices, adjudications staff
     performed as generalists, processing all types of applications. 

  According to INS officials at one field unit, the mix of
     applications (i.e., the proportion of application types) that
     field units receive affects their processing times.  These
     officials added that, if a field unit receives a larger
     percentage of applications that take longer to process, its
     average processing times for all types of applications would be
     longer relative to other field units. 

  According to INS officials we visited, staffing at the district
     offices has varied.  While some district offices have been
     staffed at or above their authorized levels, other offices have
     lost staff on a temporary basis to larger offices.  These
     officials added that the experience level of the adjudication
     staff differs across INS.  They said INS had recently hired new
     staff, and the new hires are generally not as efficient as the
     more experienced staff. 

  According to officials we visited, some INS district offices rely
     on outside testing agencies to conduct naturalization
     examinations, while other offices conduct their own
     examinations.  According to the officials, the use of outside
     testing agencies may improve timeliness. 

  According to officials in three district offices, authorized
     increases in overtime hours above their budget enabled their
     offices to reduce processing times. 


--------------------
\26 At the time of our review, this system was not being used
agencywide. 


   CONCLUSIONS
------------------------------------------------------------ Letter :7

Our analyses showed that the production rates among the district
offices and among service centers varied significantly for the five
application types we analyzed.  We did not find a relationship
between production rates and the mix of applications received or the
volume of completed applications.  Furthermore, the projected
processing times of naturalization and adjustment-of-status
applications differed among the district offices.  We found no
significant relationship between production rates and projected
processing times among the district offices.  An INS report covering
approximately the same time period also showed variations in
projected production rates and projected processing times among its
district offices.  INS has not identified reasons for these
variations. 

We did not attempt to assess the extent to which specific practices
or circumstances caused the differences in production rates and
processing times among field units.  However, our analyses of
production rates and projected processing times for the nine district
offices we visited, along with the fact that the field officials also
provided other reasons, seem to indicate that factors other than data
quality problems, at least in part, may have contributed to the
variation.  Data quality, specifically definitional issues, however,
could have contributed to differences across field units. 

The production rates of district offices and service centers are
important because of the significant growth in the number of
applications that INS has received over the past several years.  This
growth has placed greater demands on INS as it attempts to process
these applications within reasonable time frames.  Our comparisons
among field units show that significant differences exist in their
production rates; thus, opportunities may exist to improve the
production rates of some of the units. 

Aliens pay the same fees for the various applications at all INS
offices; however, the length of time that aliens wait for their
applications to be completed has varied widely from field unit to
field unit.  This raises a fairness issue in that the length of time
aliens have to wait for their applications to be processed varies
according to the INS office at which they apply. 

Determining the reasons for the differences in, or methods for
improving, production or timeliness were outside the scope of this
review.  Because INS has in-depth knowledge of its field operations
and its application processing procedures, it is in the best position
to pursue the causal factors that may be contributing to higher
production in some field units.  The identification of these factors
can be important because they may relate to opportunities for
improved efficiencies at all field units. 


   RECOMMENDATIONS TO THE ATTORNEY
   GENERAL
------------------------------------------------------------ Letter :8

We recommend that you direct the INS Commissioner to periodically
determine and assess the production rates and processing times in the
INS field units.  The Commissioner should first ensure that the field
units are consistently reporting the data used to calculate the rates
and times.  After ensuring that data are consistently reported,
including using the same definitions, the Commissioner should (1)
analyze the production rates and processing times for each field unit
by application type, (2) identify factors that contribute to making
the field units more or less productive and timely, (3) determine
whether and what changes could be made to make individual field units
more productive and timely, and (4) follow up with the field units to
ensure that appropriate changes are implemented. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :9

In an April 22, 1997, letter, the INS Commissioner provided comments
on a draft of this report (see app.  III).  Although not specifically
commenting on our recommendations in its letter, INS officials,
including the Associate Commissioner for Examinations, in a meeting
on March 18, 1997, said that they agreed with our recommendations.\27
However, the Commissioner said that our draft led the reader to
believe that our overall conclusions were based on scientific
analyses when, in her view, they were based simply on unvalidated
testimonial and anecdotal information. 

