Immigration Statistics: Guidance on Producing Information on the U.S.
Resident Foreign-Born (Letter Report, 07/22/1998, GAO/GGD-98-155).

The makeup of the foreign-born population living in the United States
continues to interest policymakers as they debate immigration issues.
These policymakers have expressed concern that the information needed to
make informed decisions on immigration policy either has been
unavailable or inadequate. This report, one in a series, identifies
federal guidance on the production of demographic information on
foreign-born residents and provides information on agencies' status
relative to that guidance. GAO (1) identifies the federal guidance
available to the agencies responsible for collecting, analyzing, and
disseminating information on the foreign-born and (2) provides
information that compares the agencies to federal guidance on
independence, capacity to provide information, and efforts to coordinate
the production of information, which includes statistical data on the
foreign-born.

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

 REPORTNUM:  GGD-98-155
     TITLE:  Immigration Statistics: Guidance on Producing Information
	     on the U.S. Resident Foreign-Born
      DATE:  07/22/1998
   SUBJECT:  Data collection
	     Data integrity
	     Government information dissemination
	     Interagency relations
	     Statistical data
	     Immigration information systems
	     Aliens
	     Census
	     Statistical methods

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GAO/GGD-98-155

Cover
================================================================ COVER

Report to Congressional Requesters

July 1998

IMMIGRATION STATISTICS - GUIDANCE
ON PRODUCING INFORMATION ON THE
U.S.  RESIDENT FOREIGN-BORN

GAO/GGD-98-155

Producing Information on the U.S.  Resident Foreign-Born

(966703)

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

  CPS - Current Population Survey
  FTE - Full-time equivalent
  HHS - Department of Health and Human Services
  INS - Immigration and Naturalization Service
  NAS - National Academy of Sciences
  OIRA - Office of Information and Regulatory Affairs
  OMB - Office of Management and Budget
  PAS - Performance Analysis System

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

B-278387

July 22, 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 makeup of the foreign-born population residing in the United
States continues to interest policymakers as they debate immigration
issues.  These policymakers have expressed concerns that the
information necessary to make informed decisions on public policy
regarding immigration either has not been available or has not been
adequate.  Accordingly, you requested that we review the federal
immigration statistics function.  You asked us to (1) follow up on
two reports of the National Academy of Sciences (NAS)\1 that contain
recommendations designed to streamline and strengthen the collection,
analysis, and dissemination of immigration statistics; (2) assess the
quality of current federal demographic information on the
foreign-born population; and (3) identify the federal guidance on the
production of demographic information on foreign-born residents and
provide information on agencies' status relative to that guidance.

This report responds to the third objective of your request.
Objectives 1 and 2 are addressed in separate reports.\2

Specifically, this report

  -- identifies the federal guidance available to the agencies
     responsible for collecting, analyzing, and disseminating
     information on the foreign-born and

  -- provides information that compares the agencies to federal
     guidance on (1) independence, (2) capacity to produce
     information, and (3) efforts to coordinate the production of
     information, which includes statistical data on the
     foreign-born.

To determine which agencies were responsible for producing the
majority of the statistics on the foreign-born, we synthesized
literature reviews, agency documents, and testimonial evidence from
agency officials and knowledgeable experts and identified the
principal agencies that generated statistical information on the
foreign-born:  Immigration and Naturalization Service (INS)\3 and the
U.S.  Bureau of the Census.\4 We then verified our selection with
officials from the Office of Management and Budget (OMB) and from the
agencies we had tentatively selected.  Three other agencies that
collect specialized information on the foreign-born are (1) the
Office of Refugee Resettlement of the Department of Health and Human
Services (HHS); (2) the Immigrant Visa Control and Reporting Division
of the Department of State; and (3) the Population, Refugees, and
Migration Bureau of the Department of State.

In developing the information for this report, we interviewed--and
analyzed relevant documents provided by--officials from OMB and the
two principal agencies as well as experts in the area of federal
statistical information in general and on the foreign-born
population.  We also drew upon our current and prior work on
statistical information on foreign-born residents.  To identify the
federal guidance affecting the production of statistics on the
foreign-born, we talked to officials from OMB, Census, and INS and
experts on immigration issues.  To provide information on the two
agencies' independence, capacity to produce statistical information,
and interagency coordination efforts, we developed indicators using
applicable criteria from current federal guidance on how statistical
agencies should operate.  We examined the two agencies' statistical
activities in relation to the indicators we derived from NAS guidance
to make our comparisons regarding the elements of independence,
capacity to produce statistical information, and interagency
coordination.

We requested comments on a draft of this report from the Director of
OMB, the Attorney General, and the Secretary of Commerce.  OMB and
the Attorney General provided oral comments, which we discuss near
the end of this report.  The Department of Commerce had no comments
on the report.  We did our work in Washington, D.C., between October
1997 and July 1998 in accordance with generally accepted government
auditing standards.\5

--------------------
\1 NAS is a private, nonprofit society of scholars established by
Congress in 1863 to advise the federal government on scientific and
technical matters.

\2 Immigration Statistics:  Status of the Implementation of National
Academy of Sciences' Recommendations (GAO/GGD-98-119, June 9, 1998)
and a companion report that will be issued shortly.

\3 Within INS, our work involved reviewing the efforts of the
Statistics Branch, which produces information on the foreign-born.

\4 Within the Census Bureau, we focused on the Population Division's
efforts because Census' information on the foreign-born is produced
by staff in that division.

\5 App.  I describes in detail the scope and methodology of our work.

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

Standards and guidance covering the production of all federal
statistical information, including statistics on the foreign-born,
have been issued by two sources.  First, governmentwide guidance has
been issued by OMB, which is legislatively charged with ensuring that
agencies' statistical activities follow federal statistical
standards.  OMB's guidance includes uniform standards for the
compilation and release of all federal statistical data.

