Immigration Statistics: Status of the Implementation of National Academy
of Sciences' Recommendations (Letter Report, 06/09/98, GAO/GGD-98-119).

Pursuant to a congressional request, GAO provided information on the
implementation status of the major recommendations made by the National
Academy of Sciences (NAS) regarding the need to improve the collection
and management of immigration statistics.

GAO noted that: (1) the recommendations in the 1985 and 1996 NAS reports
proposed a range of corrective actions to address concerns about
unreliable immigration statistics; (2) generally, the 1985
recommendations focused on changing policies and procedures for
processing immigration statistics, and the 1996 recommendations
emphasized collecting more immigration statistics from new sources; (3)
specifically, the 1985 NAS report included 13 major recommendations that
action be taken to: (a) improve the process for collecting and reporting
immigration statistics; (b) issue policy statements regarding the
importance of producing quality and timely immigration statistics; and
(c) reorganize the Immigration and Naturalization Service (INS) and
increase INS' staff to improve its immigration statistical capabilities;
(4) all six 1996 NAS recommendations focused on the perceived need to
collect more immigration data from additional sources, such as the
Bureau of the Census' Current Population Survey; (5) GAO determined that
some actions had been taken to implement most of the 19 recommendations;
the majority of the recommendations were fully, substantially, or
partially implemented; (6) specifically, GAO determined that: (a) three
recommendations in the 1996 report had been fully implemented; (b) four
recommendations in the 1985 report and one recommendation in the 1996
report had been substantially implemented, which means the actions taken
were not in compliance with the technical aspects of the
recommendations, but the actions were generally responsive to and
consistent with the recomendations' purposes; (c) five recommendations
in the 1985 report and two recommendations in the 1996 report had been
partially implemented; and (d) three recommendations in the 1985 report
had not been implemented; (7) agency officials were developing plans to
implement one of the three recommendations during fiscal year 1998; and
(8) GAO did not categorize one of the recommendations to the Attorney
General because it was basically the same as another recommendation but
directed to INS.

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

 REPORTNUM:  GGD-98-119
     TITLE:  Immigration Statistics: Status of the Implementation of 
             National Academy of Sciences' Recommendations
      DATE:  06/09/98
   SUBJECT:  Immigration or emigration
             Immigration information systems
             Data collection
             Data integrity
             Population statistics
IDENTIFIER:  Census Bureau Current Population Survey
             
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Cover
================================================================ COVER


Report to Congressional Requesters

June 1998

IMMIGRATION STATISTICS - STATUS OF
THE IMPLEMENTATION OF NATIONAL
ACADEMY OF SCIENCES'
RECOMMENDATIONS

GAO/GGD-98-119

NAS Recommendations

(966702)


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

  DOJ - Department of Justice
  INS - Immigration and Naturalization Service
  NAS - National Academy of Sciences
  OMB - Office of Management and Budget

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


B-277650

June 9, 1998

The Honorable Stephen Horn, Chairman
The Honorable Dennis J.  Kucinich
Ranking Minority Member
Subcommittee on Government
 Management, Information and Technology
Committee on Government Reform and Oversight
House of Representatives

The Honorable Carolyn B.  Maloney
House of Representatives

The quality of immigration statistics has been a long-standing issue
among experts in the public and private sectors.  The National
Academy of Sciences (NAS) issued two reports\1 in which it made
recommendations regarding the need to improve the collection and
management of immigration statistics.  The recommendations were
directed to various federal organizations, including Congress, the
Department of Justice (DOJ), Immigration and Naturalization Service
(INS), Office of Management and Budget (OMB), and Bureau of the
Census. 

This report responds to your request that we provide information on
the implementation status of the major recommendations to Congress,
the agencies, and OMB in these reports.  Specifically, we summarized
NAS recommendations and determined what, if any, action Congress, the
agencies, and OMB took in response to the 13 major recommendations in
the 1985 NAS report\2 and all 6 recommendations in the 1996 NAS
report.  Also, in your request, you asked us to assess demographic,
statistical information on the foreign-born population and federal
policies affecting immigration statistics.  As agreed with your
Subcommittee, we will provide this information at a later date. 


--------------------
\1 Immigration Statistics:  A Story of Neglect, Daniel B.  Levine,
Kenneth Hill, and Robert Warren, eds., National Research Council,
National Academy Press:  Washington, D.C., 1985 and Statistics on
U.S.  Immigration:  An Assessment of Data Needs for Future Research,
Barry Edmonston, Ed., National Research Council, National Academy
Press, Washington, D.C., 1996. 

\2 The 1985 NAS report contained 38 recommendations to various
federal agencies involved in the collection of immigration
statistics.  Of those, NAS considered 13 to be major recommendations
because they required action and commitment at a high policy level
and because they were fundamental to the accomplishment of the key
goal--the ready availability of accurate, timely, and useful
statistical information on international migration. 


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

The recommendations in the 1985 and 1996 NAS reports proposed a range
of corrective actions to address concerns about unreliable
immigration statistics.  Generally, the 1985 recommendations focused
on changing policies and procedures for processing immigration
statistics, and the 1996 recommendations emphasized collecting more
immigration statistics from new sources.  Specifically, the 1985 NAS
report included 13 major recommendations that action be taken to (1)
improve the process for collecting and reporting immigration
statistics, (2) issue policy statements regarding the importance of
producing quality and timely immigration statistics, and (3)
reorganize INS and increase INS' staff to improve its immigration
statistical capabilities.  All six 1996 NAS recommendations focused
on the perceived need to collect more immigration data from
additional sources, such as the Bureau of the Census' Current
Population Survey. 