We disagree with INS that our analyses and conclusions were not
scientifically based.  We analyzed the production rates using
standard statistical techniques to determine if the differences
between field units by application type were significant.  Our
analyses showed that significant differences existed.  We then
examined other factors that might be related to the differences in
the production rates such as processing times, mix of application
types, and volume of application types.  However, we recognized as a
result of INS' comment that additional information about our
methodology would be beneficial to a reader.  Accordingly, we added
additional information to this report to clarify the statistical
analyses we performed. 

INS also said that the data in our draft were suggestive and not
conclusive and that the report provided very little information to
help it better understand the problem.  Therefore, INS believes that
our work further demonstrates the need for it to continue its efforts
to improve data integrity.  INS added that one of its priorities is
to revise its workload reporting process, including standardizing the
definitions and methods of data collection. 

As discussed in this report, we agree that the data we analyzed do
not provide conclusive reasons for the differences in production
rates and processing times within the nine field offices.  Our
objectives for this review did not include determining actual causes
for the differences. 


--------------------
\27 At this meeting, INS provided technical comments, which were
incorporated in this report where appropriate. 


---------------------------------------------------------- Letter :9.1

This report contains recommendations to you.  As you know, the head
of a federal agency is required by 31 U.S.C.  720 to submit a written
statement on actions taken on these recommendations to the Senate
Committee on Governmental Affairs and the House Committee on
Government Reform and Oversight not later than 60 days after the date
of the report.  A written statement also must be sent to the House
and Senate Committees on Appropriations with the agency's first
request for appropriations made more than 60 days after the date of
the report. 

We are sending copies of this report to the Chairmen and Ranking
Minority Members of interested congressional committees; the INS
Commissioner; the Director, Office of Management and Budget; and
other interested parties.  Copies will also be made available to
others upon request. 

Major contributors to this report are listed in appendix IV.  If you
have any questions about this report, please contact me on (202)
512-8777. 

Sincerely yours,

Norman J.  Rabkin, Director
  Administration of Justice Issues


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

Because of the large volume of applications and indications of
differences in processing times across INS field units, we initiated
a review under our basic legislative authority to determine if
significant differences in production rates and processing times
existed among INS' field units in application processing.  Because we
found differences, we also asked officials at the nine district
offices and two service centers that we visited what factors they
believed could have caused the differences.  We did not attempt to do
the more detailed analyses that would be necessary to determine
actual causes. 

To determine the production rates for each type of application in the
INS district offices and service centers, we obtained the monthly
adjudications workload summary reports (G-22.2 and G-22.3 reports,
dated January 31, 1997) from INS headquarters covering the 25-month
period from June 1994 through June 1996.  These monthly reports
provided information, by district office and application type, on (1)
the number of applications received and completed, as well as the
ending (pending) balances; and (2) the productive hours of the
adjudications staff.  For each office, we then calculated average
monthly production rates for each application type by dividing the
applications completed by the productive hours spent on
adjudications. 

The reports do not include contractor hours for processing
applications and records management at the field units.  During our
discussions with field unit officials, they did not mention
contractor hours as a factor affecting the differences in production
rates or processing times.  Since the INS reports did not contain
contractor hours, we could not analyze the effect that contractor
hours may have had on production rates or processing times. 

To better understand how production compared across INS field units,
we analyzed the production rates for the five major types of
applications separately.  According to INS data, the five application
types that were processed most frequently were the replacement of
alien registration card (I-90), immigrant visa for alien relative
(I-130), registration for permanent residency or adjustment of status
(I-485), employment authorization (I-765), and naturalization
(N-400).  These five application types accounted for about 97 percent
of all completed applications for June 1996.  We compared the rates
for each application type only with those for the same type of field
unit.  For example, the production rates for employment authorization
applications at district offices were compared with those at other
district offices but not with those at service centers.  According to
INS, the application review processes are different in the two types
of field units. 

