9/11 Personal Privacy

/K/S
Prepared by: Danielle Giese Index: Type bundle index here
Date Prepared: 3/14/03 DOC Number: 845755
Reviewed by: Type reviewer name here DOC Library: GAOHQ
Job Code:130162

Record of Interview
Title Interview about NIIS
Purpose To obtain an overview of the purpose and operations of NIIS
and the limitation of its data
Contact Method Telephone Interview
Contact Place N/A
Contact Date 3/5/03\s
Thomas Andreotta, Assistant Chief Inspector
Department of Homeland Security
Bureau of Citizenship and Immigration Services
425 I Street, NW
Washington, DC
Phone:

GAP
Danielle Giese, Analyst
Comments/Remarks:
I introduced our engagement to Mr. Andreotta and asked him to provide some information about
the purpose and operations of the Nonimmigrant Information System and the limitations of the
data from this system. Mr. Andreotta provided the following.

Overview
The Nonimmigrant Information System (NIIS) was established in January 1983 to collect
information about the arrivals and departures of nonimmigrants. The data that this system
maintains is from the 1-94 form, the Arrival/Departure Record. Upon arrival, a section of this form\s comp

the point of entry (POE), e.g. airportXHIjMMi^itoVy and is review along with other necessary
documents for entry such as passports and visas. The inspector fills out the remaining information
needed for official purposes, such as the type of visa and length of allowed stay, allows the
nonimmigrant to enter (if appropriate), gives the a detached portion of this form to the immigrant
and keeps the arrival information. The arrival section of the form is sent to contractors who
manually input the 1-94 information into NIIS. The detached portion of the form is known as a
"departure coupon" which is kept by the nonimmigrant until he/she leaves the country. Just before
a nonimmigrant leaves the U.S., the departure coupon is given to the transportation carrier or the
immigration officer at a POE and submitted to the contractor in order for them to match the
departure information with the arrival record. Mr. Andreotta stated that, although the Bureau of
Citizenship and Immigration Services (BCIS) plans to discontinue using NIIS in the next 4-6 years,
the agency does not plan to change the operations of this system while it continues to exist. A
nonimmigrant with a visa that allow him/her to leave and reenter freely, such as H-1B workers, will
have completed multiple I-94s and have multiple arrival/departure records.

Pagel Record of Interview

Prepared by: Danielle Giese Index: Type bundle index here
Date Prepared: 3/14/03 DOC Number: 845755
Reviewed by: Type reviewer name here DOC Library: GAOHQ
Job Code: 130162

A 14 Day Lag Time Exist Before Arrival/ Departure Data is Processed

Mr. Andreotta stated that among the limitations of the data in NIIS is that it does not record
arrivals/departures in real time; BCIS' current processes take 14 days before an arrival is recorded
in NIIS. Mr. Andreotta stated that this processing time is an improvement over what it was 6
months ago at 30 days. He also stated that the NIIS administrators are continuing to take efforts to
shorten this lag. Currently, they are trying to get the 1-94 to the contractors more quickly from four
of the airports that produce 40% of the 1-94 workload, and in the future, they hope to improve the
computer uploading speed.

Arrival Information is Believed to be Incomplete Often

Mr. Andreotta believes that another data limitation is that arrival information is often incomplete.
Among the lacking information is U.S. addresses and correctly spelled names. He believes that
addresses are missing simply because nonimmigrants do not report them or only report parts of
them on their I-94s. Name misspellings occur because those who input the data have a difficult
time reading some people's handwriting. The only way that NIIS computer administrators become
aware of name misspellings is when they are contacted the Social Security Administration (SSA).
SSA uses NIIS data that is uploaded to the Alien Status Verification Index (ASVI) to ensure that
nonimmigrants who are applying for Social Security numbers are giving them the correct
documents related to work authorization. If someone's name in ASVI does not match their paper
documentation, SSA will not issue a number and will ask NIIS administrators to review paper
documentation to ensure the proper name spelling in ASVI.

Not All Departure Coupons are Collected

Regarding departure data, Mr. Andreotta stated that a significant number of arrival records are
missing departure records. He attributes this to a lack of departure coupon collection that
occurred for a variety of reasons, such as overstaying allowed time, a visa status that allowed the
person to stay for multiple years and a change of visa status or citizenship that allowed a person to
stay longer that originally allowed. In addition, Mr. Andreotta stated that Canada immigration
inspectors collect departure coupons if they see them, but they are not required to do this.
Therefore, if a nonimmigrant left through-a land border and the inspector did not collect the
departure coupon, a departure record will be missing in NIIS for that person.

The Entry Exit Program Will Address Arrival and Departure Information Issues
Mr. Andreotta believes that the planned Entry Exit System will address the issues that currently
exist with collecting arrival and departure information. Among of the greatest changes that those
developing the system will face are implementing the system at the 355 POEs and having
documentation that is as reliable (or more reliable), portable and flexible as the current paper I-
94s. {Auditor's Note: When I asked Mr. Andreotta about what immediate efforts were in place to
improve data quality, he only mentioned getting the arrival information inputted more quickly.)

Page 2 Record of Interview

I;Katherine Brentzel -_Re:JNTE_RVIEW ABOUT NIIS __ __ Page 1

From: Barbara A Guffy

To: Brentzel, Katherine; Giese, Danielle
Date: 4/4/03 2:OOPM
Subject: Re: INTERVIEW ABOUT NIIS

Danielle,

Thanks for the ROI, I think it will be very useful to us. Unfortunately, I haven't documented my discussion
with Tom yet (we're trying to get the first draft of the report out), but I just wanted to highlight a few details
that Tom mentioned to me:

--He's implemented his satellite scanning process at two of the four airports-Miami and Los Angeles. He
also plans to deploy it at Kennedy and San Francisco. However, it is too expensive a system to establish
at all airports, and certainly at the land POEs. Tom hopes to deploy the less expensive table-top version
sometime in FY2004. (I didn't get too many details on what the table-top version would entail. Apparently
it is basically a "turn key" version of the satellite scanning process.)

--Tom thought the new satellite scanning process now at Miami and LA does help to improve data quality.
Under this process, the contractor is on site to pick up the l-94s almost as soon as they're completed;
thus, s/he can spot problems and immediately follow up with the inspector about omitted data or apparent
errors.

-land POEs can implement automated programs that might improve data quality-for example, El Paso
POE has a program that allows information scanned by the document readers to be automatically loaded
into an electronic form 1-94, leaving the inspector to type in the U.S. address information. Unfortunately, it
is impossible for the POEs to send the data directly to NIIS; because of limitations w/ the system
architecture, data must always be keyed in.

Not much, but it might help. If you have questions, please give me a call I I.

Barbara i

>» Danielle Giese 04/04/03 09:30AM >» !

Kate, |

Here is a opy of our interview with Tom Andreotta. Sorry it's not reviewed yet; I will send you another copy
when it is. He basically said that it takes two weeks to process the l-94s, which is an improvement over
what it was before at 30 days. Unfortunately, I don't have have procedures or policy documents related to
this. I hope this helpful. |

--Danielle i

CC: Dino, Michael P; Peguero, Eileen; Weiss, Lori A; Wysocki, Anthony !

9/11 Personal
Privacy