Second is NAS' report, Principles and Practices for a Federal
Statistical Agency, which provides guidance to executive branch
agencies on how to compile and release statistical information and
suggests practices for achieving independence, the capacity to
produce information, and coordination.\6 According to OMB and NAS,
the existing federal guidance provides statements of best practices,
which are intended as suggestions, not prescriptions.

The Bureau of the Census and INS differed from each other in their
structure and mission, and thus their independence, capacity, and
coordination varied.  For example, according to Census Population
Division officials, the Census Bureau, structured as a statistical
agency with a primary mission of collecting and disseminating
statistical information, has incorporated the elements of the NAS
guidance in generating information on the foreign-born.
Specifically, Census has procedures in place to protect its
independence, it has the capacity to produce information, and it
coordinates with other statistical agencies.

In contrast, INS' Statistics Branch, a self-described data collection
and analysis unit, has incorporated some, but not all, of the
elements of independence and many of the elements of capacity and
coordination.  For example, it was not established by statute as an
independent entity.  Officials said the branch has been working to
improve its capacity and coordination by hiring qualified
professional staff and by coordinating its statistical activities
with other agencies that produce data on the foreign-born.

--------------------
\6 Principles and Practices for a Federal Statistical Agency
(Washington, D.C.:  National Academy Press, 1992).

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

For this report, we define the following terms:

  -- "Foreign-born" refers to all persons who were born abroad to
     parents who were not U.S.  citizens, and who now either (1) are
     in a permanent legal status (naturalized citizen, legal
     permanent resident, refugee, person granted asylum) or (2) are
     in a temporary legal status (tourists, business people, and
     students) or in the United States illegally but who remain here
     for over a year.

  -- "Independence" is derived from elements of NAS' guidance
     intended to provide an agency with freedom from influence by
     others in the production of its statistical products.

  -- "Capacity to produce statistics" refers to elements that we
     derived from NAS' guidance that provide for a clearly defined
     and well-accepted mission and commitment to quality and
     professional standards.  This definition also includes an
     ability to comply with legal and administrative
     responsibilities, such as congressional reporting requirements
     or contractual arrangements with other agencies.

  -- "Coordination" refers to elements that we derived from NAS'
     guidance that suggest cooperation with data users and
     coordination with other statistical agencies.

NAS defines a federal statistical agency as a unit of the federal
government whose principal function is the compilation and analysis
of data and the dissemination of information for statistical
purposes.  NAS further states, "The unit must be generally recognized
as a distinct entity."

NAS' Committee on National Statistics is comprised of professionals
in the statistical field who have no direct relationship with the
federal government.  Since its founding, the Committee on National
Statistics has concentrated on reviewing selected federal statistics.
It also prepares reports on special studies it carries
out--independently or under contract--that are intended to improve
the effectiveness of the federal statistical system.

The activities, budgets, and staffing of INS' Statistics Branch and
the Census Bureau, as well as their principal products related to the
foreign-born, are as follows.\7

--------------------
\7 App.  II provides more detail.

      INS' STATISTICS BRANCH
---------------------------------------------------------- Letter :2.1

INS' Statistics Branch is responsible for preparing reports on
operational and demographic statistics, monitoring the information
system's reliability, and advising other INS offices on sampling and
other statistical applications.  Some of the branch's reports are
used for internal programmatic purposes, and others are used by
Congress, federal agencies, and others interested in information on
the foreign-born.  The branch is located within the Office of Policy
and Planning, which was created in a major INS reorganization in 1994
to reinforce Servicewide planning and provide attention to
macro-level immigration policy.  The branch's fiscal year 1998 budget
was $1.4 million, and in March 1998, the branch had a staff of 24
full-time-equivalent positions, 22 of which were filled.  The branch
is responsible for INS' primary statistical publication, the annual
Statistical Yearbook of the Immigration and Naturalization Service.
Although the Yearbook has been published since 1892, the Immigration
Act of 1990 (P.L.  101-649, section 142, codified at 8 U.S.C.
1103(d)\8 ) specified the selected reporting requirements.  Also
published annually are the Commissioner's Fact Book and Immigration
Advance Reports.

--------------------
\8 This report was not intended to be a comprehensive analysis of all
statutes relating to statistical information on the foreign-born.
Accordingly, this report focuses on 8 U.S.C.  1103(d).

      CENSUS BUREAU'S POPULATION
      DIVISION
---------------------------------------------------------- Letter :2.2

The Population Division's fiscal year 1998 budget was $31 million.
The division has two full-time demographers who specialize in
information on the foreign-born.  These demographers, supported by
other Census staff, collect and analyze information on the
foreign-born and implement an interagency agreement with INS for
providing this type of information.  Two Census Bureau products
represent a source of immigration information:  (1) estimates and
projections, which are published in Census' Current Population
Reports, are based on data from INS and the decennial census and (2)
the Current Population Survey (CPS).  Customers for this information
include Congress, federal agencies, state and local governments, the
private sector, the academic community, research organizations,
libraries, and individuals.

   TWO SOURCES GUIDE THE
   PRODUCTION OF FEDERAL
   STATISTICAL INFORMATION
------------------------------------------------------------ Letter :3

As required by the Paperwork Reduction Act, official guidance
covering the production of all federal statistical information,
including statistics on the foreign-born, is to be issued by OMB.
NAS has also issued guidance for agencies that produce statistical
information.  Governmentwide statistical guidance has been issued by
OMB, in its Statistical Policy Handbook and subsequent statistical
policy directives.  The other source of guidance is NAS' 1992 report,
Principles and Practices for a Federal Statistical Agency, which
provides guidance to executive branch agencies on how to compile and
release statistical information, specifies best practices that may be
used to achieve independence, the capacity to produce information,
and coordination with data users and other agencies.  The NAS
guidance has been used by us and NAS to carry out studies of
statistical agencies.\9 We used the guidance in our current work to
gather and present information on aspects of independence, capacity,
and coordination in the production of information on the
foreign-born.