We determined that some actions had been taken to implement most of
the 19 recommendations; the majority (15) of the recommendations were
fully, substantially, or partially implemented.  Specifically, we
determined that

  -- three recommendations in the 1996 report had been fully
     implemented;

  -- four recommendations in the 1985 report and one recommendation
     in the 1996 report had been substantially implemented, which
     means the actions taken were not in compliance with the
     technical aspects of the recommendations, but the actions were
     generally responsive to and consistent with the recommendations'
     purposes;

  -- five recommendations in the 1985 report and two recommendations
     in the 1996 report had been partially implemented; and

  -- three recommendations in the 1985 report had not been
     implemented.  Agency officials were developing plans to
     implement one of the three recommendations during fiscal year
     1998. 

We did not categorize one of the recommendations to the Attorney
General because it was basically the same as another recommendation
but directed to INS.  We categorized the recommendation to INS as
substantially implemented. 


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

Immigration statistics are used to develop, execute, and evaluate
immigration policies.  However, experts in both the public and
private sectors, including many government agencies responsible for
the collection of immigration statistics, expressed concerns that
immigration statistics are inadequate, incomplete, and often
unreliable.  Among the most common concerns were that immigration
statistics do not accurately reflect the number and characteristics
of immigrant populations, or how immigrants fare after entry into the
United States.  During the 1980s, INS estimated that the United
States received about 6.3 million immigrants, or an average of
approximately 630,000 immigrants per year.  The volume increased in
the 1990s, with about 1 million immigrants arriving each year.  Given
that over a million immigrants arrive in the United States annually,
the need for reliable immigration statistics is crucial for
decisionmakers.  For example, information about changes in the rate
of arrival or departure of aliens, or their demographic
characteristics, could be important to decisions about changes in
immigration policies or services. 

In response to concerns about the quality of immigration statistics,
INS asked NAS to conduct two comprehensive reviews of federal
immigration statistics.  First, INS asked NAS to identify major
shortcomings in immigration statistics and to recommend appropriate
remedies and actions.  Second, INS, in conjunction with the National
Institute of Child Health and Human Development, asked NAS to assess
the current immigration data and to identify limitations.  These
requests resulted in the 1985 and 1996 NAS reports. 

Generally, the reports (1) identified deficiencies and limitations
with immigration statistics and (2) made recommendations for
improving the collection and management of immigration statistics. 
The 1985 NAS report identified significant problems with the
collection and management of statistical immigration data.  NAS found
that a statistical system to produce immigration data existed, but
that it was being neglected.  NAS pointed out that there was an
"extraordinary lack of concern with immigration data on the part of
many agencies and that this neglect extended throughout almost all
levels of responsibility within the agencies which are most directly
involved in the statistical data." Of the 13 major recommendations, 6
were addressed to INS, 3 were directed to Congress, 3 were directed
to OMB, and 1 was addressed to the Attorney General.  The
recommendation made to the Attorney General was separate, but similar
to one of the recommendations made to INS regarding the need to
provide more reliable data on immigration statistics. 

Similar to the 1985 NAS report, the 1996 NAS report addressed
limitations in immigration data.  In its 1996 report, NAS made six
recommendations--three to Census, two to INS, and one to statistical
agencies--to improve the data collection and analysis efforts of
federal statistical agencies.  Generally, the recommendations focused
on (1) the need for additional data sources for program and research
purposes and (2) modifications to existing immigration data sources
(e.g., adding new questions to and refining existing questions
contained in immigration data collection instruments).  Furthermore,
the 1996 report had a recommendation similar to NAS' 1985 report
recommendation dealing with obtaining data on new immigrants. 


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

To determine the actions taken by Congress, the agencies, and OMB in
response to the 19 NAS recommendations, we reviewed the NAS reports,
obtained the views of the agencies to which NAS directed the
recommendations, classified the status of the recommendations, and
discussed the reports with officials from the agencies and NAS
officials.  For the three recommendations directed to Congress, we
also considered any related actions that the agencies may have taken. 

To gain an understanding of the NAS recommendations, and the types of
problems the recommendations were designed to correct, we reviewed
the 1985 and 1996 NAS reports.  In addition, we met with
knowledgeable agency officials from INS, OMB, and Census to discuss
the recommendations.  Also, we had separate discussions with
individuals who worked on each of the NAS reports.  However, we did
not evaluate the merits of the recommendations or determine whether
the agencies could have or should have implemented them. 

To categorize the status of the recommendations, we used the
following categories.\3

  -- Fully implemented.  The entire recommendation, including all
     specified actions, had been fulfilled; the action taken was
     responsive to the letter of the recommendation and consistent
     with its purpose. 

  -- Substantially implemented.  While the action taken was not in
     compliance with the technical aspects of the recommendation, the
     action was generally responsive and consistent with the
     recommendation's purpose. 

  -- Partially implemented.  The recommendation has been implemented
     only in part but not fully or substantially. 

  -- Not implemented.  No part of the recommendation has been
     completed. 

