Immigration Statistics: A Story of Neglect (1985)

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The Immigration and Naturalization Service OVERVIEW: MANDATE AND PERFORMANCE This chapter describes the programs and operations of the Immigration and Naturalization Service (INS), an agency of the U.S. Department of Justice. It highlights the procedures followed to collect data and the type of data collected. Because of the INS's central role in administering the flow of international migration to the United States, its statistical activities were examined in considerably more detail than were those of the other federal agencies involved in collecting immigration data. The INS is charged with the administration of the Immigration and Nationality Act as well as of other federal statutes concerning the status of aliens in the United States and of the process of naturalization. The work of the agency in carrying out its legal and administrative missions can be divided into two broad areas, examination and enforcement. Operational programs and services are administered through field offices of the INS throughout the United States and in selected locations in U.S. territories and abroad. Although the legislative history of the INS contains few references to statistics or data (as outlined in Chapter 3), the agency is following a long tradition in collecting and furnishing information on the movements of aliens. The reporting of U.S. immigration statistics was first authorized by the Congress in 1819, and in 1892 that reporting responsibility was given to the Bureau of Immigration, then in the U.S. Department of Labor, the forerunner of the INS. Hence, the gathering of immigration statistics has been an integral part of the mission and activities of the INS or its previous incarnations for close to 100 years. The statistical activities of the INS are directly related to its administrative and operational structure; consequently, to describe and evaluate the statistical activities requires an understanding of the organizational context of data collection and analysis within the agency, which is shown in Figure 4-1. Each area of operation In INS is concerned with the processing of aliens and, in some cases, citizens: monitoring entry to and exit from the United States and changes in legal status. In carrying out its duties, the INS generates many types of inflation on alien populations within a range of legal and administrative statuses. 35

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37 The data vary in quality, refinement, accessibility, and timeliness, and the focus of the information is operational rather than statistical. During the past decade the INS has been criticized by the General Accounting Office and the House Committee on Government Operations for internal problems--such as poor record management, inadequate service to the public, and low employee morale--and for being unable to prevent illegal entry or to maintain adequate control over the nonimmigrant population in the United States. Coincident with these management problems was a sharp increase in the agency's workload. Testifying before the Senate Appropriations Committee in March 1980, the Acting Commissioner of INS noted (U.S. Department of Justice' 1980:11~: Major changes in the law in 1965 resulted in considerably more paperwork for the agency, and it was not and has not been equipped to cope with it, either through systems or procedures or through automation. At the same time, immigration to this country has been increasing substantially, and we now find ourselves in a hole from which it will not be easy to extricate ourselves. Table 4-1 shows the steady and in some cases dramatic increases in alien admissions, naturalizations, and apprehensions of deportable aliens since 1966. While immigrant admissions less than doubled, admissions of nonimmigrants (visitors, students, and other nonresident aliens) increased fivefold, from 2.3 million in 1966 to 11.8 million in 1981; apprehensions increased sixfold, from 139,000 in 1966 to more than 1 million during the late 1970s. In addition, nearly 1 million refugees were admitted to the United States during the past decade. As the workload of INS expanded after 1965, its budget also increased significantly, reaching t351 million in 1980. However, the number of authorized permanent positions increased by a little more than 50 percent, from 7,000 in 1966 to 11,000 in 1980. Only a minuscule portion of its resources were devoted to statistics: 49 permanent positions were allocated to the statistics program in 1980. Most of these positions were held by clerical personnel who manually sorted and compiled statistics. Except for its initiatives in the data-processing area and in spite of increasing national concern about immigration in recent years, INS for many years has not requested any additional funding for the purpose of improving its statistical capabilities or products, nor has it taken significant actions to accomplish such a goal with its existing resources. This budgetary and organizational neglect has been accompanied by a deterioration of its statistical functions. Prior to the late 1950s, the INS statistics program and its staff, although comparatively small, had the reputation of producing quality statistics in a timely fashion, but in recent years both quality and timeliness have deteriorated seriously. The great expansion of automated data processing (ADP) at the INS during the past few years provides the opportunity for a rapid improvement in its statistical capabilities in meeting both its own information needs and the demands for data by external users. Consequently, this chapter includes a review of the development of automated data processing, a description of the ADP plans that are being

38 TABLE 4-1 Immigrants and Nonimmigrants Admitted, Persons Naturalized, and Aliens Apprehended: 1966-1981 (in thousands) Fiscal Immigrants Nonimmigrantsa PersonsAliens Year Admitted Admitted NaturalizedApprehended 1981 597 11,757 166976 1980 531 NA 158910 1979 460 NA 1641,076 1978 601 9,344 1741,058 1977 462 8,037 1601,042 1976b 104 2,674 48222 1976 399 7,654 143786 1975 386 7,084 142767 1974 395 6,909 132788 1973 400 5,977 121656 1972 385 5,171 116506 1971 370 4,404 108420 1970 373 4,432 110345 1969 359 3,645 99284 1968 454 3,200 103212 1967 362 2,608 105162 1966 323 2,342 103139 aIncludes visitors, students, and other nonresident aliens. bTransition quarter July 1 - September 30, 1976. Source: INS Annual Reports, 1966-1981. implemented, and a discussion of their statistical potential. Before turning to these developments, however, and in order to understand those plans within the context of the agency, we first present a summary of the information collected by the INS in carrying out its responsibilities, a summary of its operations, and an examination of its primary work report. Following the ADP review, we consider the agency's resources for statistical analysis and, finally, present our conclusions and recommendations about the INS. INFORMATION COLLECTED BY THE INS Categories of Migrants With regard to data, six broad categories of migrants are incorporated within the complex of legal and administrative boundaries that define the areas of responsibility of the INS:

39 Permanent resident aliens Nonimmigrants Refugees, parolees, and asylees Naturalized citizens Border crossers Deportable aliens These categories are not mutually exclusive in all cases, nor is the list comprehensive of all movements in or out of the country; they do, however, cover the major categories of movement. With virtually no exception, the information generated for each of these categories derives from program needs; none of the items has a statistical origin. Not all of the data that are collected are processed. The glossary contains more detailed and technical definitions of these categories; all the forms mentioned in the discussion below are shown in Appendix A. The numbers of people given below for each category are for the most recent year for which data are available. Permanent Resident Aliens A relatively extensive array of social and demographic data is available for permanent resident aliens, a group that consists of people entering the country with immigrant visas and those already in the country who adjust to permanent resident status. In fiscal 1981, a total of 596,600 people were recorded in this group, with adjustments representing about one-third of the total, primarily because of refugees who adjust to permanent resident status. The data on immigrants admitted for permanent residence are the most widely accessible of the INS data sets, both as published in the annual statistical yearbook and as available on tape in the form of public-use micro record samples. The following information is collected, mainly from immigrant visas (or in the case of adjustment, INS form I-485~: District and port of entry District of residence Month and year of admission Class of admission Country of last permanent residence Country of birth Nationality Age Nonimmigrants Sex Occupation Marital Status Labor certification Expected zip code in the United States Class and year of entry (for persons adjusting status) Nonimmigrants are those temporarily in the country as visitors, tourists, students, on business, or as temporary workers. There are more than 9 million admissions with nonimmigrant visas each year. Information on these admissions is generated from the items contained on the I-94 form required for both entering and leaving the country: Visa issuing place Date of birth Class of admission Country of residence

40 Date of entry Date admitted until Citizenship Port and date of departure Port of entry State of destination Mode of travel Occupation (obtained for temporary workers, intercompany transfers, exchange visitors) Tabulations for this group are available in the annual statistical yearbook, except for the years 1980 and 1981, when processing was abandoned due to excessive workload. Naturalizations This category covers aliens receiving citizenship, either through direct application or by derivative means, such as children born outside the country of at least one parent who is a U.S. citizen. In fiscal 1981, 166,317 persons were naturalized. The data for this group are collected on forms N-400 and N-600: INS district handling case Country of birth Year of birth Year of admission Applicable section of law Type of court--federal/state Former nationality Month and year naturalized Sex Refugees, Parolees, and Asylees Marital status and marital history Number of children by sex and date and country of birth Occupation and 5-year work history Zip code of residence Five-year residence history Refugees consist of those persons outside their country of nationality who fear persecution if they return. In fiscal 1984, a total of about 70,000 persons entered the country as refugees. Persons already in the country as nonimmigrants or those at a port of entry who are unable or unwilling to retunes to their country because of fear of persecution are listed as asylees; in fiscal 1984, this group totaled slightly over 11,500. The final group consists of parolees, who are persons allowed to enter the country temporarily under emergency conditions. Prior to the passage of the Refugee Act of 1980, most refugees were paroled into the country and were included in the count of parolees but are now shown separately. In fiscal 1981, some 15,700 persons were allowed to enter the country for humanitarian and other reasons as parolees. Although the INS collects information on refugees at three different times--before admission to the country, at the time of entry to the country, and when the refugee applies for status as a permanent resident, relatively little of the information is actually made available publicly. The 1981 Statistical Yearbook contains only three tables presenting data for refugees: refugees granted lawful permanent resident status; authorized

