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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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Representative terms from entire chapter:
master index
36
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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.
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.
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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.
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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.
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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.