To categorize the recommendations, we relied on information from the
agency responsible for implementing the recommendation and from our
prior knowledge on immigration-related issues.  We discussed the
implementation status with officials from INS, OMB, and Census.  INS
provided data on the status of the recommendations directed to the
Attorney General.  To obtain the official agency positions regarding
the NAS recommendations, we requested and received written replies
from INS, OMB, and Census.  For recommendations to Congress, we
reviewed immigration-related legislation and any related actions that
the agencies may have taken.  We did not verify the accuracy of the
agencies' responses because of the extensive work that would be
required on our part to analyze the actions they reported to have
taken.  However, in our analysis of their responses, we relied on our
prior immigration-related work, as applicable. 

We formed a three-member panel of our experienced staff to help in
our categorization of the status of the recommendation.  Two panel
members are knowledgeable about INS' immigration programs and
policies, and the other panel member has a design and methodology
background.  The panel members used the above categories to
independently categorize the status of the recommendations.  The
panelists then met and discussed their categorizations.  After their
discussion, they agreed on the categorization of 14 of the 18
recommendations.  For the four recommendations for which they did not
agree, the difference was only between adjacent categories (e.g.,
substantially implemented versus partially implemented).  The panel
members agreed not to categorize the one recommendation that was
similar but made separately to the Attorney General and INS. 

In categorizing the status of the recommendations, we did not focus
on the timeliness of the agencies' actions.  Also affecting our
categorizations of the status of the recommendations was the wording
of some of the NAS recommendations.  For example, one recommendation
required that action be considered; it did not actually require
action to be taken.  Therefore, any consideration by the agency or
OMB would constitute compliance with the recommendation. 
Accordingly, in such situations, we relied on the wording of the
recommendation for our categorization (i.e., we categorized the
recommendation in this case as implemented because the agency
considered taking action).  Also, in certain instances, several
agencies shared responsibility for implementing a recommendation.  In
these cases, we reviewed each agency's response separately, but made
a single determination as to the implementation status. 

In categorizing the recommendations, we relied on (1) the analysis of
the panel; (2) our past immigration work and the knowledge gained
from such work; (3) discussion with OMB, Census, and INS officials;
(4) written responses by these agencies on the status of the
recommendations; and (5) separate discussions with individuals who
worked on each of the NAS reports. 

We conducted our review from October 1997 to April 1998 in accordance
with generally accepted government auditing standards.  We requested
comments on a draft of this report from the Attorney General; the
Director, OMB; and the Commissioner, Bureau of the Census.  Their
comments are discussed at the end of this report. 


--------------------
\3 We previously used definitions similar to these when reporting on
the implementation status of the National Performance Review
recommendations (Management Reform:  Implementation of the National
Performance Review's Recommendations (GAO/OCG-95-1, Dec.  5, 1994);
Management Reform:  Completion Status of Agency Actions Under the
National Performance Review (GAO/GGD-96-94, June 12, 1996); and the
Blue Ribbon Panel recommendations (Customs Service:  Status of the
Implementation of Blue Ribbon Panel Recommendations (GAO/GGD-96-163,
Sept.  3, 1996). 


   NAS' RECOMMENDATIONS ADDRESS
   MANAGEMENT AND DATA COLLECTION
   CONCERNS
------------------------------------------------------------ Letter :4

The 19 recommendations in the 1985 and 1996 NAS reports addressed a
wide range of issues needed to improve the management and collection
efforts for immigration data.  The recommendations were directed to
Congress and those federal agencies involved in collecting
immigration data, especially INS because of its central role in
administering the flow of international migration to the United
States.  The most common problems addressed in the 1985 report were
management and data collection concerns.  The 1985 recommendations
were intended to improve the statistical gathering policies,
procedures, and programs.  The following are examples: 

  -- Most recommendations in the 1985 NAS report proposed creating
     new methodologies to collect better immigration data and to
     eliminate duplication.  One recommendation required the OMB
     Director to establish an interagency review group to examine
     consistency of immigration concepts and definitions used by
     individual agencies in the collection of immigration data. 

  -- Some recommendations in the 1985 NAS report urged that the
     production of quality immigration statistics be elevated to a
     high priority by issuing policy concerning the importance of
     reliable immigration statistics.  One recommendation proposed
     that the Attorney General issue a strong policy directive
     asserting the importance of reliable, accurate, and timely
     statistical information on immigration to the mission of INS and
     unequivocally committing INS to improving its existing
     capabilities. 

  -- Several recommendations proposed that INS, given its central
     role in assembling data on aliens, expand its immigration
     statistical capabilities.  NAS recommended that INS establish a
     Division of Immigration Statistics, which would have increased
     authority, responsibility, and professional staff. 

The 1996 NAS recommendations focused on efforts to improve the
collection of immigration data at federal statistical agencies.  All
of the 1996 recommendations focused on collecting more and better
immigration data from new sources.  For example, one 1996
recommendation urged that INS work with other federal agencies and
Census, under the overall direction of OMB, to include key
immigration questions on future censuses, including a question on
nativity and parental nativity, based on the requirements of the
Immigration Act of 1990. 


   MOST RECOMMENDATIONS ACTED UPON
------------------------------------------------------------ Letter :5

At least some action had been taken to implement most of the 1985 and
1996 NAS recommendations.  Tables 1 and 2 provide a summary of the
1985 and 1996 NAS recommendations, the agencies' views on the status
of the recommendations, and our categorization of the implementation
status.  As previously discussed, we did not categorize one
recommendation to the Attorney General because it was basically the
same as another recommendation directed to INS. 