41 admissions (that is, ceilings) and approvals of refugees for admission by geographic area of chargeability; and refugees granted lawful permanent resident status by country or region of birth. Additional tables will be included in the 1982 and the 1983 Statistical Yearbook. The Office of Refugee Resettlement also collects and publishes information on refugees, as described in Chapters 5 and 7. Border Crossers Border crossers are a heterogeneous group of people entering the United States from Canada or Mexico who are not required to complete form I-94 arrival declarations. Such entries take place predominantly but not exclusively across land borders, and are made up of U.S. citizens, permanent resident aliens, and those nonresident aliens entering the United States for periods of no more than six months (from Canada) or 72 hours (from Mexico). The number of such entries reached almost 290 million in fiscal 1981; however, relatively little information beyond total is available for this group. The methods used to obtain the information are described later in this chapter. Deportable Aliens Close to 1 million deportable aliens were located in fiscal 1981. Information collected about them included: Citizenship Residence in the United States Date and manner of entry Date and place of birth Visa status Social security number Length of time illegally in country Last employer and dates of employment Occupation Wage earned The information is collected on form I-213, which is not machine processed; limited data on locations by nationality group, type of entry, broad categories of length of illegal stay, and employment status are manually extracted for form G-23 (see below), and further manual extraction of data on earnings and use of social services is made for internal INS reports. Further data on aliens deported and aliens required to depart, excluding those opting for immediate voluntary departure, are generated by INS enforcement operations, but they cover only 5 percent of all deportable aliens located. Records Control: The Alien File Throughout its history, the INS has been a massive producer of administrative records, in paper form, all of which were supposedly filed in case of future need. The heavy emphasis on automated data processing, discussed below, is a response to this proliferating, virtually

42 uncontrollable mass of records. Wit appears quite certain that the INS will remain, along with the Social Security Administration and the Internal Revenue Service, among the leading government agencies in generating records. Successful record control thus becomes a necessity in the battle to achieve efficient operation of this organization. The key record in this battle is the alien file, the "A-file," which is a hard-copy folder containing the store of original documentation available for each alien to whom an alien number has been assigned. The criteria for deciding whether an A-number should be assigned to a particular alien, and hence a file established, are not clearly laid down. Essentially, an A-file is created whenever the need arises; the last of the official list of 19 circumstances that warrant the creation of an alien file is "rainy other time a case file is needed for an individual" (INS Administrative Manual:2702.02~. The major categories of aliens with A-numbers and for whom documentation is maintained, of course, consist of permanent resident aliens, naturalized citizens, refugees, asylees, and parolees. Alien files are physically maintained in the records section of the district offices of the INS; inactive files are retired to federal records centers. The content of the A-files varies widely. Files may contain virtually any piece of documentation pertaining to the case of an alien, including birth certificates immigrant visas, petitions, any official or unofficial documentation supporting claims and petitions, correspondence, travel forms, etc. There appears to be little effective policy about which documents should be filed. Files are supposed to be kept in the INS control office having jurisdiction over the area in which the alien currently lives; in fact, they may be located in some other office for a variety of reasons. Because of this situation, the master index (see below) originally was introduced as a f ile tracking measure. OPERATIONAL ASPECTS OF THE INS The data collected by the INS are the by-product of administrative activities carried out by the various operational units of the agency. This section describes briefly the role of each major organizational unit and its contribution to collecting data on international migration. Inspections Immigration inspectors are responsible for determining the admissibility of all persons seeking to enter the country and for collecting original documentation from aliens admitted to the country within the range of legal statuses. Examination of U.S. citizens and the inspection of aliens seeking admission occurs at officially designated ports of entry located along international land borders and at air and sea ports. Preinspection occurs in some foreign cities; deferred inspections can be administered at INS offices other than the designated ports of entry. Immigration officers share the responsibility of border control with other federal agencies, including the Customs Bureau (U.S. Department of

43 the Treasury), the U.S. Department of Agriculture, and the Public Health Service (U.S. Department of Health and Human Services). Admissions The documentation collected from aliens entering the United States varies with legal or visa status. Aliens entering as permanent residents present their immigrant visas and supporting documentation to inspectors. Nonimmigrant aliens arriving by international air and sea carriers present arrival forms (form I-94), and inspectors also collect passenger manifests (form I-92) from carriers. The I-94 form collects little social and demographic information, and inspectors seldom check the accuracy of what is collected. The coverage and processing of 1-94 and 1-92 forms is discussed further in Chapter 5. Flows Into the United States Across Land Borders Inspectors at land ports process people crossing borders in a variety of legal categories. Most aliens entering the United States over land borders do not require documentation: Canadians may travel for business or pleasure for a period of six months without requiring a nonimmigrant visa; Mexicans crossing the border frequently may present border crossing cards for admission to the United States for business or pleasure within 25 miles of the Southwestern border for a period not to exceed 72 hours. Aliens admitted for permanent residence who work in the United States yet continue to reside in Canada or Mexico are considered commuters and present an immigrant visa upon first admission and a special "green card" thereafter. Procedures for counting people entering at land border ports vary significantly among ports. Generally, land ports experiencing a large volume of traffic rely on estimates of the number of aliens and U.S. citizens arriving per vehicle or as pedestrians; smaller ports make actual counts of the number of people inspected and admitted, by citizenship status. By far the largest number of entries into the country each year occur through points of entry on the Mexican and Canadian borders. In 1981, almost 99 million border crossings were recorded across the Canadian border, and 190 million across the Mexican border, compared with some 21 million arrivals by air and sea. (The figures are not quite comparable, since the land border data count number of crossings, while some categories of the air and sea data may count multiple arrivals in a year by the same person only once, but the difference in magnitude is nonetheless clear.) In order to review the procedures used by the INS to arrive at a count of border crossings, the panel conducted a telephone survey of 20 offices, 11 on the Canadian border and 9 on the Mexican border, selected purposively to give a spread both geographically and by size of reported flow. The individual office responses then were evaluated, if possible, through examination of data produced by the offices and reported on the

44 work measurement form (G-23) and on the semiannual workload report forms G-540-542 . I t should be noted that primary inspect ions are shared between the INS and Customs Bureau officers at land borders, and, although reporting is an INS function, Customs officers share in the recording process. Table 4-2 summarizes the f indings from the survey. The most striking feature of the procedures used is their variability from office to office, although this variability is not surprising given the lack of guidance provided by district, regional, and central offices: the only invariant response to the survey was that all the offices reported receiving no guidance from district or regional offices about how to carry out surveys or make estimates. At every port but one, a direct count is made of passenger cars crossing into the United States, although the mechanism used to obtain the count varies. At many smaller ports, direct counts are maintained by hand tallies or hand counters, though some of these ports reported that the accuracy of the count might slip at times of peak traffic. At larger ports, vehicle counts are made by sensors; in the case of bridges, some counts are obtained from toll records. Although there may be a problem of overcounting in some cases, since buses and trucks will trigger sensors, the flow of passenger cars into the United States is probably recorded with reasonable accuracy. This is an example of a statistic important to the INS--since port workload varies closely with numbers of cars--but of little interest to policy makers or the research community. The method of counting of passengers, which is of importance to a wider audience, also varies, most obviously by size of port and by whether the port is on the Canadian or Mexican border. Many of the small and medium sized ports on the Canadian border make direct counts using hand counters or tallies of the numbers of passengers and whether they are citizens or aliens. The larger Canadian border points, and almost all the Mexican border points, estimate the numbers of total passengers by applying an average occupancy figure to the car count. The number of citizens and of aliens is then estimated by applying citizen/alien ratios to the estimate of total passengers. The sources of these average occupancy figures and citizen/alien ratios also vary from port to port. In some cases, the ports report using results from the semiannual survey ~ forms G-540-542) typically conducted on three days, including a Saturday and a Sunday, in February and August each year. However, the forms contain no breakdown by citizenship, and the semiannual survey does not always collect a citizenship breakdown. It is not clear from our port survey how the citizenship split reported on the G-23 is arrived at for those ports that make estimates rather than direct counts: some ports report using their own surveys conducted at regular periods; others conduct surveys on the hunch that traffic patterns have changed. The results of our port survey also do not indicate precisely how average occupancy and citizen/alien ratios, however obtained, are used to estimate total passenger flow by citizenship. For selected ports, the forms and the G-23 returns were examined to determine whether the data obtained were consistent with the procedures reported. This examination suggests that those ports that said they used direct counts did so; that most ports using estimates of occupancy based their estimates on G-540-542 returns, while a few applied nonempirical ratios; and that most

