Utilizing and Visualizing Geolocation Data for Powerful Analysis

Comprehensive Immigration Reform
Transforming the U.S. Immigration System
Comprehensive Immigration Reform
Transforming the U.S. Immigration System
Proposed comprehensive immigration reform will require
federal, state, and local agencies to assess the impact of
proposed statutory changes on existing programs and the
potential need for new programs. Affected agencies will
include those with primary responsibility for immigration,
border security, and law enforcement and will also extend to
agencies that provide services and benefits to populations
that may increase as a result of the legislation. In fact, it is
difficult to imagine an agency that will be not be affected by
immigration reform. Even though the legislation is not final,
agencies need to consider the possible effects of proposed
reform provisions and prepare for the transformational
change to the nation’s immigration system. As a long-time
partner with the agencies that manage the immigration
system and border security, Booz Allen Hamilton has
observed first-hand the many challenges federal officials
face accomplishing their mission in this highly complex
area and is prepared to collaborate, partner, and consult on
the way ahead.
The immigration system includes the laws, regulations,
policies, and procedures that govern the movement
of foreign nationals into and out of the country by
which the United States meets its responsibility as
a sovereign nation. It also includes the capabilities,
competencies, and capacity of each agency that in
aggregate enable the implementation of policy and the
enforcement of laws. This system necessarily interacts
with and impacts all elements of national power
and a broad range of stakeholders, including foreign
governments, domestic large and small-business
owners, foreign students, local government officials,
the private sector, and immigration advocacy groups.
In recent years at the request of our federal
partners, Booz Allen has initiated numerous studies
and engaged experts with government and private
sector experience to glean lessons from the past
and develop innovative solutions for addressing our
nation’s immigration challenges. Upon reflection of
the challenges that comprehensive reform will pose,
implementing reform legislation will likely entail: (1)
understanding and learning the important lessons of
past reform efforts, (2) confronting and solving the
difficult execution of mandates related to migrant labor,
entry and exit, legalization, and internal enforcement,
(3) applying the advantages of new technology and
solutions unavailable to earlier undertakings, and (4)
creating a community approach to implementation. This
paper presents the results of that collective reflection
upon how best to implement immigration reform.
The Impetus for Reform
Today’s immigration system is confronted by serious
challenges. The Departments of Homeland Security
(DHS) and State struggle to keep pace with the
demands of managing the millions of foreign nationals
who legally arrive in the United States for work, study,
travel, and legal immigration. Meanwhile, the problem
of resolving legal status for the estimated 11 million
immigrants who illegally reside in the United States
looms over the nation (see Exhibit 1 on page 2).1 In
addition, discussions on immigration reform over the
past decade have taken place in the context of the
terrorist attacks of September 11 and associated
issues related to border security and a continually
evolving and complex threat environment. The current
discussion regarding immigration reform has generally
centered on three basic elements:
1. The strengthening of border and interior
enforcement to ensure immigration laws are fairly
and effectively executed;
2. The creation of a pathway to legal residency for
qualified foreign nationals living illegally in the
United States;
1 Pew Research Center, http://www.pewhispanic.org/2012/12/06/unauthorized-immigrants11-1-million-in-2011/
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3. The development and implementation of policies
and procedures that more effectively support
U.S. economic interests regarding seasonal
and temporary workers, foreign students, and
intellectual capital.
Any or all of these principles will likely be addressed
in a final legislative package. Achieving the goals of
comprehensive immigration reform legislation will be a
complex, transformational undertaking. Once legislation
is enacted, the challenges of implementation will be
significant, demanding an “enterprise” or “community”
approach that includes a complex network of federal
departments, agencies, and programs involved in
these elements. However, it is a mistake to think of
this reform effort as simply an issue of scale—that
is, more enforcement, more legalizations, more visas.
The implementation of effective reform follows a life
cycle starting with reimagining agencies’ individual
and collective missions and ending with the execution
of programs and activities that are sustainable…that
“stick.” Given the anticipated impact of proposals
already under discussion, it is clear that agencies
will have to make fundamental changes to their
organizations’ processes and procedures to deliver
real reform.