                                     Table 1
                     
                        Implementation Status of 1985 NAS
                                 Recommendations

                                                              GAO's
Recommendation      Action taken                              categorization
------------------  ----------------------------------------  ------------------
Recommendation 1:   INS: Although no such directives were     Partially
Congress should     issued by Congress after the 1985 NAS     implemented.
strongly affirm     recommendation, the current INS
the importance of   Commissioner has provided formal          While Congress has
reliable,           internal and external statements          not taken the
accurate, and       committed to improving the accuracy and   recommended
timely statistical  timeliness of INS information.            action, the
information on                                                current INS
immigration to the                                            Commissioner has
needs of Congress                                             issued a statement
and direct the                                                concerning
Attorney General                                              improving the
to reexamine the                                              accuracy of INS
organizational                                                data and has
structure of INS                                              placed INS'
as it relates to                                              Statistical Branch
statistics, with a                                            under the
view to placing                                               Executive
greater priority                                              Associate
on this important                                             Commissioner for
task.                                                         Office of Policy
                                                              and Planning
                                                              (OPP).

Recommendation 2:   INS: INS said that the Immigration Act    Substantially
Congress should     of 1990 provided for a statistical        implemented.
require that the    information system as follows:
Attorney General                                              Congress took
prepare and submit  "(d)(1) The Commissioner, in              action by passing
by June 30 of each  consultation with interested              the Immigration
year an annual      academicians, government agencies, and    Act of 1990, which
report to the       other parties, shall provide for a        required INS to
President and       system for collection and dissemination,  produce an annual
Congress            to Congress and the public, of            report that
presenting data on  information (not in individually          contained specific
aliens admitted or  identifiable form) useful in evaluating   immigration data.
excluded,           the social, economic, environmental, and  INS produces an
naturalization,     demographic impact of immigration laws.   annual report, the
asylees, and                                                  Statistical
refugees;           (2) Such information shall include        Yearbook, which
describing their    information on the alien population in    contains much, but
characteristics;    the United States; on the rates of        not all, of the
and containing an   naturalization and emigration of          statistical data
analysis of         resident aliens; on aliens who have been  recommended by
significant         admitted, paroled, or granted asylum; on  NAS.
developments        nonimmmigrants in the United States (by
during the          occupation, basis for admission, and
preceding fiscal    duration of stay); on aliens who have
year in the         not been admitted or have been removed
immigration and     from the United States; on the number of
emigration field.   applications filed and granted for
                    cancellation of removal; and on the
                    number of aliens estimated to be present
                    unlawfully in the United States each
                    fiscal year.

                    (3) Such system shall provide for the
                    collection and dissemination of such
                    information not less often than
                    annually.

                    (e)(1) The Commissioner shall submit to
                    Congress annually a report that contains
                    a summary of the information collected
                    under subsection (d) and an analysis of
                    trends in immigration and
                    naturalization.

                    (2) Each annual report shall include
                    information on the number, and rate of
                    denial administratively, of applications
                    for naturalization, for each district
                    office of the Service and by national
                    origin group." 8 USC 1103

                    INS produces its Statistical Yearbook
                    annually to fulfill this requirement.
                    INS is examining the development of
                    regularly produced reports for various
                    data series, such as immigrants and
                    naturalizations, in order to make the
                    information provided in the Yearbook
                    more timely.

Recommendation 3:   INS: Congress has not mandated an         Partially
Congress should     immigrant adjustment study. However,      implemented.
mandate that a      federal agencies have taken the first
study be initiated  steps to establish a longitudinal study   While Congress has
and conducted       titled the New Immigrant Survey. INS is   not taken action,
among new           a major cosponsor of the survey, which    INS is in the
immigrants over a   is a pilot study to identify whether the  process of
5-year period, in   immigrant's address on the green card     conducting a
order to develop    application can be used to locate recent  study, which would
information for     immigrants. If proven successful, the     address this
policy guidance on  pilot may lead to a longitudinal study    recommendation.
the adjustment      of immigrant adaptation in the United     Therefore, we,
experience of       States. The study will also collect       along with INS,
families and        baseline information describing the       considered it to
individuals to the  characteristics of the immigrants when    be partially
labor market, use   they enter the United States. The pilot   implemented.
of educational and  test is currently in its second year,
health facilities,  and the researchers are concentrating on
reliance on social  determining the feasibility and costs of
programs, mobility  conducting such a study on a permanent
experience, and     basis.
income history.

Recommendation 4:   INS: Although no such policy directives   Not classified.
The Attorney        were issued by any Attorney General
General should      after the NAS recommendation, the         We did not
issue a strong      current INS Commissioner has provided     categorize this
policy directive    formal internal and external statements   recommendation to
asserting the       committed to improving the accuracy and   the Attorney
importance of       timeliness of INS information.            General because
reliable,                                                     the requirements
accurate, and                                                 for implementing
timely statistical                                            the recommendation
information on                                                were documented in
immigration to the                                            another 1985 NAS
mission of the INS                                            recommendation to
and unequivocally                                             the INS
committing the INS                                            Commissioner. (See
to improving its                                              Recommendation #5
existing                                                      in the 1985 NAS
capabilities.                                                 recommendations.)