--------------------
\9 Statistical Agencies:  Adherence to Guidelines and Coordination of
Budgets (GAO/GGD-95-65, Aug.  9, 1995) and The Bureau of
Transportation Statistics:  Priorities for the Future (Washington,
D.C.:  National Academy Press, 1997).

      OMB'S GUIDANCE
---------------------------------------------------------- Letter :3.1

OMB's guidance is aimed at federal statistical agencies.  The need
for strong oversight and coordination of the decentralized federal
statistical system was recognized in law by the enactment of the
Paperwork Reduction Act of 1980, codified at 44 U.S.C.  3501.\10 The
act created the Office of Information and Regulatory Affairs (OIRA)
in OMB and assigned the Director of OMB and the Administrator of OIRA
the responsibility for overseeing the federal statistical system and
coordinating its activities.  OIRA's Statistical Policy Branch
functions include

  -- developing and implementing governmentwide policies, principles,
     standards, and guidance concerning data sources, data collection
     procedures and methods, and data dissemination and

  -- evaluating statistical program performance and agency compliance
     with governmentwide policies, principles, standards, and
     guidance.

OMB established governmentwide uniform statistical standards and
guidance for the collection and compilation of statistical data and
for the release and publication of federal statistics.  According to
OMB, the standards and guidance are intended to result in several
benefits, including greater efficiency in the design and conduct of
statistical surveys, reduction in reporting burdens on respondents,
greater uniformity and comparability among statistical series and
studies, and improved accuracy and timeliness of statistical data.
OMB also encourages the use of NAS' Committee on National Statistics
as an independent adviser and reviewer of federal statistical
activities.

--------------------
\10 In addition, the Budget and Accounting Procedures Act of 1950 and
the Paperwork Reduction Act of 1995 granted OMB general statutory
responsibility for developing statistical standards and definitions.

      NAS' GUIDANCE
---------------------------------------------------------- Letter :3.2

NAS' Committee on National Statistics developed guidance that it
believes comprises "fundamental characteristics that define a
statistical agency and its operations." The guidance is contained in
NAS' 1992 report, which the committee prepared partially in response
to requests from congressional and executive branch officials for
advice on what constituted an effective federal statistical agency.
The committee also prepared the report because it was concerned that
federal statistical agencies sometimes might not meet what it
considered to be acceptable professional standards.

According to NAS, the guidance contains principles and practices,
consistent with current laws and statistical theory, that are
statements of "best practices," rather than legal requirements or
scientific rules.  In its report, NAS also provided guidance that it
considered important for the proper functioning of a statistical
agency.\11 This guidance includes a strong measure of independence,
the capacity to produce statistics, and coordination with statistical
agencies and data users.

--------------------
\11 According to NAS, "Although focused on federal statistical
agencies, many of the principles and practices presented [in its
report] also apply to statistical activities elsewhere."

         INDEPENDENCE
-------------------------------------------------------- Letter :3.2.1

The guidance included suggestions for ensuring that a statistical
agency have a strong measure of independence, noting that the
circumstances of different agencies may govern the exact form that
independence takes and that not all aspects of independence are
required.

Specifically, the agency should

  -- be generally recognized as a distinct entity that may be located
     within a cabinet department or an independent agency;

  -- have independence mandated in organic legislation or encouraged
     by organizational structure;

  -- be headed by a presidential appointee for a specific term not
     coincident with that of the administration;

  -- be distinct from the enforcement and policy-making activities
     carried out by the department in which it is located;

  -- have broad authority over the scope, content, and frequency of
     data collected, compiled, or published;

  -- have primary authority over the selection and promotion of its
     professional staff; and

  -- be recognized by policy officials outside the unit for its
     authority to release statistical information without prior
     clearance.

The NAS guidance discusses the importance of each of the above
elements of independence.  For example, the guidance suggests that "A
statistical agency must be in a position to provide credible
information that may be used to evaluate the program and policies of
its own department or the government as a whole.  The basic
independence of a statistical agency is essential."

Although recognizing that some limitations on independence are
common, the guidance further says, ".  .  .  the effectiveness of an
agency depends on its maintaining a reputation for impartiality;
thus, an agency must be continually alert to possible infringements
on its credibility and be prepared to argue strenuously against such
infringements." NAS also suggests that the independence of the unit
head be understood and that the unit head be recognized as
professionally qualified and have direct access to the secretary of
the department in which the unit is located.

The guidance cites as an example the independence of agencies such as
the Census Bureau, where the head of the agency is appointed by the
president and confirmed by the Senate.  The guidance suggests that
the unit head and qualified unit staff be able to speak on the unit's
statistical program before Congress.  The guidance also suggests that
a clear distinction be made between the statistical information the
unit releases and the policy interpretations of such statements by
the secretary of the department, the president, or others.  This
suggestion reflects practices long followed by many of the principal
statistical agencies.

         CAPACITY
-------------------------------------------------------- Letter :3.2.2

The NAS guidance also included the suggestions that a statistical
agency have a commitment to professional standards and to a clearly
defined and well-accepted mission, which we consider to be components
of a capacity to produce statistics.

Specifically, the agency should

  -- have a clearly defined and well-accepted mission;\12

  -- develop strong staff expertise in the disciplines relevant to
     its mission as well as in the theory and practice of statistics;

  -- develop an understanding of the validity and accuracy of its
     data and convey the resulting measures of uncertainty to users;

  -- use modern statistical theory and sound statistical practice in
     all technical work; and

  -- follow accepted standards in reports and other releases of data
     on definitions, documentation, descriptions of data collection
     methodology, measures of uncertainty, and discussions of
     possible sources of error.