To determine whether a relationship existed between production rates
and projected processing times, we analyzed data for
adjustment-of-status and naturalization applications for all district
offices that completed at least 100 of either type of application per
month during the 25-month period ending June 1996.  To determine
whether a relationship existed between the two application types, we
needed a sufficient number of completed applications.  On the basis
of our review of the data, 100 completed applications per month was
adequate for our purpose.  We also analyzed the production data to
determine whether the mix of naturalization and adjustment-of-status
applications received (i.e., proportion of application types at a
district office) or the volume of naturalization and
adjustment-of-status applications completed by district offices, was
related to their production rates.\1 Specifically, we performed three
statistical analyses. 

  Our analysis of the variation in monthly production rates showed a
     statistically significant difference (probability that the
     relationship was due to chance was less than 5 percent) between
     district office average production rates.  We analyzed data from
     June 1994 through June 1996 for the 33 districts for the 5
     predominant types of applications processed by the district
     offices and 3 types for service centers.  This result led to
     several other analyses to attempt to determine what factors
     might be related to production rates. 

  We compared production rates and projected average processing times
     to see if a statistically meaningful relationship existed
     between the two.  That is, we wanted to know if districts with
     high production rates also generally had shorter projected
     average processing times than districts with lower production
     rates, or whether the inverse was true.  We analyzed data for
     adjustment-of-status and naturalization applications for all
     district offices that completed an average of at least 100
     applications per month during the 25-month period.  We did not
     find a significant relationship (the Pearson correlation
     coefficient was less than 0.1 with a probability due to chance
     greater than 80 percent). 

  We also analyzed adjustment-of-status and naturalization
     applications to see if either the volume of applications
     processed or the mix of applications processed was related to
     the production rate.  Volume was measured by the average number
     of completions per month for the two application types, and mix
     was measured by the ratio of applications completed for one
     application type divided by applications completed for all other
     application types.  We did not find a statistically meaningful
     relationship among these factors.  We did, however, find a
     statistically significant, positive relationship between the
     production rate for naturalization applications and the
     production rate for adjustment-of-status applications (Pearson
     correlation coefficient equaled 0.58, with a probability that
     the relationships was due to chance of less than 5 percent). 
     That is, districts with high production rates for one
     application type tended to have high production rates for the
     other application type. 

Finally, while we did not verify the accuracy of the adjudications
data received from INS, we obtained the comments of INS officials in
field units and headquarters on how data for the monthly
adjudications workload summary reports and productive hours are
accumulated, as well as what checks are performed to ensure the
quality and accuracy of the data.  These officials raised questions
about the reporting of productive hours and the definition of
naturalization application completions.  Accordingly, we performed
additional analyses of the data in an effort to determine their
validity. 

To analyze applications' processing times, we gathered processing
time reports (also called "aging reports") from INS headquarters
covering each district office for the same 25-month period--June 1994
through June 1996.  Processing time data were not readily available
for the service centers.  We focused our analyses on the
naturalization and adjustment-of-status applications because these
were the only applications for which INS collects timeliness data. 
Further, INS has made these application types its highest priority
for adjudication and the INS Commissioner has set specific processing
time goals for these two types of applications.  As with the
production rate data, at each INS office we visited we also obtained
the comments of INS field and headquarters officials on the accuracy
of the processing time data and what factors affect the usefulness of
the data. 

To determine the reasons for the differences in production rates and
projected processing times, we selected and visited 9 of INS' 33
district offices and 2 of its 4 service centers.  On the basis of our
analyses of the production data provided by INS, we selected five of
the relatively more productive district offices--Dallas, TX; El Paso,
TX; Houston, TX; Omaha, NE; and Seattle, WA--and four of the
relatively less productive district offices--Baltimore, MD; Buffalo,
NY; Kansas City, MO; and Los Angeles, CA--to visit.  In addition, as
part of our selection criteria, we factored in the relative volume of
applications received and applications' projected processing times. 
The service centers we visited were the California Service Center
(Laguna Niguel, CA) and the Texas Service Center (Irving, TX).  These
two service centers were chosen primarily on the basis of their
proximity to the selected district offices we visited. 