Recommendation 5:   INS: The current Commissioner placed the  Substantially
INS should issue    Statistics Branch in the new OPP in       implemented.
an explicit         1994. One of OPP's explicit missions is
statement clearly   to "more effectively collect and          INS' Strategic
setting forth that  maintain statistical databases, produce   Plan includes a
the collection,     and disseminate timely statistical        mission statement,
cumulation, and     reports (many will be monthly) which are  which addresses
tabulation of       of direct relevance to program planning,  data integrity.
reliable,           monitoring and evaluation." OPP           This is consistent
accurate, and       functions include "directing the          with the
timely statistical  development of a Service-wide             recommendation
information on      statistical reporting system," and        that INS issue a
immigration is a    "maintaining and improving the            statement about
basic               Performance [Analysis] System (PAS) of    quality
responsibility and  program statistical reporting and         immigration data.
inherent in the     analysis."
mission of INS.
                    Improvements in data reliability and
                    accuracy have been explicit priorities
                    of the Service for several years.
                    Beginning in 1997, each of the INS
                    priorities had a data integrity
                    component and, beginning in 1998, "Data
                    Integrity and Integration" will be
                    consolidated under one priority.

                    The 1998 priority states that INS will
                    improve data integrity by focusing on
                    current and future data collection,
                    processing and reporting activities in
                    order to increase efficiency,
                    consistency, accuracy, and timeliness of
                    data availability. Efforts will be
                    concentrated on ensuring appropriate
                    data reporting for fiscal year 1998 and
                    fiscal year 1999, and pursuing initial
                    efforts required to maximize
                    effectiveness and efficiency in
                    complying with new Results Act
                    performance management requirements and
                    for satisfying other long-term data
                    needs. Functions to be addressed
                    include: field-level data collection and
                    reporting; collection and reporting
                    processes and automated systems support;
                    technical training and support to users;
                    and data reconciliation, analysis, and
                    validation of INS activities.

Recommendation 6:   INS: INS attempted to establish a Bureau  Not implemented.
INS should          of Immigration Statistics in its Fiscal
establish a         Year 1996 Budget to the Congress, but     Although INS
Division of         the request for 10 additional positions   created a new
Immigration         and $10 million for salaries and          office, OPP, in
Statistics,         expenses was eliminated in committee      1994, it does not
reporting directly  without comment. The budget request       carry out all of
to an associate     stated that the Bureau of Immigration     the functions
commissioner or an  Statistics would:                         specified in the
equivalent level,                                             recommendation. In
with overall        "collect, process, analyze and            addition, INS
responsibility      disseminate data useful in evaluating     stated that it had
for:                the social, economic, environmental,      not implemented
--ensuring the use  demographic and geographic impact of      this
of appropriate      immigration laws. The entity will         recommendation.
statistical         establish a statistical information
standards and       system in consultation with interested
procedures in the   government agencies and other parties to
collection of data  satisfy a number of criteria, including
throughout the      relevance to current social and economic
agency;             issues, timeliness in reflecting today's
--ensuring the      rapidly changing economic conditions,
timely publication  accuracy and consistently high
of a variety of     statistical quality, an impartiality in
statistical and     both subject matter and presentation."
analytic reports;
--providing
statistical
assistance and
direction to all
parts of the
agency to help in
carrying out their
mission; and
--directing
statistical
activities
throughout the
agency.

Recommendation 7:   INS: The Statistics Branch currently has  Partially
INS should direct   24 employees--14 professional and 10      implemented.
and implement the   clerical. The staff includes recognized
recruitment of a    subject-matter experts and persons with   INS has made
full complement of  graduate degrees in demography,           progress in
competent, trained  statistics, and sociology. There are      implementing this
professionals with  currently six analysts with degrees at    recommendation by
statistical         the doctoral level, whereas none were     hiring some
capabilities and    employed at that level in 1985. Four      trained
subject-area        analysts have been hired over the past 2  professional staff
expertise.          years. The other professional employees   to work in the
                    consist of management analysts and        Statistical
                    computer specialists who work on the      Branch.
                    systems to collect, process, and
                    tabulate INS data.

Recommendation 8:   INS: The Statistics Branch does not have  Not implemented.
INS should          a standing advisory committee but has
establish an        brought in advisers several times to      INS considers that
advisory committee  review existing data systems and to       it has partially
composed of         comment on current products. For          implemented this
experts in the use  example, INS collaborated with the        recommendation.
and production of   National Institute of Child Health and    Although INS used
immigration-        Development to fund the National Academy  outside advisers
related data, to    of Science Workshop titled "Statistics    on an ad hoc
advise the          on U.S. Immigration: An Assessment of     basis, INS did not
associate           Data Needs for Future Research." NAS      establish a
commissioner and    provided recommendations on improving     standing advisory
the proposed        immigration statistics that were          committee as
Division of         published in 1996. Groups of outside      directed in the
Immigration         experts have also provided comments on    recommendation. In
Statistics of       current methodologies, such as the        our opinion, using
needs for new or    estimates of the illegal immigrant        advisers on an ad
different types of  population. INS plans to continue to use  hoc basis is not a
data; to review     outside experts on an ad hoc basis        substitute for a
existing data and   rather than through a standing committee  standing advisory
data collection     to better address the variety of data     committee.
methodology; and    specialties and methodologies used to
to provide the      make estimates.
Service with
independent
evaluation of its
statistical
products, plans,
and performance.