According to the NAS guidance, "The best guarantee of high-quality
results is a strong professional staff .  .  .  .  Managers .  .  .
should charge professionals with responsibility and authority for
developing and promulgating statistical standards." The guidance
further says

     "An effective statistical agency keeps up to date on
     developments in statistical theory or practice that might be
     relevant to its program.  It must also be alert to changes in
     the economy or in society that may call for changes in the
     concepts or methods used in particular data sets."

Closely related to a discussion of an agency's capacity to produce
data is NAS' suggestion that an agency have a clearly defined and
well-accepted mission.  In its guidance, NAS explains that some
agencies' missions are spelled out in legislation, while other
agencies lack a specified mission and instead have only general
legislative authority.  The guidance further explains that,
occasionally, specific requirements may be set in legislation, and
when this is the case, NAS' guidance suggests that meeting these
legislative requirements is a measure of an agency's capacity to
produce statistics.  Further, the guidance suggests that a
statistical agency recruit and retain a professional staff of
statisticians and analysts in fields relevant to the unit's mission
and develop relationships with appropriate professional statistical
organizations to review the agency's statistical program, priorities,
methods, and data products.

--------------------
\12 We interpret this element as also having the ability to comply
with legal or administrative requirements.

         COORDINATION
-------------------------------------------------------- Letter :3.2.3

In addition, the NAS guidance included the suggestions that a
statistical agency coordinate with other statistical agencies and
cooperate with data users.  Specifically, the agency should

  -- coordinate with other statistical agencies;

  -- seek advice on data concepts, methods, and products;

  -- seek advice on its statistical programs, priorities, and
     methodologies;

  -- meet access and confidentiality needs; and

  -- make data accessible to all potential users.

The guidance also suggests working with interagency committees and
engaging "wholeheartedly in coordinating activities." The guidance
provides that

     "Statistical agencies do not conduct their activities in
     isolation.  They must be alert not only to exterior needs for
     their data, but also to potential exterior sources of data and
     of improved methods.  An effective statistical agency will also
     be alert to occasions in which it can provide technical
     assistance to others."

The guidance further suggests the use of "joint arrangements"--one
agency contracting with another to conduct a survey, compile special
tabulations, or develop models.  The NAS guidance calling for
cooperation with data users is closely related to the guidance on
coordination because of the interagency dependence on one another's
data on the foreign-born.

   INDEPENDENCE, CAPACITY, AND
   COORDINATION OF STATISTICAL
   EFFORTS VARIED
------------------------------------------------------------ Letter :4

According to agency officials and experts with whom we spoke, the two
agencies' independence, capacity to produce information, and
coordination with statistical agencies and data users varied
depending on the nature of the agency--its mission, structure, and
output--and whether it was considered to be a statistical agency.
OMB has identified and categorized the federal agencies that produce
statistical information.\13 According to OMB's characterization, the
Census Bureau is the largest of the 10 "principal" statistical
agencies whose sole mission is to collect and disseminate statistical
information.  INS' Statistics Branch is part of a grouping of about
60 agencies that are not considered to be principal statistical
agencies.

The Census Bureau's organizational structure was established by
statute.  Further, the Bureau's director is appointed by the
president and confirmed by the Senate.  The Census Bureau's adherence
to the NAS guidance was documented in our 1995 report on statistical
agencies.\14 In that report, we said Census is well-recognized as the
largest multipurpose agency in the federal statistical system.  In
contrast, INS' Statistics Branch is a self-described data compilation
and analysis unit that primarily provides program support for INS
operations.\15 The Statistics Branch was not established by statute
as an independent entity, and it is headed by a career civil servant.
The branch is working to develop the capacity of its demographic
statistics section in order to provide for more policy-related
information, and it is continuing to coordinate with other agencies
that develop information on the foreign-born, as discussed in the
following sections.

Three other organizations produce statistical information on the
foreign-born, but they are primarily program support units that
produce specialized statistical information (e.g., numbers of
refugees and visa applications) for the agencies in which they are
located.  These three organizations--HHS' Office of Refugee
Resettlement and State's Immigrant Visa Control and Reporting
Division and State's Population, Refugees, and Migration Bureau--are
not considered to be statistical agencies.

--------------------
\13 OMB's annual report, Statistical Programs of the United States
Government, lists about 70 units, each of which spends over $500,000
annually on statistical activities.  Ten of these are recognized by
OMB as "principal statistical agencies" because they collect,
analyze, and produce statistics as their primary mission.

\14 GAO/GGD-95-65, Aug.  9, 1995.

\15 Although INS tried to establish a Bureau of Immigration
Statistics in its fiscal year 1996 budget, the request for 10
additional positions and $10 million for salaries and expenses was
eliminated in committee without comment.

      INDEPENDENCE
---------------------------------------------------------- Letter :4.1

Although INS' Statistics Branch does exhibit some elements of
independence--it has authority over the scope of the data it
collects, authority over its staff, and tries to maintain a
distinction between its data and the policy interpretation by
others--it is not independent as NAS defines the term.  The branch
was not established by statute as a separate entity, is headed by a
career civil servant, cannot release data without approval from its
Office of Policy and Planning, and has no predetermined schedules for
releasing data.  Further, the branch's chief has not served as a
witness at congressional hearings.

In contrast, Census' legislative mandates and organizational
placement within the Department of Commerce afford the bureau a
higher degree of independence.\16 Census is organizationally distinct
from its department's enforcement and policy-making activities.
Census' director is appointed by the president and confirmed by the
Senate.

Congress is a major user of the statistics produced by the Census
Bureau.  The director testifies before congressional committees about
the results of statistical activities and to outline the agency's
budget requests.  The director also appears regularly at user
conferences, which have been attended by Members of Congress and
congressional staff, to discuss aspects of statistical programs.