Building the Foundation for Reform
Successful immigration reform implementation
will depend in part on the government’s ability to
understand the lessons learned from previous reform
efforts and apply them to the challenges posed by
the new reform legislation. Immigration reform efforts
are not new to the United States. Since the post-war
era alone, the United States has seen eight major
legislative actions or modifications to the immigration
system, complemented by dozens of executive orders
or policy adjustments. Most informative to current
reform, in 1986 Congress passed the Immigration
Reform and Control Act (IRCA), and in June 2012,
the Obama Administration enacted the Deferred
Action for Childhood Arrivals (DACA) policy through
executive order.
The lessons learned from previous legislation and
policy efforts should inform strategies for future
implementation. Key lessons from IRCA include:
Number of Unauthorized Immigrants
Exhibit 1 | Estimated Annual Unauthorized Immigrant Population in the United States: 1990 to 2010
12,000,000
9,000,000
6,000,000
3,000,000
0
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
Year
Source: Unauthorized Immigration to the United States: Annual Estimates and Components of Change, by State, 1990 to 2010. Robert Warren, John Robert Warren. International Migration Review,
Volume 47 Number 2 (Summer 2013)
2
• IRCA was not comprehensive in its handling of the
illegal population. Critics deemed IRCA’s legalization
program not inclusive enough, offering legal status
only to those who had been “continually present”
in the United States for five years prior to the law.
While IRCA offered legal status to three million
people, it failed to address nearly two million
people who remained in an unlawful status, making
them more susceptible to marginalization and
exploitation.2 This population became the core of
the current illegal population in the United States
as individuals continued to migrate to join family
members already living illegally in the United States.
As a result, an imbalance was created between the
illegally present population and resources available
for border and interior enforcement (see Exhibit 2).
• IRCA failed to develop and staff programs to
deal with follow-on legal migration. Relatives
of immigrants legalized under IRCA applied for
immigration benefits in far greater numbers than
anticipated, creating visa backlogs that persist
today. Effective reforms are addressed over the
expected life cycle of implementation.
• Employers and the government had difficulty verifying
worker status. Neither side had the resources or
tools to verify workers’ identities in a systematic
way.3 Effective worksite enforcement requires
accurate and timely employment authorization data
to be available to all employers. It is likely that
mandatory identity verification will be included in any
reform legislation in addition to improved biometrics.
Exhibit 2 | Immigration Facts and Figures
About the Population
• Foreign Born Population (who entered after
1979)—31 million4
• Legally Resident Immigrant Population (as of January 1,
2011)—22 million4
• Unauthorized Population (as of January 1,
2011)—12 million4
About Benefits
• Adjustment of Status (I-485) Applications Received in
2012—300,0005
• Academic Student (F1) Visas Issued in 2012—2 million6
• Naturalizations in 2011—700,0007
About Enforcement
• Individuals Removed by U.S. Immigration and Customs
Enforcement (ICE) in FY2012—400,0008
• Apprehensions by U.S. Border Patrol in FY2012—400,0009
2 Demetrios G. Papademetriou, “The Fundamentals of Immigration Reform," The American
Prospect, Volume 24, Number 2. http://prospect.org/article/fundamentals-immigration-reform
3 Ibid.
4 Estimates of the Unauthorized Immigrant Population Residing in the United States, January
2011. http://www.dhs.gov/xlibrary/assets/statistics/publications/ois_ill_pe_2011.pdf
5 USCIS Adjustment of Status Form I-485 Performance Data (FY2010 - October FY2013).
http://www.uscis.gov/USCIS/Resources/Reports%20and%20Studies/Immigration%20
Forms%20Data/Adjustment%20of%20Status/I485-performancedata-2013-Oct.pdf
3
6 Nonimmigrant Admissions to the United States, 2011. http://www.dhs.gov/xlibrary/assets/
statistics/publications/ni_fr_2011.pdf
7 U.S. Naturalizations, 2011. http://www.dhs.gov/xlibrary/assets/statistics/publications/
natz_fr_2011.pdf
8 http://www.ice.gov/removal-statistics/
9 http://www.cbp.gov/xp/cgov/border_security/border_patrol/usbp_statistics/
• Enforcement elements of IRCA fell far short of need.