Recommendation 9:   INS: The Statistics Branch initiated a    Partially
INS should          meeting of federal agencies involved in   implemented.
establish a formal  the collection and use of immigration
liaison with other  statistics in December 1991. This group   INS considers that
federal and state   has met quarterly since then and has      it has implemented
agencies involved   improved information sharing and          this
in the collection   cooperation among the federal and         recommendation.
or analysis of      congressional members. For example, this  While INS has
immigration-and     group identified the need for "country    established a
emigration-         of birth" to be added to the control      liaison with
related data.       card in the monthly Current Population    federal agencies
                    Survey, and beginning in 1994, several    and is scheduled
                    of the agencies provided funds to Census  to meet regularly
                    to collect country of birth data. The     with them, state
                    group also evaluated existing             agencies did not
                    longitudinal studies involving            participate. NAS
                    significant immigrant populations, and    recommended that
                    participant agencies helped fund the New  not only federal
                    Immigrant Survey pilot survey.            but state agencies
                                                              are to
                                                              participate.

Recommendation 10:  INS: Almost all of INS' data originate    Not implemented.
INS should          from administrative records rather than
initiate a review   surveys. There has not been a             INS considers that
of all data-        comprehensive review of these forms to    it has partially
gathering           eliminate duplication and evaluate data   implemented this
activities to       needs. In fiscal year 1998, however, the  recommendation.
eliminate           issues of duplication, data needs and     However, it has
duplication,        gaps, and standardization of concepts     not conducted a
minimize burden     will be addressed in the 1998 priority    comprehensive
and waste, review   titled "Data Integrity and Integration."  review of
specific data       The specific plans for the priority are   immigration data
needs and uses,     currently under development. INS has      to eliminate
improve question    developed a plan to implement a           duplication.
wording and format  corporate information system structure    Furthermore, as
design,             that will ensure that all systems use     INS stated, it is
standardize         the same definitions and will allow for   currently
definitions and     consistent information across all INS     developing plans
concepts, document  systems.                                  to address
methodologies,                                                specific issues.
introduce
statistical
standards and
procedures, and
promote
efficiencies in
the use of staff
and resources.

Recommendation 11:  OMB: OMB is responsible for reviewing     Substantially
OMB should ensure   agency management activities and budget   implemented.
that it exercises   requests in support of the Executive
its                 Office of the President and the           OMB reviews the
responsibilities    President's annual budget submission to   INS statistical
to monitor and      Congress. OMB provided the same level of  activities as part
review statistical  scrutiny to INS' statistical program as   of its annual
activities and      other INS programs. In fiscal year 1998,  budget review and
budgets concerning  in response to an INS request, OMB        is to ensure that
statistics on       recommended an enhancement of 15          all data collected
immigration and     positions and $7 million to support the   meet the
emigration,         agency's statistical analysis program.    requirements of
particularly those  Also, OMB recommended that the INS        the Paperwork
of the INS, to      statistical program provide the baseline  Reduction Act.
minimize            and annual measurements/estimates to
duplication and     support the agency's performance
ensure that         measurement system. INS currently
appropriate         estimates the number of illegal aliens
procedures are      residing in the United States and the
used; standards     increment of new illegal aliens arriving
are met; and        annually. Both the total number of
priorities are      illegal aliens and the rate of illegal
observed in the     entry can be useful in measuring the
collection,         success of INS performance in deterring
production, and     illegal entry at the borders and in
publication of      effectively removing those who attempt
such data.          to remain illegally. INS is in the
                    process of improving its statistical
                    models to begin to measure performance
                    at both local levels and in the
                    aggregate for the illegal immigrant
                    population as a whole.

                    INS' statistical program is required to
                    support decisionmaking by providing data
                    that measures the scope of illegal
                    immigration and that can be used by the
                    administration and Congress to recommend
                    policy options. OMB fully supports this
                    central role for the INS statistical
                    policy operation.

                    According to OMB, its responsibility
                    under the Paperwork Reduction Act is to
                    ensure that all data collected maximize
                    practical utility and minimize burden,
                    thus providing broad level of quality
                    assurance. OMB added that it is not
                    responsible for conducting quality
                    evaluations.

Recommendation 12:  OMB: An Interagency Task Force has been   Partially
OMB should require  advising INS on data-related issues       implemented.
and establish an    since December 1991. INS reports that
interagency review  the other agencies have been very         While OMB relied
group responsible   active. The accomplishments of the Task   on INS to advise
for direction and   Force have been substantial.              it on immigration
coordination in                                               data issues, OMB
the field of                                                  did not establish
immigration and                                               an interagency
emigration data;                                              review group to
the group would                                               carry out the
examine                                                       duties specified
consistency and                                               in the NAS
comparability in                                              recommendation.
concepts and
definitions used
by individual
organizations in
the collection of
such information
and oversee the
introduction and
use of
standardized
approaches.