45 ports making estimates of citizens and aliens used ratios that did not change over time and presumably had no recent factual basis. The returns must be used carefully to avoid bias. Traffic flow, average occupancy, and probably the citizen/alien ratio vary substantially and systematically by time of day, day of week, and month of year. An average occupancy figure based on the three-day semiannual survey, including two weekend days, is likely to overestimate the true value, since occupancy is highest at weekends; the ratio of citizens to total passengers may also be highest at weekends. It is clear that in the absence of careful design and standardized procedures, the numbers on flows by citizenship could be (and probably are) substantially in error. Passengers by car represent a substantial majority of all entries across land borders, but some persons cross by bus or truck and some walk. Numbers of pedestrians (including bus passengers who generally pass through pedestrian lines), by citizenship, are counted directly at many ports, particularly on the Canadian border, but several ports make estimates on the basis of the semiannual or other survey. The error in these estimates is probably quite high, but since the pedestrian flow is a small proportion of total flow, the effect on estimated totals is probably not large. Our review of methods used by the INS to estimate the number of border crossings raises serious doubts about the accuracy of the numbers by port and by citizen/alien designation, which are published annually in the INS statistical yearbook, as well as about the accuracy for some ports of the figures laboriously compiled on the G-23 each month and in the G-540-542 report every six months. The importance of these numbers to the agency managers must also be doubtful, given the difficulty of locating reports for some ports, and the fairly obvious deficiencies, including simple arithmetic errors, in some G-23 returns. A more fundamental question is whether these numbers are important for any purpose at all. Many border crossings are made by commuters, shoppers, or people out for an evening who spend at most a few hours either in or outside the United States and who are of no interest to those concerned about immigration policy or to studies of immigration. Even staff workload seems to depend more on numbers of vehicles processed than on passengers by citizenship. The installation of automatic sensors of vehicle traffic at all points of entry that recorded weekly or even monthly, with no attempt at tallying passengers, would save greatly on inspections and clerical workload at the cost of sacrificing data that are virtually worthless. If INS officials or policy makers decide that some count of passengers by citizenship is desirable, sound statistical procedures using sampling should be introduced, removing the burden from the ports themselves. The INS could establish traveling teams to carry out regular and standardized surveys, at least of the medium- and large-flow ports; these teams could also record departing vehicles by occupancy during the survey period, to provide comparable figures on outgoing border crossings, which do not now exist.

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48 Adjudications and Naturalizations The adjudication and naturalization programs are concerned generally with processing petitions and granting benefits on behalf of aliens (but see following section). Determinations for some benefits, such as petitions for relative and occupational preferences, applications for various' travel documents, and for extensions of stay are sometimes made immediately by INS personnel in district offices through the "up front" adjudications process, although the INS has found it more efficient to use other methods of processing. Other determinations, such as naturalizations, require more studied analysis of the documentation submitted or personal interviews; they, too, may be done in the district offices, but the INS is opting increasingly for remote adjudications in which specific types of petitions are sent to INS personnel assigned to adjudications centers. The quality of information entered by aliens on the forms and applications is likely to vary. Examiners review closely those items that are very relevant to case determination; often these items are checked against supporting documents. The accuracy of reported information that is less relevant to determining the validity of claims is unknown. ADP developments will have a major impact on the statistical reporting systems in the adjudications and naturalization program. The case tracking systems in both operational areas will have the capacity to produce major sections of the work measurement report (G-23), so these data should become more timely and accessible for users at all levels within the INS. The Refugee, Asylum and Parolee Program The activities of the INS concerning the admission of refugees and the processing of asylees, and the process of paroling aliens into the United States, are coordinated in the central office by the Refugee, Asylum and Parolee Program. However, the program is administered and services are provided in different parts of the examinations sections: for example, personnel in adjudications are concerned with aliens applying for political asylum; immigration inspectors are responsible for processing the requests of refugees for admission as legal permanent residents as well as for paroling aliens into the country; INS officers overseas collect data on individual aliens applying for refugee status. Aggregate data on refugee admissions are submitted monthly on a special supplement to the G-23 report by the ports officially designated to process refugees. Individual-level data on the entry of refugees are generated through the nonimmigrant information system; the quality of these data is dependent on whether refugee status is recorded on the arrival portion of form I-94. The most comprehensive data on refugee admissions and settlement patterns come from the data systems managed by the Office of Refugee Resettlement in the U.S. Department of Health and Human Services (see Chapters 5 and 7~.

49 The INS statistical yearbook now includes tabulations of characteristics of refugees and asylees adjusting to permanent resident status. (Since the passage of the Refugee Act of 1980, parolees are not shown.) Published tables do not include information on the characteristics of refugees at the time of entry nor on the population of aliens in the United States seeking or granted asylum. The implementation of automated case tracking systems is expected to increase the availability and the accessibility of statistical information concerning the entry of refugees and persons seeking political asylum in the United States. Enforcement The operational areas classified as enforcement include the Border Patrol, investigations, antismuggling activities, intelligence, and detention and deportation. In general, enforcement programs are concerned with identifying and processing violators of the Immigration and Nationality Act. The Border Patrol The Border Patrol is responsible for the security of the borders of the United States with Canada and Mexico. The operations of the Border Patrol generate information on aliens apprehended on grounds of violating immigration law. Most of the data collected by the Border Patrol are maintained in local Border Patrol sector headquarters. The basic record completed for apprehended aliens is the Report of Deportable Alien Located (form I-213. Other local data bases have been developed to serve local needs and requirements. Border Patrol field units also complete relevant sections of the G-23 report. The I-213 report is completed by a Border Patrol agent for each alien apprehended. The conditions under which an agent completes the form vary widely. For example, the record may be completed in a Border Patrol station for a group of aliens or in the field at the point of apprehension. As noted above, the form includes a substantial number of items including name, age, nationality, physical characteristics, visa status, family information, occupation, date of entry, and circumstances of apprehension. Because of the volume of apprehensions in certain areas, forms with preprinted entries in selected blocks (name of sector, method of entry, nationality, etc.) are used to collect certain items of information. The complexity of the form and the varied conditions under which it is completed cast doubt on the accuracy of the information collected. A study by Davidson (1981) of a sample of forms for 1978 reports high nonresponse rates for certain questions. Most of the data collected through the activities of the Border Patrol are manually processed and submitted in aggregate form on the G-23 report. For example, the information recorded on form I-213 is available for analysis, for the most part, only in the form of aggregated G-23 report statistics. Greater emphasis on quality and machine processing of

50 I-213 data would make possible much more detailed and valuable tabulations for a group about which little is known. The Border Patrol Division in the central office in Washington also has authorized the special collection of data for certain enforcement operations. An example is the survey of apprehended aliens, begun during 1983. Data collected through the survey are intended generally to support program evaluation and planning within the Border Patrol and specifically to provide a basis by which changes in undocumented immigration can be anticipated. The survey questions include age, sex, family and household characteristics, details of entry, and intentions concerning length of stay and activity within the United States. Data are processed by the ADP unit in Washington. It should be noted that this survey was not discussed with staff of the Statistical Analysis Branch prior to initiation, nor has it been reviewed and approved by the Office of Information and Regulatory Affairs of the U.S. Office of Management and Budget, as federal regulations require. More emphasis on, and minor changes to, form I-213 would make such additional data collection exercises unnecessary. The INS statistical yearbook includes a few summary tables on the activities of the Border Patrol and on characteristics of deportable aliens located. These published tabulations are the most accessible source of information on Border Patrol activities. Detention and Deportation Detention and deportation programs are administered through district offices of the INS. These programs are concerned with any aliens being maintained in INS detention facilities and all aliens awaiting a hearing or trial or awaiting exclusion, required departure, or deportation. Data are maintained on aliens being detained and moving through the various stages of the legal system and aliens exercising available legal or administrative options. Individual-level data on deportations, required departures, crew member desertions, and exclusions are submitted each month by detention and deportation units to the Statistical Analysis Branch in Washington for data processing. Selected items submitted refer to demographic characteristics of the alien as well as information on status at entry, location of processing, and country of destination. However, the vast majority of deportable aliens are apprehended by the Border Patrol and, if given the option, request immediate voluntary return. These persons can be tracked only through data on the G-23 report and are classified by nationality only--as Mexican or other than Mexican. There is increasing public concern about differences in legal treatment among deportable aliens of different nationality groups. The automated case tracking systems have the potential for generating aggregate data on selected groups of aliens in various statuses in order to study the issues involved. There is also concern about what information is not provided by the data systems that are being developed. For example, the process of immediate voluntary departure (voluntary departure under safeguards) remains undocumented within the

51 data systems in existence now and those that are being developed for future use, except for highly summarized results available from the G-23 report. Invest igat ions Immigration investigators, like Border Patrol agents, are charged with the responsibility of locating persons violating the Immigration and Nationality Act, but they generally operate away frog the border areas of the United States. Most investigators are in cities and concentrate their activities on economic sectors in which undocumented aliens are believed to be working. The data generated in the investigations process are similar to those collected through Border Patrol activities. Data on investigation activities and alien violators (from form I-213) are summarized on the G-23 report, with files and records existing in generally inaccessible form in the field. Tables in the INS statistical yearbook are based on the G-23 reports and refer to the activities of district offices, covering Reportable aliens located by nationality, by length of time in the United States, and by employment status. Trial Attorneys Immigration trial attorneys, located in the office of the General Counsel (Figure 4-1), represent the agency in hearings and cases conducted by the Executive Office of Immigration Review, U.S. Immigration Court. Attorneys rely on statistical information generated by various units of the INS, particularly detention and deportation, for anticipating future workload. The G-23 report has been the primary source of such information despite its apparent lack of timeliness and accuracy (see below). The work of INS attorneys will soon be supported by an automated case tracking system, which should provide information on backlogs and produce current statistics on the number and types of cases in progress. THE WORK MEASUREMENT REPORT: FORM G-23 The statistical data base most familiar to INS personnel is the "Report of Field Operations," the G-23 report. Introduced in the 1940s, the G-23 report summarizes office workload activities in specific operational areas within examinations, enforcement, legal counsel, and management. When statistics are discussed at the INS, the G-23 report is the usual point of reference. It is the one statistical activity that is experienced in common among the range of diverse programs, personnel, and geographic locations. Having expanded dramatically over the years since its inception, the G-23 report today is a handwritten monthly compilation of thousands of numbers entered on as many as 43 pages of reporting fovea. The report is used for a wide variety of purposes within the INS; it is generally inaccessible to those outside the agency.