As the NAS guidance on independence indicates, one of the ways in
which a federal statistical agency can guard against the perception
of political interference is by carefully controlling the release of
important statistical data.  As an example, the release of economic
statistical data produced by Census is governed by OMB Statistical
Policy Directive No.  3, which provides guidance to federal
statistical agencies on the compilation, release, and evaluation of
principal federal economic indicators.  The directive establishes the
authority of affected agencies to release economic statistical
information without prior clearance or policy interpretations.
Procedures established by this directive were designed to ensure that
key economic data that are the basis for government and private
sector actions and plans are released promptly and on a regular
schedule, that no one benefits from "inside" access to the data
before they are available to the public, and that the public has
confidence in the integrity of the data.  Also, the directive does
not limit the authority of the agencies over the scope, content, and
frequency of economic data collected, compiled, or published.

Another important element of independence, according to NAS, is
adherence to predetermined schedules in public release of important
data, an element intended to prevent manipulation of release dates
for political purposes.  INS officials said they are working on
developing such predetermined schedules.  Census follows procedures
outlined in OMB's guidance for developing approaches to releasing
information.  For example, Census develops release schedules annually
and provides them to OMB, and the schedules are available on the
Internet.

--------------------
\16 As noted by NAS, most statistical agencies have broad authority
over their programs, but that authority can be limited by budgetary
constraints, departmental interests, OMB review, and congressional
mandates.

      CAPACITY
---------------------------------------------------------- Letter :4.2

Regarding the capacity of INS' Statistics Branch to produce
statistical information, INS officials said the branch meets aspects
of the NAS guidance, such as strong staff expertise, a relationship
within the profession (e.g., membership in professional
organizations), and accepted standards in reports and data releases.
From our interviews with branch statisticians, it appears that the
branch has made progress in increasing its capacity in recent years.
Experts on immigration statistics also credit the branch for making
improvements in its capacity to produce statistical information.
However, as mentioned earlier, NAS guidance suggests that when
specific requirements for statistical information are called for in
law, meeting these requirements is a measure of an agency's capacity
to produce statistics.

INS' capacity is limited because it does not report on all of the
data elements called for in 8 U.S.C.  1103(d).  The act requires the
Commissioner of INS to "provide for a system for collection and
dissemination, to Congress and the public, of information .  .  .
useful in evaluating the social, economic, environmental, and
demographic impact of immigration laws." The law also specifies that
the information system provide for the collection and dissemination
of information not less often than annually.\17 Table 1 lists the
data elements and identifies those that INS officials said have and
have not been reported annually.

                                Table 1

                INS' Annual Reporting Requirements Under
                            8 U.S.C. 1103(d)

                                                           Does INS
                                                           report?
                                                        --------------
Data element                                            Yes     No
------------------------------------------------------  ------  ------
The alien population in the United States                       X

Rates of naturalization of resident aliens              X

Rates of emigration of resident aliens                          X

Aliens who have been

Admitted                                                X

Paroled                                                 X

Granted asylum                                          X

Nonimmigrants in the United States, information on
their

Occupation                                                      X

Basis for admission                                     X

Duration of stay                                                X

Aliens who have not been admitted to the United States  X

Aliens who have been removed from the United States     X

The number of applications filed for cancellation of            X
removal

The number of applications granted for cancellation of  X
removal

The number of aliens estimated to be present            X\a
unlawfully in the United States in each fiscal year

Applications for naturalization, number and rate of
administratively denied by

INS district office                                             X

National origin                                                 X

Total                                                   9       7
----------------------------------------------------------------------
\a This data element is revised periodically.  It was reported for
three points in time--October 1988, October 1992, and October 1996.

Source:  INS officials.

As previously noted, the ability to comply with legislative mandates
is part of the mission requirements for a statistical organization
and relates to the organization's capacity to produce statistical
information.  However, INS has provided reasons--which we did not
analyze--for not complying with some of the requirements.  For
example, officials said the agency does not report the alien
population of the United States because the term "alien population"
is not clear.  They explained that INS has internal estimates of
foreign-born entrants and the legal resident population.  Other
elements, such as rates of emigration of resident aliens, are
difficult to develop, the officials said.  Another rationale for not
complying with the 1990 law was contained in INS' 1996 and 1998
budget submissions, which said, ".  .  .  INS will be unable to meet
its reporting mandates as stipulated in the
[law] .  .  ." unless the agency's funding is increased.

INS, as well as other organizations and experts, has recognized
concerns about the quality of immigration statistics.  In 1985 and
1996, NAS issued reports that recommended improvements in the quality
of immigration statistics.  INS has started implementing over half of
the recommendations directed to it.  In our report responding to the
first objective of your request, we provided the implementation
status of these recommendations.\18 Of eight major recommendations
directed to INS, five were substantially or partially implemented.
Further, we assessed the quality of current federal demographic
information on the foreign-born population, which is discussed in a
separate report to be issued shortly.

Although INS' Statistical Branch officials said they are improving
their unit's commitment to quality and professional standards, they
recognized that they could make further improvements, including

  -- undertaking ongoing quality assurance programs to improve (1)
     data validity and reliability and (2) the processes of
     gathering, compiling, editing, and analyzing data; and

  -- publishing statistical standards for modern statistical theory
     and sound statistical practice to guide the technical work of
     professionals in the agency as well as external users.

Further, as noted on page 10 of our June 1998 report, NAS recommended
that INS increase its capacity, saying

     "INS should establish an advisory committee composed of experts
     in the use and production of immigration-related data, to advise
     the associate commissioner and the proposed Division of
     Immigration Statistics of needs for new or different types of
     data; to review existing data and data collection methodology;
     and to provide the Service with independent evaluation of its
     statistical products, plans, and performance."

In that report, we noted that

     "the Statistics Branch does not have a standing advisory
     committee but has brought in advisers several times to review
     existing data systems and to comment on current products .  .  .
     .  Groups of outside experts have also provided comments on
     current methodologies, such as the estimates of the illegal
     immigrant population.  INS plans to continue to use outside
     experts on an ad hoc basis rather than through a standing
     committee [which it believes] will better address the variety of
     data specialties and methodologies used to make estimates."