Recommendation 13:  OMB: Since 1985, there have been          Substantially
OMB should          significant improvements in the data      implemented.
actively encourage  provided by INS. In 1986, the Yearbook
and support the     was improved by including text            INS is publishing
timely publication  describing data quality and analysis of   an annual
and dissemination   trends, preparing the publication via     statistical
of data on          desktop publishing, and making it more    publication. Also,
immigration and     timely. Fully documented public-use       public-use tapes
emigration; the     tapes have been available since about     are available.
ready availability  1990; more recently, data are being made
of fully            available on the Internet.
documented public-
use data tapes,
including samples
of individual
records without
identifiers where
feasible; and data
summaries.
--------------------------------------------------------------------------------
Source:  GAO classification of the status of NAS recommendations. 



                                     Table 2
                     
                      Implementation Status of the 1996 NAS
                                 Recommendations

                                                              GAO's
Recommendation      Action taken                              categorization
------------------  ----------------------------------------  ------------------
Recommendation 1:   OMB: The Interagency Task Force on        Substantially
NAS urged that INS  Immigration consists of representatives   implemented.
work with other     of federal agencies with an interest in
federal agencies    immigration (including Census). It has    While not under
and Census, under   been meeting regularly since December 9,  OMB guidance, the
the overall         1991, under the sponsorship of INS. Two   Interagency Task
direction of OMB,   OMB representatives attended the initial  Force, consisting
to include key      meeting, and received the minutes of      of representatives
immigration         each meeting for several years            from various
questions on        thereafter. The Interagency Task Force    federal agencies,
future censuses,    was not directed by OMB; rather, it was   (including INS and
including a         chaired and guided by INS. OMB monitored  Census, with some
question on         the progress of the Interagency Task      OMB participation)
nativity and        Force and its accomplishments. The Task   worked to have
parental nativity,  Force has developed ideas and programs    nativity and
based on the        to improve immigration statistics in a    parental nativity
requirements of     variety of ways, such as including data   questions put on
the Immigration     on temporary migrants, using data from    the Current
Act of 1990.        longitudinal surveys, adding immigration  Population Survey.
                    data in the Current Population Survey,    While including a
                    and increasing exploitation of            question on
                    administrative data.                      nativity, a
                                                              question on
                    The proposed Census 2000 questionnaire    parental nativity
                    does include a question on nativity, but  will not be
                    does not include a question on parental   included on the
                    nativity. The contents of the 2000        Census 2000
                    Census have been restricted to items      questionnaire.
                    that are required by law. While nativity  According to OMB,
                    is required according to the Immigration  INS, and Census,
                    Act of 1990, that law does not require    the Immigration
                    parental nativity. The Task Force did     Act of 1990 does
                    ensure that information on nativity and   not specifically
                    parental nativity is collected in the     require that
                    Current Population Survey.                parental nativity
                                                              information be
                    INS: Current plans call for the           collected. The
                    respondent's nativity, but not their      contents of the
                    parental nativity, to be collected in     Census 2000 have
                    the Census 2000. INS stated that while    been restricted to
                    parental nativity is useful for           items that are
                    identifying the children of immigrants,   required by law.
                    the Immigration Act of 1990 does not
                    specifically require that this
                    information be collected.

                    Census: Questions on citizenship have
                    appeared on the decennial census form on
                    a continuous basis since 1890. Place of
                    birth, year of entry (for those born
                    outside the United States), and
                    citizenship will be subjects on the
                    Census 2000 questionnaire. However,
                    other questions that relate to parental
                    nativity will not be included on the
                    proposed Census 2000 questionnaire.
                    Beginning in December 1992, OMB, in
                    conjunction with Census, asked federal
                    agencies to provide information
                    describing their data needs. In the
                    summer of 1994, Census completed its
                    review of the responses from the
                    agencies. Each data need was classified
                    using a rather narrow legalistic
                    topology to determine if a subject
                    should be classified as mandatory,
                    required, or programmatic. Only subjects
                    for which federal laws explicitly
                    mandated or required decennial census
                    data were recommended to Congress by
                    Census for inclusion in Census 2000.
                    Some subjects, such as parental
                    nativity, were not recommended since the
                    review found that these subjects were
                    needed only for program planning,
                    implementation, or evaluation and that
                    there were no explicit requirements for
                    the use of the census data in federal
                    law.

Recommendation 2:   Census: Census considered creating a      Fully
NAS recommended     Public Use Microdata Sample for the 1990  implemented.
that Census         census containing local-area contextual
consider ways to    data. An informal working group           Census has
add local-area      investigated the issue and concluded      considered ways to
contextual data in  that (1) the disclosure avoidance         add local-area
the Public Use      procedures used in the 1990 census to     contextual data in
Microdata Sample    ensure confidentiality of respondents     the Public Use
files. Contextual   would have been compromised by adding     Microdata Sample
data on such        local-area data, which could lead to      for the 1990
variables as local  identifying specific individuals; and     census.
employment,         (2) although the Russell Sage Foundation
income, education,  was willing to fund the inclusion of
and racial and      contextual data, formal research was
ethnic composition  needed to resolve the technical issues,
would measurably    which would have required additional
improve this        staff, time, and resources that Census
important data set  did not have at the time. Census decided
for academic and    that contextual data such as local
policy research on  employment rates, income, and
immigrants.         educational attainment will not be
                    available in the Public Use Microdata
                    Sample files of Census 2000 data.
                    According to Census, a key reason for
                    not including these types of contextual
                    variables in the Census 2000 Public Use
                    Microdata Sample is that addition of
                    these variables could compromise the
                    confidentiality of census data.

