Audit Acknowledges that Proper Immigration Processing Takes Time

By Dan Cadman on April 4, 2018

The Department of Homeland Security Office of Inspector General (DHS OIG) has published a little gem of an audit report: "USCIS Has Unclear Website Information and Unrealistic Time Goals for Adjudicating Green Card Applications".

Anyone who has read my blog posts over a period of time probably knows that I'm not always enamored of the audit work of watchdog agencies such as the OIG or Government Accountability Office (GAO). I recognize the importance of oversight, but sometimes come away dissatisfied with the audit reports. Often enough, they strike me as puerile or, worse yet, having completely missed the mark.

Then, there's the fact that it's all too easy for auditors to swan into an agency, delve through a "sampling" of files or data, crank up a few tables and charts, and declare the work of that agency's workers flawed or inadequate in the resultant report. Dabbling around the margins is quite a different cup of tea than having to labor on a daily basis under the unrelenting pressure of too much work, too many deadlines, too few resources, conflicting guidelines, and (more frequently than outsiders realize) political pressure.

But this simple little report shows a spark of reality and measured thinking that is so often missing from auditors' efforts. The major finding is unsurprising, almost to the point of being mundane:

USCIS [U.S. Citizenship and Immigration Services, the agency within DHS responsible for adjudicating applications for immigration and naturalization benefits] regularly posts information on its website about the time it takes field offices to adjudicate green card applications (processing time). Yet, the information is unclear and not helpful to USCIS' customers because it does not reflect the actual amount of time it takes field offices, on average, to complete green card applications. In addition, the actual average time it takes USCIS to complete green card applications has lengthened, and USCIS is not meeting its goal of adjudicating applications in 120 days. [Emphasis added.]

The welcome surprise comes in the OIG's conclusion:

[G]reen cards are the gateway to citizenship. Therefore, the integrity of the citizenship process depends on careful adjudication of green card applications. Given their responsibility and the consequences of their decisions, ISOs [immigration services officers, the officials adjudicating green card applications] should continue to be given time to thoroughly vet applicants, especially if adjudicating green card applications becomes more complex. With the number of factors outside of USCIS' control that can lengthen the adjudication process, as well as the ongoing need to fully vet green card applicants, the 120-day goal may not be realistic.

What a difference 15 months can make! There isn't a scintilla of doubt in my mind that in the Obama administration, the OIG would never have recommended that USCIS adjust its 120-day completion goal farther out to accord with reality.

What's more, USCIS would never have accepted such a recommendation, but instead would have just forced adjudicators to cut corners and meet the goal without regard to the quality of the decision, in keeping with its relentless focus on approvals and quantity rather than quality — often enough with disastrous results (see, e.g., here, here, and here).

This report is no doubt a disappointment to Sen. Claire McCaskill (D-Mo.), who initiated the audit with a formal request to the OIG, apparently because she was disturbed by the inability of adjudicators in St. Louis and elsewhere in Missouri to hew to the unrealistic completion standards imposed on USCIC officers under the prior administration. NumbersUSA accords McCaskill an immigration grade score of "F" based on her complete disregard for immigration enforcement and control efforts of any sort. It's not much of a stretch to imagine that she had hoped to use the outcome of such an audit to bludgeon USCIS officials, especially those in her home state, into doing more with less until, voila!, they would be doing everything with nothing — which is an easy enough proposition if one eliminates the need to actually examine an application or petition to determine the bona fides of the alien applying.

For once, common sense — not to mention an acknowledgement of the primacy of national security and public safety in benefits decision-making — has prevailed.

It would be nice to think that, with the department's renewed emphasis on both intra- and inter-agency strategic thinking, the DHS Policy Office would go the next step and direct USCIS to reassess all of its completion goals across the entire range of applications and petitions, because there is little reason to think that the finding and conclusion aired by the OIG in this report would be any different for any of the others.