By Michael T. Dougherty

It is an open question whether Congress will address comprehensive immigration reform legislation this year or find time to work on smaller immigration packages such as the DREAM Act or AgJOBS. If any legislation includes a pathway to citizenship for some or all the 10.8 million illegal immigrants that the Department of Homeland Security estimates reside in the United States, Congress should ensure that U.S. Citizenship and Immigration Services, the DHS agency responsible for administering immigration benefits and services, has the resources that it needs to promptly and accurately enroll that population.

In the enrollment, USCIS would be required to oversee the intake of immigrant applications and fees, collect biometrics, perform background security checks, conduct interviews, adjudicate applications, and issue identification cards – all while staying current with its existing caseload, which is both demanding and diverse.

USCIS has not experienced an enrollment event of comparable size – the nearest would be the surge of applications and petitions that occurred in the summer of 2007, when USCIS received around 3 million filings prompted by an increase in fees, the availability of employment-based visas, naturalization drives and perceptions that immigration enforcement would increase.

USCIS is not alone in facing the prospect of administering a large enrollment program.  Other federal agencies have done the same, as have government agencies and ministries around the world. Perhaps none is as ambitious as the Indian government’s plan to issue unique identity numbers to 600 million residents by 2014 to better track and control the distribution of government benefits.

To understand enrollment dynamics, Raytheon Homeland Security studied reports and materials on 10 domestic enrollment programs occurring in the last 25 years.

We took away numerous lessons from our review. While different agencies administering different programs face distinctive challenges, they usually share several pressure points, including the need to speedily deliver benefits, documents, or other items of value to a very large number of people whose identity and eligibility must be accurately assessed; this while facing significant political scrutiny and heightened public expectations. On this last point, it should be remembered that individuals involved in an enrollment – whether hurricane victims, people needing credentials for work or travel or those seeking to adjust immigration status – are often experiencing their own set of pressures and anxieties. They understandably expect and need rapid results from government. With so much on the line, enrollments events can make or break an agency’s reputation.

Our review shows that there is no substitute for comprehensive planning. Agencies that have undertaken a rigorous and honest assessment of their own capabilities are best positioned to know what they need to maintain the integrity of the program without losing momentum. Modeling and simulation (M&S) tools can provide agency leaders with an objective means of measuring the readiness of the agency’s enterprise. This in turn helps them objectify acquisition requests and defend policy choices.
M&S also socializes frequently overlooked voices from field personnel – it is not always true that agency leaders access or understand what passes as common knowledge to line staff in operations. M&S helps build consensus among managers, protecting against stalls or reverses in program planning. If a model is properly framed and updated, it will remain a durable planning tool throughout an enrollment surge. It may also function as a tool for gathering metrics to accurately and rapidly report to executive and political leaders.

Immigration reform poses many difficult issues for Congress. One primary issue needing resolution will be the determination of how to provide resources to USCIS (which gets most of its budget through fee collections) in advance of the enrollment event so that USCIS can rapidly expand operations to meet the surge of applications sure to come.

Michael Dougherty, Director of Immigration Control with Raytheon Homeland Security, is the former Citizenship and Immigration Services Ombudsman at the Department of Homeland Security.