Recommendation 3:   Census: Beginning in 1994, information    Fully
NAS applauded the   on nativity, parental nativity, year of   implemented.
introduction of     entry, and citizenship was collected for
key questions on    all members of the Current Population     Census has
nativity as a       Survey households in the initial          indicated that it
regular part of     interview. Census plans to continue       plans to retain
the Current         collecting this information.              key immigration-
Population Survey.                                            related questions
Questions on                                                  on the Current
nativity, parental                                            Population Survey.
nativity,
citizenship, and
year of entry into
the United States
provide
information
essential to the
understanding of
immigration in
this country. NAS
urged Census to
retain these key
immigration-
related topics on
the Current
Population Survey.

Recommendation 4:   Census: Census is currently exploring     Partially
NAS recommended     the feasibility of conducting a special   implemented.
that Census, in     supplement to the Current Population
consultation with   Survey about emigration (that is, about   Census is
federal agencies    persons who leave the United States).     currently
and immigration     Emigration is one of the key components   reviewing the
researchers,        required for estimates and projections    possibility of
review the          of the U.S. population. Census officials  adding special
possibility of      believe that the earliest feasible date   immigration
adding special      for incorporating a supplement on         questions to the
immigration         emigration on the Current Population      Current Population
questions to the    Survey is early 2000. Census plans to     Survey, but has
Current Population  continue its efforts to determine if      not completed the
Survey.             funding and staff can be made available   effort.
Additional, more    for the conduct of this supplement.
detailed
immigration-
related questions
would enhance the
value of the
Current Population
Survey data for
immigration policy
research. Such
questions might be
included on the
Current Population
Survey on a
special basis,
perhaps on one of
the special
monthly
supplements, or on
a periodic basis,
depending on the
purpose and
usefulness of the
data.

Recommendation 5:   Census: Census has been in contact with   Fully
NAS recommended     its counterpart institution in Mexico     implemented.
that federal        (the National Institute for Statistics,
statistical         Geography, and Data Processing)           Census officials
agencies meet with  regarding issues that relate to           met with their
their counterpart   population flows between the United       Mexican
institutions in     States and Mexico. In November 1997,      counterparts to
Mexico to discuss   demographers and other technicians from   discuss exchanging
the potential for   the National Institute for Statistics,    immigration data.
establishing joint  Geography, and Data Processing met with
surveys on          Census' staff in Suitland, Maryland, to
immigration. Such   discuss potential exchange of data and
a meeting should    other information pertaining to
include key         population flows between the United
immigration         States and Mexico. Census will continue
researchers from    working with this agency. However, a
both countries.     joint survey on immigration will not
                    occur in the foreseeable future unless
                    additional funding can be found for this
                    effort.

                    INS: U.S. and Mexican scholars
                    collaborated on a joint report on
                    Mexican immigration to the United
                    States. The Commission on Immigration
                    Reform published the Binational Study of
                    Migration between Mexico and the United
                    States in September 1997. INS and
                    Consejo Nacional de Poblaciï¿½n (National
                    Population Council), which is the
                    Mexican Statistical Agency, have also
                    begun discussions to develop a
                    memorandum of understanding to consult
                    with each other on various projects and
                    to share information.

Recommendation 6:   INS: INS is a major cosponsor with the    Partially
NAS recommended     National Institute of Child Health and    Implemented.
that INS establish  Human Development of the New Immigrant
the design and      Survey, which is a pilot study to         INS is
usefulness of a     identify whether the immigrant's address  cosponsoring a
survey of green     on the green card application can be      pilot study to
card applicants. A  used to locate recent immigrants. If      determine the
survey of new       proven successful, this pilot may lead    usefulness of
immigrants appears  to a longitudinal study of immigrant      using the
to be feasible,     adaptation in the United States. The      immigrant's
using the           study will also collect baseline          address on the
relatively          information describing the                green card
accurate addresses  characteristics of the immigrants when    application to
that are provided   they enter the United States.             locate recent
by immigrants in                                              immigrants.
order to receive
their permanent
resident visa.
--------------------------------------------------------------------------------
Source:  GAO classification of the status of NAS recommendations. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :6

To obtain agency comments on a draft of this report we met separately
with officials from OMB, including the Assistant Branch Chief, Human
Resources and Housing Branch, Office of Information and Regulatory
Affairs; Justice, including the Director, Statistics Branch, OPP,
INS; and Census, including the Associate Director for Demographic
Programs.  These officials said that they agreed with our report. 
They provided additional information, which we incorporated as
appropriate.  On the basis of discussions with OMB officials and the
additional information they provided, we changed our original
categorization of three recommendations. 


---------------------------------------------------------- Letter :6.1

We are providing copies of this report to the Chairmen and Ranking
Minority Members of other committees with jurisdiction over
immigration issues; the Attorney General; the Commissioner, INS; the
Director, OMB; the Secretary of Commerce; and the Commissioner,
Bureau of the Census.  We will also make copies available to others
on request. 

Major contributors to this report are James M.  Blume, Assistant
Director, and Mary B.  Hall, Evaluator-in-Charge.  Please call me on
(202) 512-7997, if you or your staff have any questions. 

Susan S.  Westin
Associate Director
Advanced Studies and Evaluation
 Methodology Group


*** End of document. ***