52 The G-23 report is relevant to a review of U.S. immigration statistics because it is the sole source of statistical information for certain categories of aliens. For example, the entry of aliens at land border crossings is reported only through G-23 statistics on primary inspections. Aggregate data on refugee admissions are compiled monthly for a special supplement to the G-23 report that is submitted by the ports officially designated to process refugees. This supplement identifies refugees by nationality and class of admission (principal, spouse, child). The number of aliens paroled into the United States is also tracked through G-23 report statistics on inspections. Special supplements to the G-23 report have been developed to document selected characteristics of populations of aliens such as the Cuban and Indochinese parolees. Currently, the G-23 report is the only source of aggregate statistics on the process of seeking political asylum. Most of the data collected through the activities of the Border Patrol, including information on Reportable aliens located (form I-213), are manually processed and submitted in aggregate form on the G-23 report. Investigations units submit a consolidated report on the employment characteristics of deportable aliens located, their wage levels cross-classified with sector of employment, and the number of deportable aliens receiving public assistance. The G-23 report is the source of investigations data published in the statistical yearbook. The G-23 report is used extensively within the agency for administrative purposes; the report is the data base used by personnel in the central, regional, and district offices for analysis of programs and allocation of resources. Analysis of G-23 report data has figured prominently in the evaluation of remote adjudications programs and efforts to reduce backlogs. Despite the widespread use of data from the G-23 report, there is a pervasive skepticism among program and policy analysts in the INS about the accuracy and comparability of the G-23 reports for support of operational research and analysis. For example, field inspections personnel use G-23 report statistics only as rough indicators of office performance prior to a site visit. The data are considered neither accurate enough nor appropriate for office or employee evaluation. The lack of timeliness of G-23 data has been a serious problem, resulting in delayed responses to inquiries from other agencies of government, policy makers, and the public concerning trends in refugee admissions and applications for political asylum. In summary, there has been critical concern within the INS about the quality of data reported and the possible lack of consistency among the offices submitting the reports. Much sharper criticism of the G-23 report came from program managers in district offices to panel members and staff in the course of our study: "The data are inappropriate as indicators of performance and productivity"; "The use to be made of many of the data items is unclear"; "The data do not represent the trends in or characteristics of operations being performed locally"; "The data are interpreted by central office personnel out of context"; etc. Because data from the G-23 report cannot serve program needs, many program managers develop their own information systems or bootleg reports that are more appropriate for evaluation and management of local programs.

53 The G-23 report is a detailed document that requires considerable experience and patience to use. The servicewide G-23 report for fiscal 1980, for example, had approximately 25,000 data entries: 17 columns and an average of 35 lines on 43 pages. In an effort to increase the utility of the information, the INS instituted a crash program in 1983 to keypunch, and thereby "automate," the handwritten G-23 report. At best, the keying of the information from the G-23 report may increase the accessibility of the data and make evaluation of the data easier. However, it does not address the critical issues of quality of data and comparability across organizational units. As the INS proceeds with plans to automate the collection of data in various operational areas, a considerable portion of the information that is now compiled in the G-23 report can be generated and tabulated by machine. A thorough review of the utility and quality of the data and the manner in which they are collected for the G-23 report could greatly reduce the reporting burden within offices and increase the timeliness and accuracy of the data for statistical analysis and program management. AUTOMATED DATA PROCESSING The INS depends heavily on the accuracy and accessibility of its records to accomplish its mission. Yet until the early 1970s the INS was dependent on manual systems for filing and retrieving information about millions of aliens. This section gives a brief review of the major automated systems that were introduced between 1972 and 1983 and raises a number of issues concerning automated processing of data on international migration by the INS. The INS started to automate its recordkeeping in the 1970s as the workload increased and significant backlogs began to develop; the decade was characterized by rather uncoordinated development of automated systems to handle the most pressing current problems. A study (Immigration and Naturalization Service, 1981:executive summary) reported that "there has been little standardization in the development of most of the systems. Automation capabilities simply evolved out of discrete needs. As a result, there are no automated interfaces, formal system documentation is either lacking or inadequate, and the administration of the systems is widely dispersed.'' In 1979 and 1980 the Committee on Government Operations of the U.S. House of Representatives conducted a thorough review of INS's automation efforts and put a hold on further procurement of hardware until a detailed strategy for automation was devised (U.S. Congress, 1980a). In reaction and response, the INS created an internal structure to plan and implement automation activities, develop detailed plans, purchase software and hardware, and integrate the new automated processes into the daily activities of its employees.

54 Early ADP Systems Two major systems were developed in the early 1970s to keep track of the files maintained by the INS and to maintain a record of the millions of nonimmigrants, such as visitors, students, and others who come to the United States each year. The master index system, operational since L972, was the first agencywide effort to introduce automation at the INS. The second, the nonimmigrant document control system, was an index of the records of arrival and departure of visitors and other nonimmigrants to and from the United States. The Master Index System The master index is a system of records that identifies the field location of files for the more than 12 million aliens who entered or were excluded from the United States since 1959. Documents for those who entered the country earlier are recorded on microfilm. The records in the master index are accessible either by the alien's file number (A-number) or by the alien's name and date of birth. The master index file includes the A-number, name, date of birth, country of birth, file control office in which the A-file is located, and the date of the latest transfer of the file. The master index remote access capability (MIRAC) provides the field offices with access to the master index via remote terminals, which expedites interrogations, adjudications, and investigations and reduces the manual work of the records sections both in the field offices and the central office. The master index has been a valuable tool for determining the location of A-f iles and for verifying that a record exists for a particular alien. The system has limitations, however, in its basic design as well as in its operational features. Because it was designed primarily as an index to the location of A-f iles, the master index is not suitable for generating statistics for policy needs. The system also was not designed to interact with other information systems, such as the nonimmigrant information system. Problems with MIRAC cited during panel visits to district offices include Slow response time, inadequate numbers of terminals, and excessive restrictions on district office personnel in updating records. The extent of omission of alien files from the master index is unknown, but one official estimated that up to 30 percent of the files that should be in the system are either missing or have been entered incorrectly. No systematic study has ever been carried out to determine the completeness or accuracy of the master index system. Because of these limitations, the master index is scheduled to be replaced in mid-1985 by the central index (described below), which is the core of the new data base management system in INS's long-range,ADP plan.

55 The Nonimmigrant Document Control System One of the earliest systems to be automated by the INS was the nonimmigrant document control system (NIDC), a centralized automated index developed in 1972 to automate the processing of records for the millions of nonimmigrants who arrive and depart annually. In 1982 NIDC included roughly 50 million records of the arrival and departure of nonimmigrants. The development of NIDC illustrates some of the recurrent problems that have been encountered by the INS in its efforts at automation. The system was designed to provide an index to the records of entry into and departure from the United States, derive statistics on types of visitors, and identify those who overstayed their visas. Unfortunately, no useful data were produced because of serious delays in entering records into the system and because of the lack of adequate controls on the collection of departure forms, and the system has been scrapped. In fact, the primary source of nonimmigrant data was the Statistical Analysis Branch, which independently produced data through manual processing of the basic forms. The process of collecting information on nonimmigrants is described more fully in the discussion of the new nonimmigrant information system that replaced NIDC in January 1983. Mid-Course Corrections Congressional Investigation In 1979 congressional concern about delays in processing applications and responding to public inquiries led to hearings by the House Committee on Government Operations. The committee examined the management of records by the INS and made recommendations in a number of areas, including record-keeping, forms, procurement, and ADP planning (U.S. Congress, 1980b). The recommendations of the committee set the framework for the further development of automated systems. The committee recommended that the INS: 0 Continue to pursue plans for automated input into the master index from the field (i.e., continue to develop MIRAC); 0 Postpone all procurement of ADP equipment until a long-range plan was completed and approved by the committee; o Work closely with the General Accounting Office, the General Services Administration, the Office of Management and Budget, and the appropriate committees of Congress in formulating its ADP plans; and o Develop and implement a plan assigning accountability to its senior executives for completing a satisfactory ADP plan.

