Audit Report on the New York City Department of Youth and Community Development’s Citizenship New York City Program

EXECUTIVE SUMMARY

Background

The Department of Youth and Community Development (DYCD) supports youth and community services throughout New York City through contracts with a broad network of community-based organizations. In July 1997, DYCD initiated the Citizenship New York City (CNYC) program to provide citizenship services to legal immigrants (immigrants who have a green card or permanent visa) living in New York City. This program, which is directly administered by DYCD, was created as the result of the federal Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996.

PRWORA changed almost every aspect of alien eligibility for federal, state, and local government assistance programs. It established comprehensive new restrictions on the eligibility of legal aliens for public assistance and further restricted public benefits for illegal aliens and non-immigrants (here to visit, attend school, or work temporarily).PRWORA eliminated virtually all eligibility of immigrants for Supplemental Security Income (SSI) and food stamps.

One of the ways immigrants remain eligible for federal benefits is by becoming naturalized U.S. citizens. To be naturalized, aliens must have continuously resided in the United States for five years as permanent residents, must show that they have good moral character, must demonstrate the ability to read, write, speak, and understand English, and must pass an examination on U.S. government and history.

The CNYC manual, dated June 1999, defines its current target population as legal permanent residents living in New York City who are eligible for naturalization and are receiving or applying for SSI or food stamps, or whose food-stamp or SSI eligibility has been discontinued because of immigration status. With the help of the New York City Human Resources Administration (HRA) and the Department of Homeless Services (DHS), CNYC is able to identify immigrants at risk of losing or being denied federal benefits.

CNYC also assists legal immigrants who neither receive nor seek federal benefits but simply want to become citizens. It has offices in each of the five boroughs, in neighborhoods with large concentrations of immigrants. Each center provides information and free assistance with citizenship applications, required photographs, and referrals for English and U.S. history and civics classes. According to CNYC officials, the staff also makes home visits to help homebound individuals with their applications.

CNYC also operates a community outreach program in which its representatives visit organizations such as schools, senior centers, churches, and hospitals to provide applications, information, and assistance to immigrants in these organizations. Further, its telephone bank of six operators calls persons whose names are received from HRA to determine if they are eligible for citizenship and to inform them that CNYC can provide assistance in the naturalization process. The phone bank also handles unsolicited calls from immigrants seeking information.

Objectives

The objectives of this audit were to determine (1) the effectiveness of the CNYC program and (2) whether funds were expended on program-related goods and services.

Scope and Methodology

The scope of our audit was originally limited to Fiscal Year 2000, but we expanded the scope to include Fiscal Years 1998, 1999, and 2001, to cover all the years that the program has been in operation. To familiarize ourselves with the CNYC program we interviewed program officials and staff members, and reviewed the CNYC Policy and Procedure Manual. We also visited the Queens field office to observe the activities at the office and to understand the process that takes place when an individual walks into the office to apply for citizenship.

We chose a random sample of 100 records from the CNYC database that contained a listing of 236,941 immigrants. We reviewed the contact screens for each individual to determine the number of people CNYC successfully contacted and the number of individuals who filed citizenship applications with INS. We reviewed an additional 25 records of individuals who had completed the application process to determine whether they were part of CNYC’s target population and the length of time it took CNYC to conduct its supervisory and quality review of their applications.

Results in Brief

CNYC measures its effectiveness by the number of applications it submits to INS. Basedbon this measurement, CNYC is doing a good job. The number of applications completed bybCNYC and submitted to INS has steadily increased from 5,607 in Fiscal Year 1998 to 10,27 in Fiscal Year 2001. The number of appointments made and applicants served has also increased each year. Additionally, CNYC’s OTPS funds were used appropriately for goods and services that were necessary and applicable to the program.

However, improvements can be made to further enhance the program, especially in terms of measuring its effectiveness. Although CNYC knows the number of applications it submitted to INS, it does not know whether the applicants it assisted ultimately became U.S. citizens. CNYC has not initiated a formal process (e.g., routine correspondence with applicants) to try to determine the outcome of its efforts, even though one of CNYC’s original objectives was to "track naturalization applicants throughout the entire process to successful completion."

We also reviewed the contact screens for 100 records in the CNYC database and concluded that the CNYC staff did not always attempt to contact all of the individuals in the database, as required by its manual. Specifically, CNYC’s staff did not attempt an outreach to 14 individuals, and did not complete its outreach to seven individuals. Moreover, CNYC contacted four individuals who should not have been contacted, since outreach had already been completed. Lastly, CNYC’s manual failed to address the steps that should be taken by the staff when the person that they are trying to contact has a disconnected telephone.

In addition, CNYC does not report on what percentage of individuals who completed the application process were at risk, even though that information is available in the CNYC database. Furthermore, during our review, the CNYC database did not have a date field indicating when the applicant’s name was entered in the system. Lastly, we reviewed the contact screens for 25 individuals who completed the application process with CNYC and determined that the supervisory review and the forwarding of applications to INS were not always done in a timely fashion.

This audit makes 13 recommendations, which are listed below. CNYC officials should:

1. Formalize the process for determining the citizenship status of program applicants.
2. Develop and report upon performance indicators that set goals and then measure the actual outcome of the program (i.e., the number of applicants who become U.S. citizens) as a percentage of applications submitted to INS.
3. Ensure that the staff completes all outreach efforts to each individual in its database.
4. Ensure that the staff does not make additional contacts in cases where contact has already been completed.
5. Ensure that the CNYC manual addresses what steps should be taken when telephone numbers are disconnected.
6. Ensure that the Event Listing case notes include all attempts at contact, including letters that are sent through bulk mailings.
7. Continue to generate exception reports to ensure that all individuals in the system are receiving the necessary outreach.
8. Require that the staff obtain and record the risk status of walk-in applicants in the Information and Retrieval screen.
9. Report in the Mayor’s Management Report the percentage of applications filed with INS for individuals who were at risk. This would indicate how well CNYC is accomplishing its mission.
10. Determine whether CNYC’s stated mission of preparing naturalization applications for immigrant New Yorkers who seek to become citizens in order to retain or attain eligibility for federal public benefits is still viable. If not, a revised mission statement should be promulgated.
11. Make sure that the CNYC database continues to maintain a visible and accessible date field that shows when individual names are entered in the system.
12. Ensure that whenever possible supervisory reviews are done on the day that processing is completed, when the applicant is present, as required by the CNYC protocol.
13. Consider defining an acceptable time frame between the quality assurance review and the forwarding of applications to INS. This time frame should be specified in the CNYC manual.

Agency Response

The matters covered in this report were discussed with officials from CNYC during and at the conclusion of this audit. A preliminary draft report was sent to the DYCD officials on April 29, 2002, and discussed at an exit conference held on May 7, 2002. On May 15, 2002, we submitted a draft report to DYCD officials with a request for comments. We received a written response from DYCD officials on May 30, 2002. The response stated in part:

"DYCD would like to thank the Comptroller’s Office for its continuous communication with DYCD officials throughout the course of the audit. These discussions made us aware of areas for improvement and allowed us to implement corrective action plans immediately."

DYCD agreed with nine recommendations (one of which it has implemented and one of which it has partially implemented), partially agreed with recommendations #2 and #8, and disagreed with recommendations #9 and #10.