INS considers that it has partially implemented this recommendation.
We reported that, "[i]n our opinion, using advisers on an ad hoc
basis is not a substitute for a standing advisory committee."

In its operations, the Census Bureau incorporated more of the
guidance's elements of capacity than INS did.  Census has authority
over the scope, content, and frequency of data collection,
compilation, or publication.  However, this authority is limited by
budgetary constraints and federal laws, such as those intended to
reduce paperwork burdens on businesses and individuals.  The Census
Director also has primary authority for selection and promotion of
professional staff.  In addition, as discussed in the following
section, Population Division officials said that in fiscal years 1996
and 1997, they carried out Census' contractual obligations to INS
regarding the provision of information on the foreign-born.  However,
as we note in our forthcoming report on data quality, questions have
been raised regarding the quality of this information.  In that
report, we note that Census said it has no current plans or
initiatives to improve its data on the foreign-born because its
budget and mission do not support such work.

--------------------
\17 INS is also responsible for providing information under other
laws requiring data on the foreign-born, as discussed in a companion
report on immigration statistics to be issued shortly.

\18 GAO/GGD-98-119, June 9, 1998.

      COORDINATION
---------------------------------------------------------- Letter :4.3

INS officials told us that their primary coordination mechanism is
through the INS-sponsored Federal Interagency Working Group on
Immigration Statistics.  This group's quarterly meetings were
initiated in 1991 in response to several evaluations of immigration
data needs--including one by NAS\19 --that concluded that the
knowledge base in this area was deficient in providing the data
needed to support agency operations and to serve in formulating and
evaluating immigration policy.  The meetings were also initiated as a
response to the provisions of the Immigration Act of 1990, which
required that the Commissioner of INS provide for a statistical
information system useful in evaluating the impact of immigration
laws.

The interagency working group has been attended by researchers and
statisticians from other statistical agencies, NAS, the Commission on
Immigration Reform, legislative branch offices, and others interested
in immigration issues.  This group identified the need for "country
of birth" to be added to the monthly CPS, and as a result, beginning
in 1994, several of the working group agencies provided funds to
Census to collect country of birth data.  The group also evaluated
existing longitudinal studies involving significant immigrant
populations, and participant agencies helped fund the New Immigrant
Survey pilot test, which was designed to provide accurate data on
immigrants and their families' economic, social, and political
adaptation to living in the United States.

The need for coordination among agencies that collect information on
the foreign-born has been a long-standing issue, as discussed in our
report on the two NAS reports that contain recommendations designed
to streamline and strengthen the collection, analysis, and
dissemination of immigration statistics.\20 In that report, we noted
that while the interagency working group has resulted in improved
coordination, NAS' recommendations to INS have not been fully
implemented.  For example, NAS recommended that not only federal but
state agencies also should participate in INS' liaison efforts.  We
noted that although INS has established a liaison with federal
agencies, no corresponding liaisons exist with state agencies.  In
its 1985 report, NAS noted that state and local governments are also
involved in the collection and analysis of immigration- and
emigration-related data that could be useful for INS' statistical
purposes.

Regarding Census' coordination efforts, we noted in our prior work
that (1) coordination with other federal agencies is particularly
important for Census because of its role in collecting statistical
data for agencies and (2) Census cooperates with data users in a
variety of ways.\21 For example, a Census representative is a member
of the INS-sponsored interagency coordinating group.  Further, the
NAS guidance on coordination indicates that the most important aspect
of coordination among federal agencies is the sharing of data.
Census and other statistical agencies have been active in
recommending and supporting efforts to enhance data sharing.  For
example, the Statistics 2000 task force--composed of members from
Census and the other major statistical agencies--worked with OMB and
Congress in developing proposals for enhanced data sharing.\22
However, it appears that the sharing of data on the foreign-born
among federal agencies was limited by the provisions designed to
protect the confidentiality of individual data providers.  For
example, one of the products of the INS-sponsored interagency working
group addressed expanding the immigration database by using more
administrative records.  The group proposed linking information from
various agencies to a specific individual by social security number.
The group's paper noted the problems associated with access to such
information because of privacy or confidentiality provisions.

The NAS guidance also suggests that federal agencies should, when
possible and appropriate, cooperate with state, local, and
international statistical agencies.  Census officials said the agency
had cooperated with other governments to the extent necessary to
obtain the data on the foreign-born that was needed.

Census and INS have worked collaboratively on a wide variety of
projects for a number of years, sharing data on the foreign-born.
Currently, INS is providing part of the financial support for the
monthly collection of nativity data in the CPS, a project that began
in January 1994.  INS decided in 1996 to expand the use, analysis,
and dissemination of these data and requested the continued
assistance of the Census Bureau in this expansion effort.  Under this
agreement, INS provides the specifications for the data files needed
and collaborates with Census to support the work.  Census'
responsibilities under the agreement include providing the data,
producing and publishing an annual report on the foreign-born,
providing subject-matter consultants for special projects, and
meeting with INS officials regarding issues and concerns about the
foreign-born.

As we have said in an earlier report,\23 coordination is important
because in its absence, it is unlikely that programs will efficiently
supplement each other to meet both program improvement and
policy-making information needs.

--------------------
\19 Immigration Statistics:  A Story of Neglect (Washington, D.C.:
National Academy Press, 1985).

\20 GAO/GGD-98-119, June 9, 1998.

\21 GAO/GGD-95-65, Aug.  9, 1995.

\22 Statistical Agencies:  Proposed Consolidation and Data Sharing
Legislation (GAO/T-GGD-98-91, Mar.  26, 1998).

\23 Program Evaluation:  Agencies Challenged by New Demand for
Information on Program Results (GAO/GGD-98-53, Apr.  24, 1998).