At each field unit, we gathered data on how production and processing
time data were collected and what checks were in place to ensure the
data's accuracy.  Generally, we met with Assistant District Directors
for Examinations and Service Center Directors, except when they
suggested that we meet with someone else on their staff.  We
discussed the unique characteristics of the various field units we
visited and what role these characteristics may have played in
affecting production rates and the timeliness of adjudications. 
Finally, we discussed the policies and procedures used by the field
units we visited.  Their comments are not generalizable to other
field units. 

INS processes asylum applications at eight offices nationwide. 
Because they are not processed at the district offices and service
centers, we excluded these applications from our review. 

In the report, we present average processing and timeliness data for
the 25-month period.  This was done for presentation purposes.  Our
analyses were done for each application type, by unit, and by month. 
We did the analyses by month because using averages over 25 months
could hide differences.  We performed our work between March 1996 and
April 1997 in accordance with generally accepted government auditing
standards. 


--------------------
\1 Naturalization and adjustment-of-status applications accounted for
about one-half of all completed applications in fiscal year 1996. 


INS FIELD UNITS' AVERAGE
PRODUCTION RATES AND AVERAGE
COMPLETIONS BY APPLICATION TYPE
FOR THE 25-MONTH PERIOD ENDING
JUNE 1996
========================================================== Appendix II



                                                                      Table II.1
                                                       
                                                         INS District Office Average Per Hour
                                                         Production Rates and Average Monthly
                                                       Completions by Application Type for the
                                                           25-Month Period Ending June 1996

                                                                                                                                                Other
                                         I-765                   N-400              I-130               I-90              I-485     Other      forms'
                                    completion              completion   I-130  completio    I-90  completio   I-485  completio    forms'  completion
District office         I-765 rate           s  N-400 rate           s    rate         ns    rate         ns    rate         ns   rate\ a        s\ a
----------------------  ----------  ----------  ----------  ----------  ------  ---------  ------  ---------  ------  ---------  --------  ----------
Anchorage, AK                 2.74          20        0.57          85    0.88         26    0.31         \b    0.41         36      0.07           3
Atlanta, GA                   4.55         587        0.84       1,212    0.91        336    1.79         33    0.64        772      0.07          42
Baltimore, MD                 0.76          96        1.09       1,384    0.32        216    0.28          1    0.37        468      0.05          40
Boston, MA                    4.39       1,358        0.73       2,086    0.68        517    0.74          7    0.73      1,010      0.04          45
Buffalo, NY                   2.10         260        0.56         415    1.13        556    0.17          7    0.41        192      0.15         201
Chicago, IL                   3.81       1,541        0.74       3,200    0.74        537    0.24          1    0.74      1,304      0.07          51
Cleveland, OH                 1.95         338        0.94         537    0.59        158    0.71          9    0.71        320      0.07          23
Dallas, TX                    3.09         634        0.97       1,153    0.93        249    1.56          8    1.03        894      0.04          17
Denver, CO                    2.22         351        0.86         565    1.05        210    0.04          1    0.88        506      0.04          15
Detroit, MI                   1.51         289        0.94         721    0.54        152    2.17        132    0.79        398      0.02          16
El Paso, TX                   3.06         337        1.83       1,277    1.26         79    0.48          2    1.28        341      1.11       1,563
Harlingen, TX                 3.00         310        0.66         442    0.69         70    0.42        173    0.47        152      0.46         503
Helena, MT                    1.43          67        0.40          67    0.60        140    0.37          2    0.41         72      0.05          29
Honolulu, HI                  1.99         261        0.45         532    0.83        305    2.04         45    0.32        247      0.08          52
Houston, TX                 2.78\c         437        1.18       1,383    1.10        186    2.88         31    0.62        630      0.08          31
Kansas City, MO               1.96         326        0.82         416    0.37        118    0.10          1    0.49        226      0.04          15
Los Angeles, CA               2.04         896        1.12      13,750    0.55        966    2.19          2    0.51      2,628      0.05         194
Miami, FL                     2.29       4,174        0.88       5,048    0.83      1,060    0.25         27    0.47      2,331      0.03          60
New Orleans, LA               2.04         354        0.65         631    0.68        170    0.90         39    0.50        375      0.04          21
New York, NY                  2.59       4,385        0.74       9,575    0.47      1,390    0.26          4    0.59      3,239      0.11         395
Newark, NJ                    1.81       1,143        1.59       3,086    1.03        429    0.79         40    0.64      1,562      0.04          34
Omaha, NE                     3.23         289        1.10         184    0.99         74    3.94         75    1.06        138      0.02           2
Philadelphia, PA              2.51         447        0.65         869    0.79        283    1.27          4    0.52        518      0.09          30
Phoenix, AZ                   3.77         740        0.60         928    0.71        192    1.51        665    0.47        524      0.39         751
Portland, ME                  1.34          43        0.35         113    0.43         38    0.10          3    0.43         50      0.01           5
Portland, OR                  1.89         277        0.93         349    1.14        108    1.50         \b    0.82        236      0.06           9
San Antonio, TX               3.24         556        0.78         807    0.65        179    0.74        203    0.84        473      0.63         670
San Diego, CA                 2.06         713        0.74       1,495    0.68        101    1.31        356    0.65        343      0.66       1,510
San Francisco, CA             2.63       2,832        0.57       5,730    0.71        740    0.86        167    0.52      1,836      0.03          48
San Juan, PR                  1.80         238        0.37         321    0.90        187    0.12          2    0.58        237      0.07          21
Seattle, WA                   3.78         501        1.34       1,171    0.79        259    0.42         29    0.85        537      0.06          64
St. Paul, MN                  4.11         294        0.53         419    1.03        631    0.41         11    0.50        254      0.04          16
Washington, D.C.              3.14         911        0.79       1,360    0.74        337    1.48         30    0.50        713      0.14          69
-----------------------------------------------------------------------------------------------------------------------------------------------------
\a The other application types ("other forms") represented a small
volume of applications, and therefore we did not analyze them
separately or as a group. 