The border control and interior enforcement efforts
of the Immigration and Naturalization Service (INS)
did not ramp up until years after IRCA passed—a
critical lapse that affected all components of IRCA’s
implementation, yielding a larger unauthorized
population today and delays in processing, as the
system was simply overrun. Border and interior
enforcement agencies are united in a single
department and are staffed at far higher levels
today than in 1986. Yet work remains to re-imagine
the border and internal enforcement and integrate
the law enforcement effort through improved
information sharing.
The recent DACA implementation also provides
valuable insight into the programs and processes that
may be employed under proposed legislation. While
some may see the DACA application process as a pilot
program for registration of unauthorized non-citizens
applying for a path to citizenship, a comprehensive
approach should build on the lessons of the DACA
experience and modify the process as appropriate for
this new applicant pool and demographic. Some first
impressions from DACA include:
• United States Citizenship and Immigration Services
(USCIS) had minimal preparation time to implement
the program but incorporated a flexible approach.
USCIS had a limited timeline to prepare for DACA
application processing and since the launch of
the program has been continuously improving
the processes to best meet program needs.
This suggests USCIS can develop a legalization
program on a quick timeline but should be given
significant time to prepare for the much larger
unauthorized population.
• The loudest critics of the DACA program focus on
concerns around fraud, particularly as it relates to an
applicant’s income claims. The income reporting that
is required to justify an applicant’s standing for legal
work is also a basis for potential tax liability. A clear,
understandable process that meets the evidentiary
requirements for employment and minimizes the
opportunity for fraudulent claims is needed.
• Applicants have expressed different concerns
including the application fee (which cannot be
waived), inconsistent or changing documentation
requirements, and the inability to appeal applications.
Fees, penalties, or fines required or imposed will
be determined in legislation and may limit agency
discretion to adapt to demand. The fee-for-service
model that currently funds legal immigration is
unlikely to be altered in legislation. Agencies will
need to prepare for and monitor these concerns
throughout the implementation of the program
through active change management. Direct and
effective communication as part of an enterprise
outreach plan will be critical.
The Challenges of Implementing Reform
Based on the United States’ previous immigration
reform experiences, current political debate, and
congressional action to date, comprehensive
immigration reform will likely create three broad
implementation challenges for federal agencies, as
discussed earlier:
1. Development and implementation of a system
to evaluate and process registered provisional
immigrants;
2. Establishment of a framework to strengthen border
and interior enforcement;
3. Creation of a flexible strategy for anticipating
future migration demand as well as life cycle
implementation and execution of reform.
While Congress will prioritize, authorize, and
appropriate funds, as well as broadly direct how these
challenges will be met, federal agencies will be tasked
with, and held accountable for, effectively implementing
the provisions of the legislation. There will also be
an expectation in the current fiscal environment that
agencies will demonstrate flexibility with existing
funding and improve the effectiveness and efficiency of
existing programs. Gaining a thorough understanding
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of the potential implementation challenges will enable
agencies to address and overcome certain hurdles to
meet the collective goals of immigration reform.
The queue of registered provisional immigrants must
be established, managed, and monitored
Any immigration reform proposal that includes a
legalization program will begin with a line of legal, or
registered, prospective immigrants to be processed
for a status change. The first step will likely be akin
to the DACA application process with an application,
relevant supporting documentation, and a processing
fee. The major challenge for the government lies
in communicating effectively with the millions of
individuals who will be eligible for a status change.
Mobilizing qualified individuals to come out of the
shadows and interact with the federal government will
require a community engagement strategy to deliver
the right message, in the right way, to the right people.
Given previous rollouts of reform, the timeline for
developing and delivering a communications approach
will be limited. The 1986 IRCA implementation was
criticized for the INS’s weak outreach as well as the
short timeframe allowed for education of immigrant
groups on IRCA’s legalization programs.10 Seeking
buy-in and assistance from immigrant community
organizations early on will aid in ensuring illegal
immigrants properly register and begin the process of
qualifying for legal residency. In addition, incorporating
new technology including social networking into
community engagement strategies will enable agencies
to reach a variety of eligible applicants in ways that
were unavailable during IRCA implementation.