56 The Scope of ADP Planning In 1980 and 1981 the INS completed a mission plan, a study of its information requirements, and a long-range ADP plan. In addition, an Office of Information Systems was formed to oversee the planning and implementation of information-related programs and automation projects at the INS. The director of the office, the Associate Commissioner for Information Systems, participates in developing information policy and directs all automation activities. The automated systems that are currently being put in place will have a major impact on the daily activities of INS employees and could affect the timing, quality, and availability of statistics produced by the INS for decades. The INS mission plan (Immigration and Naturalization Service, 1980a) states the major responsibilities of the agency and describes 81 specific strategies for achieving its goals. Unfortunately, more emphasis is placed on eliminating the collection of unnecessary data than on improving the accuracy and completeness of the data that are collected. Information requirements are narrowly defined as being the information needed by INS officers to make decisions about individual cases. This restricted view of what constitutes adequate data on immigrants--and emigrants--underlies INS statistical policy. In 1980 the INS conducted a study of its information requirements to lay the foundations for the development of automated systems. Although a limited attempt was made to address the statistical needs of other agencies, the study focused almost exclusively on the information considered to be critical to INS officers for making decisions in their daily work. The limited scope of the study was stated clearly (Immigration and Naturalization Service, 1980b:13~: The need for policy information of the Executive Branch and Congress--while long recognized--fell outside the purview of this report. Finally, the information needs of non-government users were omitted from this exercise. These users include the general public, members of which frequently request general information from INS, and the research community (colleges, universities, research foundations and consulting firms), members of which frequently request detailed information on aliens from INS. The scope of this study reflects the current top priorities of the INS. This succinct statement clearly indicates the low priority placed on immigration statistics by INS management. Interim Systems As work proceeded on a long-range ADP plan, the INS was authorized to develop two interim systems to handle the increasing backlogs and problems in tracking cases being processed in the largest offices. The naturalization and citizenship casework support system (NCCSS) was designed to monitor the status of naturalization and citizenship cases and to provide support to the clerical staff. As each application

57 is entered in the system, a sequential number is assigned to the case. This ensures that cases are processed in the proper order and that accurate counts of pending cases can be compiled. Prior to implementation of the NCCSS in Los Angeles, the estimated backlog of cases was 30,000; when NCCSS was implemented, with more accurate counting of cases, the backlog was discovered to be more than 50,000. The Reportable alien control system (DACS) was designed to improve the storage and retrieval of information on detention and deportation cases. In addition to monitoring the status of cases, the system is supposed to produce reminders of the next scheduled event and provide data concerning aliens who have been detained. An evaluation of the two interim case tracking systems by the Justice Department and the INS (U.S. Department of Justice, 1983) concluded that both systems were operating successfully in the offices in which they were initially installed. The evaluation noted, however, that technical problems at the test sites resulted in relatively slow and sometimes erratic response times. Recent Developments The Long-Range ADP Plan In September 1981 the INS completed a long-range plan that is expected to expand its ADP capabilities dramatically. The new initiatives in the area of automation differ significantly from the earlier efforts. Considerably more planning has gone into the development of the new systems, and an effort has been made to include most of the agency's operations in the plans for automation. The plan was developed on the apparently sound assumption that sufficient resources would be available to purchase equipment and software. The budget for automation activities is expected to double from approximately $60 million in 1984 to $120 million in 1986. A new strategy for information management is also being implemented. Rather than automating, and thereby institutionalizing, existing processes, the plan calls for a series of modular data bases in different functional areas. The use of the data-base approach permits flexibility for changing information requirements and is expected to make data available for INS users to generate their own reports. The long-range plan calls for the data bases to be linked to a central index that is scheduled to replace the master index in mid-1985. In-terms of implementation, development of the central index is nearing completion, the nonimmigrant information system and the immigrant data capture system are operational, and the two interim case tracking systems described above are being revised to conform to the specifications of the long-range plan. In 1984 the INS began purchasing ADP equipment to satisfy the future automation requirements of all offices.

58 The Central Index The purpose of the central index is to provide a list of the particular data bases in which more information about an individual can be found. The central index will contain such identifying data as name, A-number, date of birth, sex, classification of admission, country of birth, port of entry, date of admission, files control office, and a list of the data bases containing information about the person. Statistical information is expected to be available for reporting and management purposes. The central index is being created by merging data from the master index, the nonimmigrant information system (see below) and other INS computer systems. After the central index is operational, each action by the agency will provide an opportunity to create or update records for an individual. In developing the central index, considerable emphasis is being placed on being able to respond rapidly to field and other - inquiries. Data bases that could be linked to the central index include those for legal pe~anent residents, students, other nonimmigrants, smugglers, exclusions, apprehensions, and refugees, asylees, and parolees. The Nonimmigrant Information System The Nonimmigrant Information System (NIIS) is the first operational system that is consistent with the long-range ADP plan. The purpose of NIIS is to collect information on the arrival, departure, and status of visitors, students, and other nonimmigrants. The process begins with a nonimmigrant completing INS form I-94 at the time of entry into the United States. The arrival section of the form is collected by the inspector at entry, and the departure section is stapled to the passport. The NIIS is supposed to be updated for each change of status, such as an extension of stay, while the nonimmigrant is in the country. When an alien leaves the United States, the departure section of the I-94 form should be turned in to an INS official or collected by the carrier. The data keyed into the NIIS include name, date of birth, address while in the United States, changes of status, mode of travel, port of entry and departure, school attended (if applicable), and the city in which the nonimmigrant visa was issued. The nonimmigrant information system does not reflect the arrival and departure of all aliens. For example, resident aliens who are returning from a visit abroad are not required to complete I-94s, and immigrants arriving to reside in the United States complete the forms, but they are not entered into the system. Collection of I-94s for arrivals is more complete than for departures, reflecting the lack of departure controls. The absence of such controls may severely limit the ability of the NIIS system to estimate the number of persons who stay longer than their period of admission; generally, the numbers of "overstayers" will be overstated.

~9 The Immigrant Data Capture System The immigrant data capture (IMDAC) system was designed to process information from immigrant visas and forms for adjustment of status and to produce data tapes for the alien identification card facility, for the Statistical Analysis Branch, and for the Records Branch for updating the master index. Prior to the establishment of IMDAC, immigrant visas and adjustment of status forms were processed separately by each of these three organizations. In addition to eliminating the duplication in coding and processing visas, the system creates the A-files that are sent to the appropriate INS district offices. The system appears to be working as designed. Issues Raised by Automation There are important issues and potential problems related to automation that deserve further consideration. These include the need for sensitivity to users when redesigning forms or making changes in data collection, adequate current documentation of systems, increased attention to the quality of the input to automated systems, and the need for establishing training and maintaining communication between the systems designers in the central office and the users in the field. Finally, adequate safeguards should be established to ensure the confidentiality of the information INS maintains about individuals. Optimism about the efficacy of the systems now being developed and introduced within the INS should be tempered by knowledge of both difficulties encountered in earlier efforts at automation and the difficulty of the tasks that remain to be accomplished. INS RESOURCES FOR STATISTICAL ANALYSIS As the preceding discussion has clearly indicated, the different parts of the INS, in carrying out their diverse missions, produce a large amount of administrative information, some of which they use internally for management purposes. The key to unlocking the potential within this structure for information of use in policy-related analysis, in evaluating the numbers and movements of immigrants, and in informing Congress and the public is the presence of a competent, adequately staffed and funded statistical organization fully supported by management and charged with the responsibility of producing timely and high-quality data and analyses and of ensuring the collection of such data throughout the organization. The Office of Plans and Analysis Institutionally, the mandate of immigration policy analysis lies within the Office of Plans and Analysis (OPA), an executive-level unit under the executive associate commissioner. This office conducts studies to

60 evaluate the implications for INS of legislative initiatives as well as analyses of INS programs, organization, and resources; it is also responsible for anticipating the effects of changes in patterns of international migration to the United States and in characteristics of the resident alien population. Since 1982 the Office of Plans and Analysis has been responsible for the agency's statistics and research programs and presently oversees the activities of the Statistical Analysis Branch. The Statistical Analysis Branch The Statistical Analysis Branch is the unit within INS that has responsibility for assembling both workload (i.e., management) data and population (i.e., policy) statistics. The branch does not have a major role either in determining what is to be collected and how or in formulating statistical policy for the agency; its responsibilities are simply to compile and disseminate what is produced elsewhere. The branch is responsible for producing an annual statistical report, compiling work measurement statistics, and responding to requests for information from Congress, other federal agencies, and other users of data on aliens and naturalized citizens. The branch's functions currently are being carried out by a staff of about 30, including 9 analysts and statisticians (in early 1984, the number stood at 5), at an annual operating cost of approximately $1 . 3 million (fiscal 1983~. Prior to 1983, the Statistical Analysis Branch was located within the Office of the Associate Commissioner for Information Systems; since then, the branch has received its day-to-day direction from the Office of Plans and Analysis, although its budget is within the newly organized Office of Information Services. Discussion of the Statistical Analysis Branch must begin with consideration of the staff available to undertake its assigned tasks. The branch does not have a full-time head, and far from being a one-time or short-term phenomenon, this situation has existed, with rare exceptions, for long periods over the past few years. It is therefore not surprising that high turnover has marked the other professional positions and that the professional staff, however capable, has been unable to achieve the performance that could follow from enlightened and strong professional leadership and agency support. The failures of the Statistical Analysis Branch also can be traced to the extremely inadequate size of its professional staff: even when fully staffed, with only nine professional positions, it is surprising and to their credit that so many of their tasks are carried out. About half of the 30 staff members have responsibilities related to statistics from the work measurement (G-23) system. Incoming forms are checked for completeness, and compilations are done for the district, regional, and national levels. The other half of the staff oversee the compilation of demographic data, produce the annual statistical report, and respond to requests for information. Statistics are compiled and distributed for immigrants, students, visitors, temporary workers, refugees and asylees, and naturalizations. In addition to compiling and