   AGENCY COMMENTS
------------------------------------------------------------ Letter :5

OMB and INS provided oral comments on a draft of this report.  Their
comments were of a technical nature, or to clarify points.  We
considered all of their comments and have incorporated them where
appropriate.  The Department of Commerce had no comments on the
report.

---------------------------------------------------------- Letter :5.1

As agreed with your staffs, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
from its issue date.  At that time, we will send copies to the
Chairmen and Ranking Minority Members of other committees with
jurisdiction over immigration issues; the Attorney General; the
Secretaries of Commerce, HHS, and State; and other interested
parties.  We will also make copies available to others upon request.

If you have questions concerning this report, please telephone me at
(202) 512-7997.  Major contributors to this report are listed in
appendix III.

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

SCOPE AND METHODOLOGY
=========================================================== Appendix I

To identify the federal guidance affecting the production of
statistics on foreign-born residents and the principal agencies
involved in the collection, analysis, and dissemination of statistics
on the foreign-born, we talked to officials from OMB and INS and
experts on immigration issues.  On the basis of those discussions, we
gathered information on relevant guidance by reviewing pertinent
literature, laws, NAS reports on immigration, and NAS and OMB
guidance for federal statistical agencies.

To determine the primary agencies responsible for producing
statistics on the foreign-born, we synthesized literature reviews,
agency documents, and testimonial evidence from agency officials and
knowledgeable experts and identified the agencies that seemed to
generate the statistical information germane to the request.  We then
verified this information with officials from OMB and from the
agencies we selected:  INS' Statistics Branch and the Census Bureau's
Population Division.

These agencies are considered to be primary sources of demographic
data on the foreign-born.  In addition, we interviewed officials and
reviewed relevant documents from HHS' Office of Refugee Resettlement,
State Department's Immigrant Visa Control and Reporting Division, and
State Department's Population, Refugees, and Migration Bureau, who
collect program-specific information on the foreign-born.  We also
drew on other work being done in response to the first and second
objectives of the request.  Other agencies that did not engage in any
primary data collection or analysis activities but only disseminated
information on the foreign-born were not included in our work.

To provide information on the agencies' positions on independence,
capacity to produce statistical information, and interagency
coordination efforts, we compiled criteria for each of these areas
from our review of federal guidance on how statistical agencies
should operate.  Using these criteria, we derived a set of indicators
by which to compare the agencies' statistical operations against the
elements in the NAS guidance regarding independence, capacity to
produce statistical information, and interagency coordination.

PROFILES OF THE TWO PRINCIPAL
AGENCIES THAT PRODUCE STATISTICS
ON FOREIGN-BORN RESIDENTS
========================================================== Appendix II

INS' STATISTICS BRANCH

INS' Statistics Branch is the largest producer of statistics on the
foreign-born and currently has a staff of 24 full-time-equivalent
positions.  The branch is located within the Office of Policy and
Planning, which was created in a major INS reorganization in 1994 to
reinforce Servicewide planning and provide attention to macro-level
immigration policy.  As an executive-level office, Policy and
Planning reports directly to the INS Commissioner.  Its mission is to

  -- support INS leadership in policy development, strategic
     planning, program evaluation, and statistical analysis and
     reporting;

  -- act as a central clearinghouse for collecting, interpreting, and
     disseminating information about immigration policy; and

  -- act as a liaison between INS and nongovernmental organizations
     and interest groups that have a stake in national immigration
     policy.

The fiscal years 1994 through 1998 Statistics Branch budget
allocations are shown in table II.1.

                Table II.1 INS' Statistics Branch Budget
                              and Staffing

                                                        Dollar
                                                          s in
                                                        millio  FTE's\
Fiscal year                                                 ns       a
------------------------------------------------------  ------  ------
1994                                                       1.2    24.1
1995                                                       1.3    22.9
1996                                                       1.3    22.5
1997                                                       1.4    24.2
1998                                                     1.4\b  24.0\b
----------------------------------------------------------------------
\a Full-time-equivalent positions.

\b INS estimates.

Source:  INS.

The Statistics Branch consists of two sections--Operational and
Demographic.  The two sections are responsible for preparing reports
on operational and demographic statistics, respectively; monitoring
the information system's reliability; and advising other INS offices
on sampling and other statistical applications.

      OPERATIONAL STATISTICS
      SECTION
------------------------------------------------------ Appendix II:0.1

The Operational Statistics Section provides information on INS'
operations (workload and resources) and develops models for
estimating revenue to support budget requests.  The staff manages
INS' Performance Analysis System (PAS), which is a workload
measurement system; produces reports of PAS data; responds to
requests for information (usually from within INS); develops models
for estimating revenue to support budget requests; and is to be the
principal source of information to meet the requirements of the
Government Performance and Results Act.  The data originate from a
variety of sources, including manual reporting systems, reports from
automated mission systems, and electronic vehicle counters at U.S.
borders.  INS' Information Resources Management Office provides
automation support for PAS through a contract with Electronic Data
Systems, for which INS pays $130,000 annually.

Until 1997, the Operational Statistics Section employed two
statisticians--the section chief and a senior statistician.  Two
additional statisticians were recently hired, one who concentrates on
analyses of enforcement data, and the other who concentrates on
immigration services information.  In March 1998, the section was
authorized 13 FTEs, and 12 of these were filled.  The employees' job
titles and grade structure were as follows:

  -- 1 Supervisory Statistician, GS-14,

  -- 3 Statisticians, GS-13,

  -- 2 Management Analysts, GS-11,

  -- 2 Management Analysts, GS-9, and

  -- 4 Statistical Assistants, GS-6.

      DEMOGRAPHIC STATISTICS
      SECTION
------------------------------------------------------ Appendix II:0.2

The Demographic Statistics Section produces reports on the size and
characteristics of various alien populations and analyzes pertinent
information collected by other agencies, such as the Census Bureau
and the Bureau of Justice Statistics.  To produce the reports, the
section primarily uses extracts from INS' mission systems, which are
developed and maintained by the Office of Policy and Planning.