Second, the government will need to effectively deploy a
broad range of application methods—such as Internetbased, paper applications, third-party assisted—to
reach the greatest possible number of eligible
applicants. As with the communications approach,
this will require a multifaceted application process
that accommodates eligible applicants’ situations. A
preferred comprehensive immigration reform scenario
would allow applicants to apply electronically or
10 Juffras, RAND, Impact of the Immigration Reform and Control Act on the Immigration and
Naturalization Service, 1991
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using a paper application, as many applicants may
have institutional, structural, or economic barriers
to electronic-only applications. Regardless of how
applicants apply, a diversified enterprise must collect
or ingest relevant information within an effective case
management system. The system, most likely the USCIS
Electronic Immigration System (ELIS) system or close
variant, should allow for individuals to complete their
initial application and track their status throughout
the process.
Third, beyond the initial application process, federal
agencies will need systems to collect and share
pertinent information throughout an eligible person’s
legal status review across the government enterprise.
During IRCA implementation, applicants appeared
for two in-person interviews with numerous INS
officers before a final adjudication.11 Given today’s
national security concerns and the larger illegal
immigrant population, comprehensive immigration
reform implementation will have to take an innovative
approach to addressing this challenge. USCIS has
made some progress in this area, including the use
of service centers and the development of the Fraud
Detection and National Security (FDNS) directorate, but
more will need to be done. Using the right technology,
including the use of biometric information and cloud
data architectures that enable interoperability, ensures
successful tracking of individuals and cases as well
as screening for those individuals who pose threats
to public safety and national security. This instant
information sharing will help verify new data with
information previously collected by federal agencies
and diminish the risk of fraud. Building more of these
capabilities into the front end of the systems will avoid
many of the long-term challenges faced since IRCA was
passed in 1986 IRCA. Current efforts to consolidate
information technology (IT) systems, exchange data in
cloud architectures, and create a new generation of
analytical capabilities will need to be sustained and, in
most cases, accelerated.
11 Migration Policy Institute, November 2010 Policy Brief: Structuring and Implementing
an Immigrant Legalization Program: Registration as the First Step, Donald M. Kerwin and
Laureen Laglagaron
An Experienced Partner
Booz Allen supports reform initiatives across the
government:
• Immigration Reform: Booz Allen has supported
DHS components including U.S. Immigration and
Customs Enforcement (ICE), U.S. Customs and
Border Protection (CBP), and U.S. Citizenship
and Immigration Services (USCIS) through
modifications of the immigration system and
in determining the impact of comprehensive
immigration reform on the agencies. Booz Allen,
while supporting ICE, won the Institute for
Operations Research and the Management
Sciences’ (INFORMS) inaugural Innovation in
Analytics Award for the project, “Enhancing
Immigration Enforcement with Decision
Analytics.” Additionally, Booz Allen supports
many of the non-DHS agencies likely affected by
comprehensive immigration reform, including the
Departments of State, Labor, Justice, Health and
Human Services, as well as the Social Security
Administration and the Internal Revenue Service.
• Financial Reform. Booz Allen helped our
clients assess the implications of the DoddFrank legislation on their mission. We helped
our clients address the varying degrees of
change wrought by the new law, from standing
up an entire bureau at the Consumer Financial
Protection Bureau (CFPB), to working to
operationalize newly created offices such as the
Office of Complex Financial Institutions at the
Federal Deposit Insurance Corporation (FDIC)
and the Office of Financial Research at Treasury,
to operations redesign across multiple offices
and divisions within the Securities and Exchange
Commission (SEC).
• Health Care Reform. The Patient Protection
and Affordable Care Act (ACA) enacted in March
2010 denotes significant reform to the U.S.
healthcare market by expanding access to
affordable health insurance and establishing
new rules and regulations for healthcare
delivery. Booz Allen is actively supporting
multiple clients tasked with the implementation
and coordination of several key provisions
across the Center for Consumer Information
and Insurance Oversight (CCIIO), a part of the
Centers for Medicare & Medicaid Services
(CMS) and the Internal Revenue Service (IRS).
