Cite as "AILA InfoNet Doc. No. 03090540 (posted Sep. 5, 2003)"
September 4, 2003
The Honorable Tom Ridge
U.S. Department of Homeland
Washington, D.C. 20528
The Honorable Eduardo Aguirre, Jr.
Bureau of Citizenship and
Department of Homeland Security
425 Eye St.
Washington, DC 20536
Dear Messrs. Ridge and Aguirre:
The undersigned organizations strongly urge you not to outsource the BCIS
Immigration Information Officer (IIO) function. To do so would raise
serious issues of sufficiency of knowledge, accountability, and efficiency.
Clearly, the problem-laden immigration benefits system is badly in need of
change. However, outsourcing IIOs will only worsen the situation for individual
applicants and ultimately affect the public accountability of BCIS.
Instead, we urge you to review the information function’s internal structure and
resource allocation, rather than take the seemingly easy, but ultimately
harmful, step of outsourcing this key operation.
Problems with Contractors: Two examples of the current use of
outside contractors bode ill for expanding this practice to the IIO
function. First, service centers now use contractors to provide intake of
filings. Contracting out this function has led to filings being rejected
because contractors do not understand immigration rules, erroneous entry of data
because the contractors do not understand the nature of what is being
entered—data that then haunts the case throughout the process, and separation or
removal of documents in the mail room because the contractors do not understand
the nature of the documents.
Recent experience with the BCIS’ National Customer Service Center (NCSC)
offers another example of the negative impacts of contracting out immigration
functions, and the differences that result from using an outside contractor
rather than a trained BCIS employee. Until just a few months ago, BCIS-employed
IIOs at the service centers handled inquiries about problems encountered with
individual cases. In June, all such telephone access was cut off, with all
inquirers instructed to call the NCSC’s 800 number. The contrast has been
profound, with resulting problems ranging from the frustrating and time-wasting
to truly damaging errors. Before the June changeover, IIOs readily solved
the majority of these problems. Operators who now answer the calls know nothing
about the subject of the call and rarely provide assistance. These
operators work from scripts, frequently cannot even identify which script they
should be using, and are rarely able to provide meaningful assistance. In fact,
they often provide answers that convey a clear misunderstanding of the subject
matter with which they are dealing.
Knowledge: Because the vast majority of those who
file applications with BCIS are unrepresented, most must find their own way
through an astonishingly complex system, with their first, and often only,
contact being the Information Officer who provides them with the appropriate
forms and advice on how to navigate the process. These officers are
trained in immigration, and are supported by others who provide information when
needed. In contrast, in those instances in which INS/BCIS has used
contractors, they have received inadequate training or, perhaps more
importantly, lack substantive back-up and support. While direct employees,
like everyone, also can make errors, the volume and severity of the errors tend
to be lower when the employee is trained and supervised by persons with
knowledge in the field.
Knowledge of immigration is important: even determining what form to dispense
involves understanding the person’s immigration situation and what is needed to
resolve the situation. This knowledge cannot be taught through lists and
scripts: officers must understand the myriad of situations with which they
are daily presented, and have a line of command that can help resolve the
People’s lives depend on accurate information from government agencies,
especially when immigration is involved. Using a contractor for the very
function by which this information is disseminated will affect BCIS’ credibility
in all reaches of this society.
Accountability: Contracted personnel do not possess this knowledge.
Nor, given past practice, will they be held accountable for the quality of their
work. Rather, they will be held accountable only for the number of inquiries
answered each day. Currently, because service center intake contractors do not
report to the service center managers, the BCIS managers are unable to direct
the contractors’ day-to-day work, and the contractors’ managers have no
immigration background. The result is that contractors are accountable to BCIS
management only for production output quotas, and not for work content.
Such a situation is irrational when the very essence of the job is the subject
matter of the agency.
This lack of accountability has created enough problems with work that does
not require immigration knowledge: opening mail and inputting initial data at
the service centers, the work of the current contractors. By contrast, IIO
work involves almost 100% knowledge of immigration.
Again, we have already seen this problem manifested in the 800 number.
Many callers are abruptly cut short or hung up on before their problem can be
addressed, undoubtedly because operators are more concerned with meeting
production quotas, the area for which they are held accountable, than with
providing accurate information -- an area for which it is nearly impossible to
make an outside contractor accountable.
Efficiency And Cost Savings: Past use of outsourcing immigration
service functions has not led to efficiencies or cost savings because service
centers have had to respond to contractors’ errors in inputting data by
requiring their own employees to check their work and, in many instances, re-do
it. Because employees with the requisite knowledge and accountability have
had to perform part of the contractor’s work, a significant proportion of the
anticipated savings from using contractors has been lost because direct
employees have had to “shadow” that work. Such shadowing often has not reflected
in the studies of cost savings from outsourcing, yet reflects a significant
Outsourcing is not the solution: Much needs to be done to improve
the BCIS’ customer service operation, but the use of outsourcing is plainly not
the solution. As noted above, we urge you to look at the internal
structure and resource allocation for the information function.
American-Arab Anti-Discrimination Committee (ADC)
American Friends Service
American Immigration Lawyers Association
Asian Law Caucus
Episcopal Migration Ministries
Immigrant Aid Society (HIAS)
Immigrant Legal Resource Center
and Refugee Services of America/U.S. Committee for Refugees
League of United
Latin American Citizens (LULAC)
Lesbian and Gay Immigration Rights Task
Lutheran Immigration and Refugee Service (LIRS)
Pacific American Legal Consortium
National Council of La Raza
United Jewish Communities
Alivio Medical Center (Chicago, IL)
Arab-American Family Support Center,
Inc. (Brooklyn, NY)
Arab Community Center for Economic & Social Services
(ACCESS) (Dearborn, MI)
Asian Pacific American Legal Center of Southern
Association of the Jews from the FSU (Milwaukee, WI)
Immigrant Center (Allston, MA)
Center for Hispanic Policy & Advocacy,
CHisPA (Providence, RI)
Centro Presente, Inc. (Cambridge, MA)
Salvadoreno (Hempstead, NY)
Florida Immigrant Advocacy Center, Inc. (Miami,
Hispanic Chamber of Commerce of Minnesota
(Mecklenburg County, NC)
Illinois Coalition for Immigrant and Refugee Rights
Immigrant Rights Network of Iowa and Nebraska
Monitoring Board (Chicago, IL)
International Institute of New Jersey (Jersey
Jewish Family Services (Milwaukee, WI)
La Esperanza, Inc.
Labor Council for Latin American Advancement, Massachusetts
Latin American Community Center (Wilmington, DE)
Massachusetts Immigrant and Refugee Advocacy Coalition
Massachusetts Law Reform Institute (Boston, MA)
Council (Milwaukee, WI)
Na Loio - Immigrant Rights and Public Interest Legal
Center (Honolulu, HI)
Nebraska Mexican American Commission (Lincoln,
Nevada Hispanic Services, Inc.
New Immigrant Community Empowerment
(NICE) (Jackson Heights, NY)
Northwest Immigrant Rights Project
HISPANO (Alexandria, VA)
Rhode Island Coalition for Immigrants and
St Francis House (Boston, MA)
Shorefront YM-YWHA of
Brighton-Manhattan Beach, Inc. (Brooklyn, NY)
Southeast Asian Mutual
Assistance Associations Coalition (Philadelphia, PA)
Southwest Iowa Latino
Resource Center (Red Oak, IA)
Voces de la Frontera: Workers Center
Washington Defender Association's Immigration Project