DHS OIG Report Highlights Flaws Related to Issuance of Green Cards

On November 16, 2016, the U.S. Department of Homeland Security’s Office of Inspector General (OIG) released a report analyzing concerns related to the issuance of I-551s or lawful permanent resident cards (“green cards”). The report, entitled Better Safeguards Are Needed in USCIS Green Card Issuance, addresses challenges in U.S. Citizenship and Immigration Services (USCIS) automation of benefits processing and the extent to which the agency has inappropriately issued green cards. The report provides recommendations to make the program more accurate, secure, and efficient.

Overview of OIG Report – Incorrect Info or Duplicate Cards

Since May 2013, USCIS personnel have been processing new and replacement green cards electronically using the Electronic Immigration System (ELIS). In 2016, the OIG conducted an audit on this system. The report is based on this audit and shows that continual system errors have caused at least 19,000 green cards to be issued with incorrect information or in duplicate over the last three years. Since ELIS implementation in 2013, the percentage of green cards issued in error has steadily increased each year.

In addition, over the last three years, the USCIS has received more than 200,000 reports from approved applicants about missing cards. The number of cards sent to wrong addresses has incrementally increased since 2013, due in part to complex processes for updating addresses, ELIS limitations, and factors beyond the agency’s control. USCIS efforts to address these errors have been inadequate.

Inadequate Recovery of Incorrectly Issued Green Cards

The report found that USCIS offices did not employ a standardized process for how to contact individuals who were issued green cards in error. In some cases, the USCIS made multiple attempts to contact the individuals by eMail and/or physical letters. In other cases, the USCIS either made only one contact attempt or could not confirm that any attempt at all was made. Without a uniform approach for conducting recall efforts, the report concludes that the USCIS cannot ensure that impacted customers are receiving clear or timely instructions on how to return improperly issued cards. In addition, due to inadequate tracking, the USCIS had difficulty determining the exact number of cards returned in response to its efforts. The OIG found that roughly 6,532 (or 34 percent) of the 19,001 green cards sent in error were unaccounted for at the time the report was written.

Risks and Burdens of Improperly Issued Green Cards

Improperly issued green cards pose significant risks and burdens for the USCIS and stakeholders. Errors can result in approved applicants being unable to obtain benefits, maintain employment, or prove lawful immigration status. Conversely, in the wrong hands, green cards may enable unqualified people to remain in the United States and access immigrant benefits. Responding to card issuance errors has also resulted in additional workload and corresponding costs, as the USCIS spent just under $1.5 million to address card related customer inquiries in fiscal year 2015 alone.

OIG’s Recommendations to Prevent Problems with Issuance of Green Cards

The report makes seven suggestions to the USCIS on how to make the system more effective, secure, and efficient.

Recommendation 1

Ensure ELIS design and functionality problems are corrected to prevent, to the extent possible, further green card processing errors.

Recommendation 2

Ensure development and implementation of the internal controls needed to ensure green card errors are identified and corrected early in the production process, prior to card issuance.

Recommendation 3

Ensure development and implementation of a standard process for card recovery efforts.

Recommendation 4

Ensure development and implementation of a standard procedure for identifying and preventing unrecoverable cards from being used.

Recommendation 5

Implement a centralized method to track and document green cards that are returned through recovery efforts.

Recommendation 6

Complete and implement identity-proofing capability to enable customers to submit address changes online in ELIS.

Recommendation 7

Evaluate the costs and benefits of using USPS’s Signature Confirmation as an alternative secure method for delivering green cards to applicants.


The OIG found significant problems related to the accurate dissemination of green cards by the USCIS. It remains to be seen whether or when the OIG recommendations will be implemented, and what effect they will have on processing and delivering future green cards.


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Disclaimer: The information provided here is of a general nature and may not apply to any specific or particular circumstance. It is not to be construed as legal advice nor presumed indefinitely up to date.