Working on 13 projects within those agencies
responsible for reform implementation, Booz
Allen provides an array of services, including
strategic planning, stakeholder engagement,
communications, change management,
governance/oversight, performance
management, policy analysis, process and
procedure development, organizational design,
risk management, and transition planning.
• Cyber Security. Booz Allen provides ongoing
implementation support for President Obama’s
Executive Order on “Improving Critical
Infrastructure Cybersecurity,” including advising
on strategic risk management activities. Further,
Booz Allen works with clients to develop and
promote partnerships with public and private
sector entities to further the advancement of
cyber security. Booz Allen also supports the
national “Stop.Think.Connect.” campaign to
educate the public about being more secure
online and the DHS Cyber Education Office to
enhance education and workforce development
in cyber security.
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Border and interior enforcement must address
national security and public safety concerns
Significant challenges will remain to ensure rigorous
enforcement both during and after reform. Following
any form of comprehensive immigration reform
legislation, individuals will still attempt to cross the
border illegally, overstay a visa, and illegally obtain
work. Many are concerned that comprehensive
immigration reform will produce a surge in illegal
immigration, similar to that experienced in the years
following the passage of IRCA in 1986. As the current
number of illegal immigrants is estimated at more than
11 million people, it is clear that tougher enforcement,
particularly employer sanctions, enacted as part of
IRCA, did not stop illegal immigration in the long term.
The illegal immigrant population increased from 3.2
million in 1986 to 12.4 million in 2007 before dipping
down to 11.1 million in 2011.12
One major challenge that will accompany any reform
effort is balancing border and interior enforcement
with the deployment of legalization programs. During
implementation, the middle ground between strong
enforcement and legalization of individuals must be
realized. Maintaining this balance will be difficult
but necessary to ensure that larger investments
can be made in the programs that best support
the overarching reform agenda. Agencies must
have the optimized infrastructure, processes, and
resources in place to continue enforcement after
legalization programs are initiated. As previously
noted, the creation of DHS in 2003 was intended
to remove organizational barriers to more effective
border security. Resources on the border have grown
significantly. There were nearly 400,000 U.S. Border
Patrol apprehensions in fiscal year (FY) 2012. If
population flows to the United States following the
passage of legislation mimic the behavior observed in
1986, U.S. Customs and Border Protection (CBP) can
expect as much as 35 percent more apprehensions
in the wake of comprehensive immigration reform.13
Smarter, tougher border security and interior
enforcement led through a DHS enterprise approach to
re-imagining its missions coupled with a less circuitous
12 Ruth Ellen Wasem, Congressional Research Service, Unauthorized Aliens Residing in the
United States: Estimates Since 1986, December 13, 2012
13 http://www.cbp.gov/xp/cgov/border_security/border_patrol/usbp_statistics/
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path to legal status can decrease the incentives to
migrate illegally.
Another key challenge is effective interior enforcement for
those individuals who already crossed the border (legally
or illegally) and reside within the United States. U.S.
Immigration and Customs Enforcement (ICE) has realized
effective enforcement through lead-generating systems
that target criminals (such as Secure Communities),
but programs must continue to focus on worksite
enforcement through an improved (and likely mandatory)
E-Verify program, effective visa overstay monitoring, and
the capture of exit information. E-Verify is a free, voluntary
program run by DHS that allows employers to compare
U.S. government records to a potential employee’s
Employment Eligibility Verification form to determine
if that person is eligible to work in the United States.
Enhanced mandatory E-Verify would include enrolling all
employers and potentially using biometric identification
to validate legal status. A systematic way to monitor
and enforce visa overstays must be implemented as
well. A biometric exit system would advance the Arrival
and Departure Information System (ADIS) and provide
actionable leads for visa overstays to maximize the
benefits of trade and travel while mitigating risks to public
safety and national security.
