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The Immigration and Naturalization Service's
Automated I-94 System

Report Number I-2001-18
August 6, 2001


"Overstays" are nonimmigrants who do not depart the United States upon expiration of their authorized stays. According to an Immigration and Naturalization Service (INS) report published in November 2000, overstays represent about 40 percent of the estimated 5 million illegal immigrants currently residing in the United States. The Department of Justice FY 1999 Annual Accountability Report listed the monitoring of alien overstays as a "Management Challenge" and stated that the collection of automated arrival and departure records would help ensure complete and reliable data.

The form used to collect arrival and departure data is the I-94. The INS began developing a system to automate the processing of air passenger I-94 forms in 1995. Both the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 and the Immigration and Naturalization Service Data Management Improvement Act of 2000 require the INS to develop an automated entry/exit system for use at land, air, and sea ports of entry. The laws differ in time frames and definition of "automated entry/exit system." The INS planned to use the Automated I-94 System to help meet the requirements of both laws.

Our audit focused on the design and implementation of the Automated I-94 System. The system currently operates at four air ports of entry; the INS has not implemented the I-94 System at any land or sea ports of entry. We found that the INS has not properly managed the project. As a result, despite having spent $31.2 million on the system from FY 1996 to FY 2000, the INS: (1) does not have clear evidence that the system meets its intended goals; (2) has won the cooperation of only two airlines and is operating the system at only four airports; and (3) is in the process of modifying the system. Recent INS projections estimate that an additional $57 million will be needed for FY 2001 through FY 2005 to complete the system. These projections include development, equipment, and operations and maintenance costs. As a result of these concerns and the amount of money needed to complete the system, we make a number of recommendations aimed at ensuring that the INS rigorously analyzes the costs, benefits, risks, and performance measures of the Automated I-94 System before proceeding with further expenditures or implementation.

Specifically, we found that as the project progressed through its life cycle the INS's efforts to compare interim results against estimates were inadequate. The INS did not: (1) convert the project's intended purpose into measurable goals, (2) collect baseline information, and (3) complete a cost-benefit analysis. We also found that the INS did not adequately manage the risks associated with the system. One risk, the lack of air carrier participation, has halted the deployment of the system as currently configured. This risk might have been mitigated had the INS developed the risk management plan required by its systems development life cycle model. The INS is currently evaluating ways to modify the system so that air carrier participation is not necessary. However, INS officials provided no details on the nature of these modifications to allow us to determine the feasibility of operating the system without voluntary air carrier participation.

Our audit objective, scope, and methodology appear in Appendix III. The details of our work are contained in the Findings and Recommendations section of the report.

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