61 distributing statistics, the branch staff inform field offices of changes in reporting requirements and coding procedures. It is instructive to compare the INS with a parallel federal agency, the Internal Revenue Service (IRS). Similar in structure and responsibility to INS, the IRS is a constituent part of a larger agency (the Treasury Department); has many field offices and diverse responsibilities; and most of its data derive from a large flood of administrative records. Within IRS, however, the statistical responsibilities are centralized within a division headed by a professional statistician and reporting directly to an assistant commissioner. The division is known and respected throughout the agency, including the IRS service centers; it is similarly known by and involved with sister statistical organizations in the federal government; and its products are extensively used in program planning and evaluation by the Office of Tax Analysis in the Treasury Department as well as by the Congress. As a final point of comparison, the IRS division's direct budget in fiscal 1984 was approximately $7 million and supported almost 170 staff years of effort. In addition, the division received some $8.25 million that it distributed to other parts of the IRS to support statistical activities required for its work. Our purpose in making this comparison is not to suggest that the statistical activities within the INS require or deserve equal treatment; the great disparity between the respective groups, however, whether in organizational status, staffing, budget, or reputation--given their many other similarities--gives a clear indication of the low priority accorded to the statistical program of the INS. The work of the Statistical Analysis Branch has experienced at least two major setbacks in the last five years. The first of these was the complete loss of statistics for nonimmigrants for the period July 1979 to September 1980. A large backlog had occurred in the processing of I-94 forms for nonimmigrants, partly due to the increased number of visitors to the United States. An unsuccessful effort was made to develop estimates of the flow of nonimmigrants using sampling techniques. As a result, INS has no statistical data on nonimmigrants for the last quarter of fiscal 1979 and for the entire 1980 fiscal year. For fiscal 1981 and 1982, when processing was resumed, only a limited number of characteristics were made available. The second setback was the loss of records from the immigrant data files for 1980 through 1983. This loss resulted from the physical loss of computer tapes containing immigrants' statistical records. In addition, some adjustment of status cases may not have been coded by the field. The presentation of tables showing data for immigrants in recent years has been made possible only by linking the agency's statistical data file with the data file of immigrants receiving I-551 forms, alien registration receipt cards ("green cards". However, since the data file on persons receiving I-551 foes does not contain all of the statistical variables that are on the immigrant visa, many of the statistical tables could not be produced from this source. To date, INS has not attempted to recapture the data on these missing records. As a consequence, statistics on immigrants for 1980 and 1981 have not been tabulated for

62 such important variables as sex, marital status, occupation, place of intended residence, country of last residence, and nationality. It appears that, beginning with fiscal 1984, the problem of missing statistical data has been resolved. The immigrant data capture (IMDAC) system was fully implemented and appears to be working smoothly; however, the best of systems can be rendered useless by a lack of proper storage, control, and protection of data tapes. The process of automation that is now accelerating at the INS has significant implications for the operations of the Statistical Analysis Branch. For example, the coding of visas and applications for adjustment of status is now done as part of the IMDAC system, rather than by the branch. The new nonimmigrant infonmat ion sys tem incorporates the processing under contract of the millions of I-94 arrival/departure documents that were formerly coded by the branch. As more data bases are created in accord with the long-range ADP plan, it should be possible for the branch stat f to have faster acces s to information and to allocate relatively more staff positions to professional analysts rather than clerical personnel. More detailed tabulations can be prepared to respond to users of INS data, and it should be possible to release public-use tapes for a wide variety of immigrant and nonimmigrant groups. Increased automation of data systems raises the potential for more detailed analysis and interpretation of data and for more constructive interaction with outside users. Whether this potential is realized remains to be seen; past experience, unfortunately, does not lead to an optimistic forecast. Automation by itself, however, will not solve the problems that have been evident for some time in the statistical operations of the INS and particularly in the Statistical Analysis Branch. Except for its somewhat limited participation in the ADP planning process, the branch appears generally to have been ignored in the design and implementation of the new systems. Forms are redesigned and specific items are added or deleted without consultation and sometimes without the knowledge of personnel in the branch. Similarly, the branch has no clear responsibility for, or control over, the quality of data collected throughout the INS. In summary, automation is likely to have an increasing impact on the operations of the branch, and the INS should make sure its staff and organization are prepared for the inevitable changes in its role and involved in the evolution of the system to ensure adequate quality control and that statistical needs can be easily and quickly met. Branch Publications INS Statistical Yearbook Delay in publishing the agency's statistics has increased considerably in recent years. The narrative section of the 1978 Annual Report was published without its statistical component, approximately 100 pages of statistical tabulations, because the statistical tables were not ready in time. Although annual reports had not included any statistical analysis in the recent past, they did include 30 to 40 pages of description of the agency's activities. As

63 this commentary included occasional definitions, descriptions of new legislation, and changes in INS policy, the text was an aid in interpreting the statistics. Since 1978, however, the statistics of INS have been published without any accompanying text, and only three Statistical Yearbooks, for 1979, 1980, and 1981, have been published. , For 1980 there was a 3-year lag between the collection of statistics and their publication, which was reduced to 2 1/2 years for the 1981 data. How can the Statistical Yearbook of the Immigration and Naturalization Service be improved? Certain basic suggestions are readily apparent from the previous discussion: (1) the report should be released in a timely manner; (2) it should be accompanied by explanatory and analytical text; (3) it should present data on all of the agency's data series (i.e., immigrants, nonimmigrants, naturalizations, etc.~; (4) the series in the report should be consistent from year to year, with necessary changes clearly noted and explained; (5) for each data series in the report, the data should be tabulated for all relevant variables; (6) some of the tables currently published, consisting largely of empty cells, should be condensed or dropped; and (7) the treatment of missing data and the number of cases missing or imputed should be fully described (see Appendix B.). - Many of the problems indicated by the above list could be corrected if the INS placed higher priority on data collection and tabulation efforts. The prompt dissemination of the agency's statistics is hindered by delays attributable to the low priority given to statistical coding--if not all statistical activities--in its field offices. Since INS's statistical data are generated on a flow basis over the year, it should be possible to publish statistics only months after the close of the fiscal year, not several years as is the case now. In addition, quarterly figures could be published during the year. This is a very basic task--the prompt processing of all statistical data. The fact that it is basic, however, does not diminish its importance, nor does it imply that it is effortless to accomplish. It demands significant amounts of planning, continual attention, and resources on the part of INS. Without this firm foundation, other gains made by improving the agency's data-processing capabilities will be negated. The reporting of INS's statistics would be improved by returning to the consolidation of the statistical tables of the statistical yearbook with the annual report as was done prior to 1978. As mentioned above, this consolidation would serve two purposes: it would link the agency's statistics with a description of its activities during that year, and it would focus needed attention on the statistics, ensuring their prompt publication. Although the present text of the annual report helps in understanding the agency's statistics, it does not meet this need completely. A descriptive analysis accompanying the statistical tables would assist users in interpreting the statistics. Such analysis should describe the characteristics and trends of the data series, as well as providing a discussion of relevant legislation or INS policy that may have affected the data. As the INS strengthens its statistical capabilities, future annual reports should be expanded to include more in-depth analysis and to inform readers of additional sources of INS data, notably unpublished detailed tables and public-use tapes (discussed