In addition, enforcement agencies must monitor those
who may violate the terms of their new status and
those who are ineligible for the registered provisional
status. Advanced information sharing (interoperability)
should be in place between government agencies
enforcing immigration laws. To do this, aging systems
must be able to communicate so that ineligible
applicants, or those who jeopardize their status, can
be efficiently identified.
A flexible strategy for responding to migration
demand must be realized and implemented
Previous immigration reform efforts failed to account
for labor needs across a continuum of skills and
industries. While immigrants comprise 13 percent of
the U.S. population, they make up 16 percent of the
workforce, a percentage that has steadily increased
since the 1970s.14 Reform legislation will likely
seek to replace existing constraints with a far more
flexible and responsive system. The government must
develop a process for effectively balancing domestic
and foreign labor supplies to guarantee U.S. global
competitiveness. This process would include three
areas: (1) defining the types and number of workers
needed; (2) communicating with industry about their
future labor needs; and (3) fairly adjudicating and
efficiently processing applications for workers.
The U.S. population is aging rapidly—in fact, between
2000 and 2010, the 45-and-older population grew
18 times faster than the population under 45.15
This aging trend underlies the need for more workers
of every education and skill level to participate
in the labor market, and providing a clear path
will facilitate this supply. Moreover, jobs heavily
composed of foreign workers and strongly affected
by the aging population, such as nursing and home
health aides, will be in growing demand in the future.
Simultaneously, established industries, including
construction, hospitality, and agriculture, as well as
emerging (or re-emerging) industries will continue to
rely on permanent and temporary foreign workers.
Understanding future labor needs and associated
fluctuations will allow the United States to adjust
immigration flows to best serve its economic needs.
Past efforts have focused on seasonal and agriculture
labor, but those labor flows have been institutionalized
in current business practices.
Establishing and maintaining clear channels to
share real-time information among industries and
businesses, labor organizations, and the government in
a consistent and meaningful way will be an important
hurdle for the government to overcome. Effective
communication among relevant stakeholders must
align to ensure that the visa supply for all types of
labor meets business demands. Streamlining the
visa application process to make it more expedient
and efficient will not only attract and retain talented
innovators but will bolster the U.S. labor force in
the future.
Finally, an improved process with a less circuitous
path for legal status for employees and their
families from abroad can decrease motivations for
illegal immigration. While current immigration law
is managed on a first-come, first served basis with
quotas for certain green card and visa categories,
family and employment-based channels for attaining
legal status in the United States are plagued with
massive backlogs and decade-long processing times.
Reform is needed to not only usher in comprehensive
immigration laws but also to fix a damaged system of
visa processing and adjudication.
Success Factors for Implementing
Immigration Reform
Booz Allen’s research and experience show that
immigration reform efforts will benefit greatly by
incorporating previous immigration reform lessons
learned, such as those discussed in this paper, with
the newly identified challenges to develop certain
capabilities. These capabilities will help government
agencies provide effective and responsive action
to participants in the immigration system. Many of
these capabilities exist to various degrees, but it
is their comprehensive and integrated application
as a government enterprise that will generate the
improvements needed to achieve the goals of
immigration reform. The following success factors are
not tied to any specific proposals under consideration
by the White House or Congress; rather, they apply
equally to all reform recommendations. Regardless
14 Singer, Brookings Institute, http://www.brookings.edu/research/papers/2012/03/15immigrant-workers-singer
15 http://www.brookings.edu/research/papers/2011/06/28-census-age-frey
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of the specific provisions that lawmakers ultimately
adopt, the likelihood of success will be significantly
increased by—and may depend upon—how well the
reformed immigration enterprise system incorporates
the following recommendations.
1. Revise the way agencies address the immigration
system
Reform will likely demand that agencies produce
more efficient outcomes for processing benefits and
enforcing immigration laws—simply adjusting capacity
in a singular way will not be enough. Viewing the
immigration system in a holistic way, influencing and
being influenced by multiple stakeholders, will enable
agencies to better prepare for sustainable results.
Agencies should establish achievable and clear goals
that incorporate success measures to which multiple
agencies and stakeholders will be held accountable.
