INS Restructuring Letter to Chairman Rogers for LRD Clearance

      Attached is the "final" version of the Rogers letter reflecting DPC/OMB
        edits and which has been cleared by the Director.   Ingrid will put the
        letter and side-by- side comparison into interagency clearance thi's
        afternoon with comments due tomorrow. Any questions, please contact
        Julie, Ingrid or me.   Thanks.

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                                                           DRAFT
The Honorable Harold Rogers
Chairman
Subcommittee on Commerce, Justice, State,
      the Judiciary and Related Agencies
Appropriations Committee
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U.S. House of Representatives
Washington, D.C. 20515

Dear Mr. Chairman,

        In the Subcommittee's Report accompanying P.L. 105-119, the Congress directed the
Attorney General to review the recommendations of the Commission on Immigration Reform
(CIR) and develop a plan that would result in greater effectiveness and efficiency in the
performance of the core functions of the federal immigration system. The President, also
responding to the report of the CIR, asked the Domestic Policy Council (DPC) to "evaluate
carefully the [CIR] proposal and other reform options designed to improve the executive
branch's administration of the Nation's immigration laws." In conducting this review, the DPC,
working closely with the Office of Management and Budget, consulted with the Departments of
Justice, Labor and State, the INS, staff of the CIR, immigration experts and advocacy groups, and
other White House offices, including the National Security Council.

        The DPC/OMB review concluded that the CIR report correctly diagnosed many of
INS' problems -- insufficient accountability between field offices and headquarters, lack of
consistency and professionalism, overlapping organizational relationships, and significant
management weaknesses. These problems have hampered the ability of the INS to pursue
effectively the principle tasks that Congress and the President expect the INS to perform:
effective enforcement of our immigration laws both at our borders and in the interior, and
the efficient provision of immigration and citizenship benefits and services. Improving the
ability of the INS to pursue these critical priorities must be the guiding principle of any
reform plan.

       After careful consideration and study, we have concluded that the most effective
way to adhere to this guiding principle is to implement dramatic and fundamental reforms
within the INS. The Administration's reform plan will untangle the INS's overlapping
and frequently confusing organizational structure and replace it with two clear
organizational chains of command -- one to accomplish its enforcement mission and the
other to provide immigration-related services. By retaining both of these functions within
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a single agency, the Administration's reform plan will ensure that both the enforcement
and service operations are appropriately coordinated and supported by Headquarters.
The Administration's reform plan will strengthen accountability and improve efficiency
and effectiveness by allowing each of the two chains of command to focus on the unique
management, knowledge, skills, and abilities of its function.

The key features ofthe Administration's plan are:

       Effect an operational split between enforcement and services, resulting in two
       distinct, clear lines of authority from the field to headquarters, with an INS
       Commissioner continuing to be responsible for overall agency operations;

       Eliminate the current "district" field structure, and replace it with a functional and
       geographic-based organization that allows for the creation of service offices in areas
       convenient to their immigrant "customers" and the creation of enforcement offices
       focus at border areas, ports of entry and significant interior locations;

       Improve the quality ofthe workforce by creating separate enforcement and service
       career paths for INS employees, so that the best employees can move up the ladder
       and be rewarded for high performance;

       Restructure management operations to ensure an effective "shared support"
       operation (e.g., records and data management, technological support, employee
       relations, and administrative support) that will serve both the enforcement and the
       service sides of the agency.

      Establish a Chief Financial Officer to address deficiencies in financial, accounting
       and budget execution systems.

       In addition to implementing the restructuring plan noted above, the Administration
will continue its efforts to identify and then take approP!iiate remedial action to eliminate
any remaining areas of duplication, overlapping responsibilities, or inadequate
coordination between the INS and the Departments of Labor and State.

        It should be noted that during its review, DPC and OMB c"arefully evaluated the
recommendations of the CrR. The CrR concluded that the INS's dual responsibility of
welcoming legal immigrants and deterring illegal immigration has resulted in "mission
overload." To address this issue, the crR recommended disbanding the INS and reallocating its
primary responsibilities to the Department of Justice (DOJ) and the State Department. We
believe those recommendations would only compound the current problems with the nation's
immigration system.

       First, such a substantial reallocation of authority could require a six- or seven-year


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transition, exacerbating existing concerns about long delays in immigration activities.
Second and even more important, this reallocation would hinder the coordination and
communication necessary to maintain the integrity and efficiency of both immigration'
enforcement and immigration service operations. To be most effective, all immigration policy
and management should remain within one agency at the Justice Department.

       The Administration's plan is a fundamental change in the way the INS conducts
business. This restructuring -- from top to bottom -- will address long-standing concerns
about lines of authority and responsibility, consistency of operations, and performance
within the INS. It will result in improved enforcement coordination, career paths that
support professionalism, and measurable changes in the way INS provides services to the
immigration community. Most important, it will greatly improve the ability of the INS to
perform their duties effectively and efficiently. We look forward to working with you and
other members of Congress to implement this restructuring plan and to ensure successful,
long-term improvements in the Nation's immigration system.

Sincerely,


Franklin Raines
Director
Office of Management and Budget



Bruce Reed
Assistant to the President for Domestic Policy



Janet Reno
Attorney General

Enclosures




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