64 in detail below). One major improvement in the 1981 Statistical Yearbook over preceding issues is the inclusion of a glossary defining U.S. immigration terms. The definitions of terms according to immigration law are seldom the same as those in common usage. The trend in recent years toward increased documentation--technical explanations of data and methods--should be accelerated because such documentation is essential to informing users of legislative and policy changes and other qualifications of the meaning of the data. The individual statistical tables need to be reviewed to increase their usefulness and to eliminate those that are downright misleading or based on data of very poor quality, such as tables 48 and 50 of the 1981 Statistical Yearbook concerning border crossers. New tables have been added in recent years presenting detail and perspective on such topics as refugees (1980 Statistical Yearbook:tables 9 and 10) and immigrant classes of admission (tables 3, 4, and 6~; in addition, many existing tables have been expanded to cover all, rather than just selected, countries. These changes need careful evaluation since the result is a series of very long, complicated tables with many empty cells. At the same time, however, such changes improve the usefulness of the statistics and should be actively pursued. Not only do they make it easier for users of the data, but they also reduce INS's workload in the long run by decreasing the number of individual statistical requests coming to the agency. In addition, changes in table format and design are essential; some of the tables are difficult to read without a magnifying glass. Finally, there should be increased attention to detail. Reports should be proofread more carefully so that the number of errors, whether processing or typographical, are reduced. The present published tables of the INS statistical yearbook are formatted (and correctly so) to reflect U.S. immigration law. Data are tabulated by the Immigration and Nationality Act's definitions of immigrants, nonimmigrants, etc., for U.S. fiscal years and for countries as recognized by the INA. However, the agency should also begin to develop additional tabulations to conform to international definitions. The United Nations (1980) has recommended definitions and tabulations for international migration statistics that will improve international comparability. The United States should begin to move toward this goal, even though it is not possible to carry out all the recommendations at this time. For example, it might be possible to use the nonimmigrant information system to produce tabulations consistent with the international definition of long-term and short-term immigrants. Several other points regarding the statistical tables should be made. Content should be updated annually, reflecting geopolitical changes and changes in immigration law. For example, until recently, data were tabulated and published for such "countries" as Palestine and the Free City of Danzig--long after they were no longer recognized by the INA and the U.S. State Department. In recent years, the Statistical Analysis Branch has begun to incorporate appropriate changes to the statistical tabulations. This monitoring of changes to the INA should be continued. All of these comments point in one direction: the INS must place a higher priority on its statistics and their publication; after all, the

65 Statistical Yearbook is one of the major reports of the agency. Many of the recommended improvements can be accomplished with existing staff although some may require additional resources. The Immigration and Naturalization Service has an extremely dif ficult mission to accomplish in administering the nation's immigration and naturalization laws. The timely publication of high-quality statistics is also an important responsibility that should be given considerably higher priority by the INS. INS Public-Use Tape Program In 1979 the Statistical Analysis Branch began a public-use tape program. At present public-use tapes can be made available for most of the sets of data maintained by the Statistical Analysis Branch. Personal identifiers such as name, A-number, and address are removed from the tapes. The INS should make an even stronger commitment to a public-use tape program. The first step would be to define a staff with clear responsibilities for the tape program. Better documentation and public information about the tapes is also crucial for improving the public-use tape program. Such a program may require additional resources, but would be beneficial to the INS as well as to other users of immigration data. Statistics on the Resident Alien Population Since the annual Alien Address Registration Program was discontinued in 1981, the INS has been unable to estimate the size of the alien population residing in the United States or in local areas of the country. Until 1981 all aliens residing in the United States in January of each year were required to complete and submit form I-53, listing current address, category and date of admission, and demographic information such as age, sex, and country of birth. The alien registration program provided detailed geographic information about the alien population that was useful for resource allocation and, potentially, for a variety of statistical purposes. Recommendations for using the I-53 data were made by a wide variety of groups and individual researchers during the 1970s. The data have been used in a number of statistical studies such as estimating the annual level of alien emigration from the country and estimating the number of illegal aliens who were included in the 1980 census. Despite the actual and potential value of the alien registration data, the perception grew within INS (and subsequently, within Congress) that the data were grossly underreported--although no tests of completeness were ever attempted--and of little value to the agency. Accordingly, when Congress proposed to discontinue the program as an economy measure, the INS did not object and the program was discontinued after 1981. A valuable source of information about the alien population residing in the United States was lost because users of the data, including analysts in the INS, were unable to convince the management of INS that the data were valuable and should be collected, evaluated, and utilized.

66 The panel seriously considered recommending the reinstatement of a modified alien address program that, for statistical purposes, would have collected information only at two or three fixed points each decade. However, after much discussion, we concluded that it was not appropriate to single out a unique and specific segment of the population in the United States and require registration solely for statistical information. Instead, we wish to emphasize the need for the development of other approaches to fill this data gap. One such alternative for collecting information about aliens residing in the United States, a longitudinal study of immigrants, is described in Chapter 8. A Statistical Advisory Committee The preceding discussion points to the need both for strong leadership and enhanced statistical professionalism within the INS and for an ongoing group of outside expert advisers to assist the INS in establishing and maintaining a coordinated and responsive statistical program. Such a statistical advisory committee could consider specific issues, such as how best to fill the gap left by the cancellation of the alien address program, whether and how to collect information about emigrant aliens, and how to estimate the size and growth of the illegal alien population; it also could address broader issues, such as the role of INS in implementing the U.N. recommendations for collecting data on international migration and provide the commissioner with independent expertise on the quality of the INS statistical program and on user needs. Evaluation of INS Statistics Evaluation of data quality should have a high priority throughout the INS. For a variety of reasons, including greater objectivity, it would be useful to contract much of the evaluation of data quality to sources external to the INS, either inside or outside the government. Precedent exists within INS for issuing such contracts (this panel's work, for example, was funded through contract). Moreover, such contracts are regularly used by the Office of Refugee Resettlement (ORR), which devotes a portion of its annual budget to evaluation activities. Contract research also can take advantage of specialized expertise outside the INS. The U.S. Census Bureau has developed and will continue to elaborate statistical procedures and models for estimating the extent of census coverage (see Chapter 5~. A contract (or other interagency agreement) could benefit the INS in applying this expertise to its problems of a similar nature. To date, however, although precedent exists for using the contract mechanism and although substantial increments in data quality might be achieved through contract research, INS has made relatively little use of contracts. More explicit attention should be given to such research as an integral part of the INS's data quality assurance program.

67 CONCLUSIONS AND RECOMMENDATIONS As we noted at the outset of this chapter, the effective mission of the INS is to enforce immigration policy and law. In carrying out this mission, the INS, through its various entities, assembles a multitude of administrative records and information items. Traditionally overburdened in the handling and processing of these records, the agency has taken dramatic strides in recent years in planning, designing, and implementing automated systems to deal with the handling, storage, and retrieval of records. Within the next five years, the agency indeed may be able to point with pride to its ability to locate efficiently and quickly the record of a specific alien. Unfortunately, the INS has not approached either its statistical system or its statistical organization in the same positive manner. On the contrary, from the Office of the Commissioner down through the organization to the single-employee border crossing station, the INS has failed to understand--and therefore failed to support--the need for timely and high-quality data. Even the information contained in its key management form, the G-23, is considered suspect by its staff. In addition, a number of senior staff question any INS role in producing policy-relevant statistics. This position also is reflected in what can only be described as meager staff and funding resources assigned to statistical compilation and analysis--nine allocated professional positions for the entire agency. The panel's view of the situation is not unique. Concerns about the inadequacies of the system in meeting data needs can be found in the records of innumerable congressional hearings on the INS, in the reports issued by congressional committees considering legislation dealing with aliens, in academic writings, and in popular articles on the subject. The most recent example of congressional displeasure at the situation is found in a House Judiciary Committee report accompanying the Appropriations Authorization Act for fiscal 1985 (U.S. Congress, 1984~; the following excerpts highlight the frustration: The Committee amendment for the first time provides statutory language requiring the collection, preparation and distribution of information and data on the number and characteristics of immigrant and nonimmigrant aliens entering and departing the United States. The Committee is deeply concerned about the unavailability of accurate and current statistical information on immigration matters. The Committee notes in this regard that INS has not devoted sufficient resources and attention to this problem and, to a great extent, has ignored the statistical needs of Congress, as well as the research needs of demographers and other outside users. While the Committee recognizes that INS must place first priority on its own operational requirements, the informational needs of Congress cannot be ignored.

68 The Committee frequently has been frustrated in its attempts to obtain the statistics needed to assess the impact of legislation it is considering. For example, only very rough estimates were obtainable of the number of investors and foreign medical graduates who would potentially benefit from the status adjustment provisions contained in the Immigration and Nationality Act Amendments of 1981, enacted by the 97th Congress as P.L. 97-116. Additionally, the Committee recently had to make a special request to the General Accounting Office for a study on the use of H and L nonimmigrant visas [for temporary workers and intracompany transferees]. This extraordinary step was taken because of the inability of INS to respond to inquiries by the Committee on admission and adjustment of status figures for temporary workers and intracompany transferees (H and L visas) in various occupations. The most widely publicized lack of statistics occurred during the Iranian crisis in 1979, when INS was unable to provide a count of Iranian students in this country. The Committee wishes to stress the need for comprehensive and timely statistics on immigration. Since INS processes the source forms for these statistics, the responsibility for their reporting and content rests logically with that agency. Congress, of course, must share some of the blame for the very situation about which it complains. Congress, as it did in the case of the Refugee Act of 1980, could have mandated both the collection of the data it desired and the preparation of analytical reports for use in its deliberations; it also could have requested an assessment of needs and provided such funding and staff as it deemed necessary to accomplish the task. The panel urges the Congress to exert its leadership to ensure that the INS and the other organizations concerned with this issue clearly understand and are equipped to deal with what is expected of them. That the INS is a veritable storehouse of data is beyond question; the quality of the information contained in its many millions of records or in summarized tabulations is another matter. The data indeed are used because in most cases they are the only data available, but use is not synonymous with quality. Our study indicates that the INS does not use even the most rudimentary of the accepted techniques in collecting and processing its data, such as: instituting quality control procedures at each level of operation; using sampling when appropriate; documenting procedures; instituting periodic training of staff to ensure understanding of objectives and testing procedures; and developing feedback mechanisms to identify and solve problems. Further, the INS has failed to assign either responsibility or accountability for its statistical program. As a final point, it is quite clear that despite its huge inventory of facts, the INS has not assembled its data or gathered the relevant information to address either the kinds of substantive policy questions identified in Chapter 3 or even the more focused issues noted in the House report cited above.