Immigration could become the impetus or lever for
agencies to seriously respond to the current austere
fiscal environment and press for more efficiency and
effectiveness across all agency missions.
Re-Imagine the Mission
Comprehensive immigration reform provides
the chance to re-imagine organizations’
individual and collective missions. This
opportunity will enable agencies to refine
their processes and systems to meet future
mission requirements. Innovation and thinking
creatively about how the pieces will fit together
will be necessary as agencies, departments,
and partners begin to work in new ways.
One way to ensure that the operating models can
be effectively transformed in the midst of reform
is standing up a Program Management Office
(PMO) in affected agencies. A PMO would treat
comprehensive immigration reform as a complex
collection of projects across a variety of business
units. The program leader would have the benefit
9
of complete access to information across these
projects, which would allow for more complete
management of the entire process. Previous studies
show that as programs increase in complexity, the
likelihood of successful implementation declines. Two
of the leading reasons for failure are poor planning
and weak governance. A PMO provides a central
planning and a governance framework to manage
the set of projects across an integrated timeline and
budget, as will likely be stipulated by the legislation.
Consideration should be given to establishing PMOs
within agencies and at the enterprise level to ensure a
whole-of-community response.
Immigration reform legislation could alter priorities
or dramatically change mission responsibilities
for many agencies. Specifically, it provides the
opportunity to re-imagine organizations’ missions and
could result in a complete overhaul of processes,
infrastructure, and technology associated with the
current immigration system. Agencies should expand
both individual and cooperative planning efforts
to rethink the limitations of current capabilities
and enhance scenario and budget planning, policy
development, partner agency coordination, and future
need anticipation as legislation develops. Strategies
and plans will require flexibility to accommodate
changes that will come post-implementation. Effective
management and reprogramming of base resources
will become a mandate.
2. Modernize and integrate systems to support data
analytics
The immigration system currently maintains large
quantities of data across many different agencies for
a variety of purposes. During reform implementation,
agencies will collect and manage vast amounts of
information to verify identities, monitor cases, and
engage in interior and border enforcement. These
systems and technologies will need to be maintained
and coordinated across relevant agencies in order to
improve adjudication during a legalization program and
strengthen enforcement.
Find the Money by Showing the Value
In these challenging budgetary times, the
need for IT investments can get lost in the
battle for resources. However, to effectively
serve the customers of immigration reform
while protecting public safety, agencies need
effective and interconnected systems. An
investment now in the IT systems of the
immigration system will help ensure agencies
protect both safety and opportunity.
To facilitate faster and more reliable information
gathering and sharing within the immigration system,
federal departments and agencies will need to
modernize and integrate current information systems.
For example, expanding biometric programs and
technologies will enhance the overall integrity of
the immigration system as biometric identifiers may
become shared by many agencies involved in the
reform effort. In addition, information gathering should
not only be simplified on modern systems but can also
be mobile-enabled to reduce the physical infrastructure
associated with the immigration system.
of new data to create risk profiles to help identify
foreign nationals who are using false identities and
other fraudulent means to enter the country or obtain
immigration benefits. Of particular note, advanced
analytic techniques can glean predictive insights,
uncover patterns and anomalies, and spot emerging
threats. Analytic and predictive techniques can identify
attributes indicating a person might be a threat or
perpetrating fraud, allowing for a risk-based approach
to be taken as a part of a larger approach to both
provisional application adjudication and long-term
enforcement. Technology-enabled threat detection not
only increases the speed of threat identification but
also reduces the labor hours spent culling through
the vast amount of data available to the immigration
system. This technology will both improve national
security and reduce costs.
The key to achieving the goals of improved data
sharing and analytics is cloud computing. The cloud
enables agencies to expand (or scale up) their storage
and computing capabilities quickly and efficiently using
existing IT models and systems. Combined with the
use of mobile technology, cloud technology will embed
an essential degree of flexibility as requirements may
need to adapt over time. If implemented correctly,
reform can be a catalyst for improved IT practices and
drive IT management efficiencies, the introduction of
cloud technologies, improved analytical capabilities,
and access to that data regardless of where the user
is working.