The Demographic Statistics Section issues a number of products, many
of which are available on the Internet.  The Statistical Yearbook of
the Immigration and Naturalization Service is published annually and
is INS' primary statistical publication.  The Yearbook has been
published since 1892.  Specific reporting requirements contained in
recent Yearbooks are called for by the Immigration Act of 1990,
codified at 8 U.S.C.  1103(d).  Also published annually are the
Commissioner's Fact Book and Immigration Advance Reports.  Other
publications include the following.

  -- INS Fact Book (Mar.  1993):  A summary of recent immigration
     data.

  -- Immigration to the United States in Fiscal Year 1996 (Apr.
     1997):  Information on legal immigration to the United States.

  -- Immigration Fact Sheet (Oct.  1997):  A compilation of
     statistics and historical data on the national origin and
     residence of immigrants and the foreign-born population in the
     United States.

  -- Estimates of the Unauthorized Immigrant Population Residing in
     the United States:  October 1996 (published periodically):
     Estimates as of October 1996 for the top 20 countries of origin
     and states of residence; includes text describing the estimation
     procedure, limitations, and discussion of estimate results.

  -- State Population Estimates:  Legal Permanent Residents and
     Aliens Eligible to Apply for Naturalization (single
     publication):  Estimates for each state as of April 1996;
     includes brief supporting text.

  -- Bulletins (on selected topics, published periodically).

In March 1998, the Demographics Statistics Section was allocated 11
FTEs, one of which was vacant.  The staff members' job titles and
grades were as follows:

  -- 1 Supervisory Statistician, GS-14,

  -- 1 Statistician, GS-14,

  -- 3 Statisticians, GS-13,

  -- 1 Supervisory Information Specialist, GS-11,

  -- 2 Management Analysts, GS-11,

  -- 1 Presidential Management Intern, GS-11, and

  -- 1 Statistical Analyst, GS-7.

CENSUS BUREAU

The Census Bureau is responsible for collecting, tabulating, and
publishing a variety of statistical data about the people and the
economy of the United States.  Census' responsibilities include the
decennial census of population and housing; censuses of state and
local governments and domestic industries; special censuses done at
the request and expense of states and localities; and compilations of
U.S.  foreign trade statistics.  Many other statistical agencies make
use of Census' extensive field structure and data-gathering
operations on a reimbursable basis.

Census' Population Division is the federal government's provider of
regularly updated information on the population of the United States,
including the foreign-born, and its demographic, geographic, and
social characteristics.  Through its subject-matter expertise, the
division oversees the planning, collecting, processing, and
distributing of population data obtained from censuses, surveys, and
administrative records.  Census has assigned two full-time
demographers to collect and analyze information on the foreign-born
and to implement an interagency agreement with INS for this type of
information.

Two products of the Population Division represent a source of
immigration information:  estimates and projections and the Current
Population Survey (CPS).  The former provides a component of
population change labeled "net international migration." This
component comprises (1) legal immigration from abroad, (2) net
undocumented immigration, (3) emigration, and (4) net movement
between Puerto Rico and the U.S.  mainland.  The CPS provides
information on the foreign-born population in the United States and
in selected states.  Customers for this information include Congress,
federal agencies, state and local governments, the private sector,
the academic community, research organizations, libraries, and
individuals.  In addition, Census has published the 1996 Statistical
Abstract of the United States and We the American Foreign Born, a
special publication issued in September 1993.

Table II.2 shows the Population Division's budgets for fiscal years
1994 through 1998.

                         Table II.2

                 Population Division Budget

                   (Dollars in millions)

Fiscal                                                 INS
year            Budget                       reimbursement
----------  ----------  ----------------------------------
1994               $31                                   0
1995                24                                   0
1996                27                               $0.20
1997                27                                0.27
1998                31                                   0
----------------------------------------------------------
Source:  Census Bureau.

Two professional staff members in the Population Division specialize
in information on the foreign-born population.  Both of these staff
members have the job title statistician/demographer.  One is a GS-12,
and the other is a GS-9.

MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III

GENERAL GOVERNMENT DIVISION

Thomas J.  Jurkiewicz, Assistant Director
Patrick R.  Mullen, Evaluator-in-Charge
Nancy A.  Patterson, Assignment Manager
Theodore H.  Saks, Senior Evaluator
Thomas Beall, Technical Adviser

OFFICE OF THE GENERAL COUNSEL

Ann H.  Finley, Senior Attorney

RELATED GAO PRODUCTS
============================================================ Chapter 0

Immigration Statistics:  Status of the Implementation of National
Academy of Sciences' Recommendations (GAO/GGD-98-119, June 9, 1998).

Program Evaluation:  Agencies Challenged by New Demand for
Information on Program Results (GAO/GGD-98-53, Apr.  24, 1998).

Statistical Agencies:  Proposed Consolidation and Data Sharing
Legislation (GAO/T-GGD-98-91, Mar.  26, 1998).

Statistical Agencies:  Consolidation and Quality Issues
(GAO/T-GGD-97-78, Apr.  9, 1997).

Statistical Agencies:  A Comparison of the U.S.  and Canadian
Statistical Systems (GAO/GGD-96-142, Aug.  1, 1996).

Statistical Agencies:  Statutory Requirements Affecting Government
Policies and Programs (GAO/GGD-96-106, July 17, 1996).

Federal Statistics:  Principal Statistical Agencies' Missions and
Funding (GAO/GGD-96-107, July 1, 1996).

Government Statistics:  Proposal to Form a Federal Statistical
Service (GAO/T-GGD-96-93, Mar.  22, 1996).

Statistical Agencies:  Adherence to Guidelines and Coordination of
Budgets (GAO/GGD-95-65, Aug.  9, 1995).

*** End of document. ***