69 We are not unmindful of the difficulties involved in attempting to overcome many years of accumulated problems in a relatively short time. However, given the importance of the Immigration and Naturalization Service, it is essential that the agency begin immediately to improve drastically its statistical policies, programs, and procedures and to be able to show progress in a relatively short time. To expedite the effort the panel recommends that the INS: o Seek short-tenm, temporary assistance from the major federal statistical agencies, including advice on statistical procedures and the temporary assignment of experienced staff; o Establish an advisory committee of outside experts in the field of immigration analysis to advise on data gaps, priorities, and problems. Such a mechanism is used extensively by other federal agencies and provides an invaluable source of expert advice and objective comment; and o Establish a program of contract research with the short-run objective of evaluating data production and quality and the long-run objective of stimulating quality analysis of INS data sets. Such a program, which has many precedents, would allow the INS to take immediate advantage of the specialized expertise outside the agency. In the longer run, such a program would encourage the growth of experience in the use of INS data and provide a base of knowledge for policy and program . . . aec IS lOnS . Given the present situation, the panel also has little confidence in the ability of the INS to meet the statistical requirements associated with enacting and implementing new immigration legislation. Therefore, we believe it essential, given the central role of the INS in assembling data on aliens, that immediate steps be taken by both the legislative and executive branches of government to address and remedy the situation. Some of these steps have small or insignificant budgetary implications, whereas others will require additional funding. The likely financial and personnel costs of these recommendations that cannot reasonably be absorbed within existing budgets are discussed following the recommendations. The panel recommends that Congress: o Strongly affirm the importance of reliable, accurate, and timely statistical information on immigration to the needs of the Congress and direct the Attorney General to reexamine the organizational structure of the Immigration and Naturalization Service as it relates to statistics, with a view to placing greater priority on this important task and o Require that the Attorney General prepare and submit by June 30 each year an annual report to the President and the Congress, presenting data on aliens admitted or excluded, naturalizations, asylees, and refugees, describing their characteristics, and containing an analysis of significant developments during the preceding year in the field of immigration and emigration.

70 The panel recommends that the Attorney General: 0 Issue a strong policy directive asserting the importance of reliable, accurate, and timely statistical information on immigration to the mission of the INS and unequivocally committing the agency to improving its existing capabilities. The panel recommends that the commissioner of the INS: o Issue an explicit statement clearly sett ing forth that the collection, cumulation, and tabulation of reliable, accurate, and timely statistical information on immigration is a basic responsibility of and inherent in the mission of the agency; o Establish a Division of Immigration Statistics, reporting directly to an associate commissioner or an equivalent level, with overall responsibility: --for ensuring the use of appropriate statistical standards and procedures in the collection of data throughout the agency; --for ensuring the timely publication of a variety of statistical and analytic reports; --for providing statistical assistance to all parts of the agency in carrying out their mission; and --for directing statistical activities throughout the agency; o Direct and implement the recruitment of a full complement of competent, trained professionals with statistical capabilities and subject-area experience; o Initiate a review of all data-gathering activities to eliminate duplication, minimize burden and waste, assess specific data item needs and uses, improve question wording and form design, standardize definitions and concepts, document methodologies, introduce statistical standards and procedures, and promote efficiencies in the use of staff and resources; o 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; to advise on the statistical implications and potential of ADP plans; and to provide the agency with independent evaluation of its statistical products, plans, and performance; 0 Establish formal liaison with other federal and state agencies involved in the collection or analysis of immigration-related data; 0 Establish both a program to enhance and stimulate research into the various effects of immigration and a fellows program, which would bring to the agency for a period not to exceed 2 years outstanding scholars and experts to undertake original research using published or unpublished data from the INS or other sources; o Authorize the proposed Division of Immigration Statistics to initiate a program of contract research. This research, which may be either extramural or intramural, should be focused on the evaluation of data production and data quality;

71 o Strengthen the annual report, presenting data on immigrants, nonimmigrants, naturalizations, asylees, parolees, and refugees, describing their characteristics, and analyzing significant developments during the previous fiscal year. The report should be published annually by June 30; o Establish a process ensuring adequate discussion and consideration both within and outside the agency of changes in forms and data collection procedures; and o Institute such other activities as are necessary and desirable to ensure: --understanding at all levels of the agency of the commissioner's commitment to high-quality, timely statistical data; --agreement with, and support for, the commissioner's policy directive. The panel recommends that the Director of the U.S. Office of Management and Budget (OMB): o Ensure that OM8 exercise its responsibilities to monitor and review statistical activities and budgets concerning statistics on immigration and emigration, and particularly those of the INS, to minimize duplication and ensure that appropriate procedures are used, standards met, and priorities observed in the collection, production, and publication of such data; o Require continuing interagency coordination in the field of immigration data; participate in discussions designed to achieve consistency and comparability in concepts and definitions used by the individual organizations in the collection of such information; and oversee the introduction and use of standardized approaches; and 0 Actively encourage and support the timely publication and dissemination of immigration data and the ready availability of fully documented public-use data tapes, including samples of individual records (with identifiers removed) where feasible, and data summaries. The agenda of required actions reflect lengthy deliberations on the panel's part, particularly concerning the cost-effectiveness of the proposed measures. Clearly, in the present climate of budgetary restraint, it would have been inappropriate and futile to recommend a package of improvements entailing sharply higher expenditure; at the same time, no improvement of the order of magnitude required can be expected with the existing budget solely from improved efficiency and attitude. Many of the recommendations listed above, however, require little or no additional funding. For example, when we ask of the Congress and the Attorney General that, to use the words of Arthur Miller, "attention be paid," the benefit should be great and almost immediate and the dollar cost small. Similarly, the costs to OMB of our recommendations, while not zero, should not exceed $25,000 per year, about a half-year of staff effort, in starting, nurturing, and carrying out the coordination function that by law is the responsibility of OMB. In several instances, however, despite our self-imposed constraints, the panel has found it necessary to recommend actions that will involve

72 relatively large expenditures. An example is the recommendation to establish a Division of Immigration Statistics, an action the panel believes to be essential. In order, however, to mitigate its funding effect in a single year, and recognizing the start-up problems inherent in such an action, the panel proposes that the development of the division be phased over several years; a period of 3-5 years would appear reasonable. Using as a guide the current $1.3 million budget of the present Statistical Analysis Branch, which supports about 30 persons, of whom 9 are professionals, we propose an ultimate annual budget for the division of $3.75 million, supporting a staff of 40 professionals and 20 support staff, 60 persons in all. As noted earlier, the growth would be accomplished over several years. Using a 3-year period, the present $1.3 million budget would increase to $1~8 million in the first year, to $2.75 million in the second year, and would achieve the $3.75 million level in the third year. The increase over the present budget would require an additional appropriation of $2.5 million. We view this level sufficient to accomplish all the recommendations noted above that are directed to the INS, if accompanied by the essential changes in attitude and priorities also recommended for the agency. REFERENCES Davidson, C. 1981 Characteristics of Deportable Aliens Located in the Interior of the United States. Unpublished paper presented at the annual meeting of the Population Association of America, Washington, D.C. Immigration and Naturalization Service 1980a INS Mission Plan, INS Planning Task Force, Robert A. Kane, Chairman. Unpublished paper. Immigration and Naturalization Service 1980b Information Requirements Study, Volume 1, INS Planning Task Force, Robert A. Kane, Chairman. p. 13. Unpublished paper. Immigration and Naturalization Service 1981 Long Range ADP Plan, Volume 1, Office of Operations Support. Unpublished paper. U.S. Congress, House 1980a Immigration and Naturalization Service Record Management Problems. Committee on Government Operations. 96th Congress, 2nd Session. Washington, D.C.: U.S. Government Printing Office. U.S. Congress, House 1980b Immigration and Naturalization Service Record Management Problems. Committee on Government Operations. 96th Congress, 2nd Session. Pages 7-9. Washington' D.C.: U.S. Government Printing Office. U.S. Congress, House 1984 Report to Accompany H.R. 5468, Department of Justice Appropriation Act, Fiscal Year 1985. Committee on the Judiciary. Washington, D.C.: U.S. Government Printing Office.

73 U.S. Department of Justice 1980 March 15 Statement of David Crosland before the Senate Appropriations Committee, p. 11. U.S. Department of Justice 1983 Joint Study, INS Interim ADP Projects. Prepared by Justice Management Division, Department of Justice and Evaluation Division, U. S. Immigration and Naturalization Service. Unpublished. United Nations 1980 Reco en ations on Statistics of International Migration. Series M. No. 58. New York.