\b Less than one completion per month on average. 

\c The Houston data for March 1996 seemed to contain an error (547
completions per hour).  Rather than attempt to determine the actual
number of completions and productive hours for March, we eliminated
the March data.  If we had included the March data, Houston's average
production rate would have been 24.59 completions per hour. 

Source:  GAO analysis of INS data. 



                                     Table II.2
                      
                        INS Service Center Average Per Hour
                        Production Rates and Average Monthly
                      Completions by Application Type for the
                          25-Month Period Ending June 1996

Se
rv
ic
e                                                                            Other
ce               I-765             I-130                I-90     Other      forms'
nt   I-765  completion   I-130  completi    I-90  completion    forms'  completion
er    rate           s    rate       ons    rate           s    rate\a         s\a
--  ------  ----------  ------  --------  ------  ----------  --------  ----------
Ca    4.28      15,434    4.20    14,357    5.31      16,009      0.22       1,356
 l
 i
 f
 o
 r
 n
 i
 a
Ne    4.02       5,125    2.85     6,349    4.09       5,708      0.41       3,453
 b
 r
 a
 s
 k
 a
Te    5.79      12,842    4.14    11,218    6.69      10,394      0.72       2,090
 x
 a
 s
Ve    3.11      14,238    3.07    13,905    3.17      10,697      0.28       2,028
 r
 m
 o
 n
 t
----------------------------------------------------------------------------------
Note:  The other application types ("other forms") represented a
small volume of applications, and therefore we did not analyze them
separately or as a group.  Generally, the service centers do not
process the N-400 and I-485.  The N-400 and I-485 are not included
with the other forms. 

Source:  GAO analysis of INS data. 




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



(See figure in printed edition.)


The following are GAO's comments on the Immigration and
Naturalization Service's April 22, 1997, letter.