The collection, sharing, and analysis of data will
also enable agencies to strengthen fraud-detection
and risk-based approaches. As agencies expand
information sharing, they can use the large stores
10
3. Develop a whole community approach
As demonstrated by the widespread social media
response to the Boston bombings, social media has
the ability to focus significant attention on behavior
and individuals, rightly or wrongly. In the Boston case,
the crowdsourcing “sleuths” misidentified individuals
as potential bombers, causing those suspected great
harm. Similarly bloggers and social media users will
be active during the legalization process. Government
agencies should prepare to actively participate in
social media as an important method of community
engagement and performance feedback. For example,
the whole community approach could identify
significant individuals in immigrant communities across
social media platforms and involve them throughout
the process. Government representatives could
engage individuals regarding questions and encourage
applications from eligible individuals, as well as dispel
rumors. An enterprise approach to public participation
Exhibit 3 | Immigration Reform Effect: Where It Is Felt
Source: Booz Allen Hamilton
11
should be designed into the enterprise program
executive office.
The whole community approach requires a
communications and social-marketing strategy that
engages and educates stakeholder groups through
media and messages tailored to each group’s unique
roles and needs. However, the goal of an effective
community engagement strategy is not just to inform
but also to influence behavior in pursuit of desired
outcomes. This approach would not only help protect
vulnerable immigrant communities against fraud
but would also increase trust and facilitate positive
outcomes for both immigrants and the nation.
Achieving reform’s ambitious goals will require all
elements of the immigration system to work together
and support one another in performing their individual
mission functions (see Exhibit 3). Although DHS
houses the primary agencies delivering immigration
services and enforcement, other departments and
agencies currently provide direct or supporting
services, including the Departments of State, Labor,
Justice, and Health and Human Services, as well
as the Social Security Administration and Internal
Revenue Service. This approach does not stop with
coordination at the federal level but extends to state
and local agencies, employers, and non-governmental
organizations that serve immigrant communities.
A comprehensive, inclusive strategy will lay the
foundation needed to educate stakeholders about
their roles and responsibilities in implementing
the legislation. Implementation of the recent
Executive Order to improve the cyber security of
critical infrastructure resulted in the creation of an
Interagency Task Force to manage the broad range
of work required. The need for an enterprise level
(government-wide) program executive office or task
force will be needed to unify and integrate immigration
reform efforts.
Making it Stick
Using a variety of tools to educate and engage
both direct and indirect stakeholders will be
crucial to successful implementation. Tailoring
communication and outreach strategies to
particular audiences’ needs and lifestyles
will help increase buy-in. For example, using
social media and mobile-enabled technology
may speak to a younger generation of illegal
immigrants who are eligible for registered
provisional status.
responsibilities for federal agencies working directly or
indirectly with the immigration system. Achieving these
goals will not be easy, given the size and complexity of
the issues facing our nation.
Federal agencies can learn from the past and
continue planning for comprehensive immigration
reform by beginning to address the capabilities
needed to implement reform. Booz Allen combines
a comprehensive understanding of the immigration
system and its stakeholders with expertise in helping
clients work through complex organizational challenges.
Booz Allen provides the structure, partnership, and
inspiration to work with agencies as they navigate the
uncertainty that accompanies multi-stakeholder, largescale changes such as comprehensive immigration
reform. Ways to start addressing immigration reform
include planning for the operational changes that will
accompany reform efforts; securing funds to modernize
current systems for the anticipated future need; and
starting to build a community for implementation.
In this way, comprehensive immigration reform can
spur a genuine transformation that enhances mission
capabilities within each agency, while also creating a
unified immigration system that meets the nation’s
21st-century economic and security needs.
Conclusion
The approach to comprehensive immigration reform
is far from finalized. The legislation will likely offer a
pathway for illegal immigrants to adjust their statuses
and serve as a vehicle for strengthening border
security and improving overall immigration services.
The legislative process will undoubtedly yield many new
12
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David Rubin
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703-902-6842
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703-377-1425
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703-984-1028
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