Figure 2: Map of INS Districts. Each of the INS's 33 district offices determines its

own naturalization testing procedures. 16

I Miami, Fla. Applicants must score seven out of 10 (70 percent) on an oral examination. This is perhaps the single most popular form of the test, also used in Denver; Honolulu; Newark, N.J.; Portland, Ore.; and San Antonio.

Given these differences, it seems clear that not every citizenship applicant will have to meet the same standards. Applicants in Atlanta are at the total mercy of the INS officers who conduct their interviews. These officers may demand an unreasonably high level of knowledge. The more likely scenario, however, is that the officers will demand almost nothing at all. Indeed, with the current rush to citizenship and the INS confronting enormous public pressure to process naturalization applicants quickly, citizenship standards appear particularly vulnerable to a massive dumbingdown. Agents regularly hint that their superiors are more interested in meeting a numbers-driven goal than in making sure every naturalization applicant receives an appropriate assessment. "We have about 15 minutes for each interview," noted an INS officer based in Arlington, Va. "If I want to

Figure 3: Survey of District Offices. Naturalization testing procedures vary dramatically from district to district. In addition, most districts report that their testing is not subject to any oversight.

take a little extra time to check something, it really backs things up. We're always behind, even if things go smoothly. I usually skip my lunch hour just to catch up. You can guess what you want about the INS giving us so many appointments and so little time.""""

A stunning loophole in the INS procedural manual shows just how subjective the history and government examination can become: "In choosing the subject matters, in phrasing questions and in evaluating responses, due consideration shall be given to the applicant's education, background, age, length of residence in the United States, opportunities available and efforts made to acquire the requisite knowledge, and any other elements or factors relevant to an appraisal of the adequacy of the applicant's knowledge and understanding.""" In other words, the INS permits completely arbitrary testing. Robert Bowles, assistant district director for examinations in Puerto Rico, confirms that this loophole comes into regular use in his office: "We try to administer the test in line with the applicant's capacity. It all depends on the applicant's capacity."

The INS district office in Boston allows for widespread abuse of this loophole: "There is no specific naturalization test. It is at the test administrator's discretion to ask as many questions as he feels are necessary, or none," said Karen Haydn, assistant district director for examinations in Boston. This is because "the workers' union protested a standardized format some years ago."

No Oversight

The INS has earned a reputation for being one of the worst-run federal agencies. (For a thorough review of its problems, see Daniel W. Sutherland's CEO Policy Brief, “Abolish the INS.")" The fact that Washington does not monitor the naturalization testing that goes on in its 33 districts is further proof of this claim. Indeed, INS headquarters in Washington is unable to provide the information revealed in Figure 3. It simply has no idea what happens beyond the Washington, D.C. city limits.

In CEO's survey of all 33 districts, most spokesmen said that nobody
oversees their testing procedures. Figure 3 shows each district's response
yes or no- as to whether Washington oversees its administration of the U.S.
history and government examination. Only six said they received
supervision. The other 27 said that nobody monitors their testing. Here are a
few examples of what INS officials said:

I "There is no oversight,” said Karen Haydn, assistant district
director for examinations in Boston.

"All Washington did was establish the guidelines for the operation

of our test site. We just comply," said Karen Eckert, deputy

assistant director for examinations in Buffalo, N.Y.

91 Citizenship for Granted

I "There is no Washington oversight,” said Mark Hansen, assistant district direction for examinations in Cleveland.

Indeed, the INS headquarters in Washington, D.C., acknowledges its lack of oversight. "There are no oversight procedures at all," said Ernestine Fobbs, an INS spokeswoman.

Conclusion:

Adopt National Standards

By weakening the U.S. history and government test, the INS damages a vital part of the naturalization process, the single best measure it has for determining whether immigrants understand the democratic principles they must know in order to participate fully in American civil society. The surest guard against the erosion of standards—and the only way to guarantee fair treatment from district to district-is to establish set of national standards based upon the following four principles:

I The test should be neither too hard nor too easy. It should
include 20 fill-in-the-blank questions and require 15 correct
responses to pass. A 10- to 15-minute time limit would be
appropriate. INS interviewers might also be permitted to coax oral
responses from borderline cases, but only with guarantees that this
practice would not become a slippery slope to lower standards.
Individual districts might be allowed to experiment with testing
people in groups immediately before they sit down for their
interviews, especially if such a procedure would save time.

I The questions should be made more meaningful. Currently,
many of the questions test trivia rather than an understanding of
American political principles. An immigrant might be asked a U.S.
senator's term of office. A more compelling question would ask
why elected representatives have terms of office in the first place. It
strikes at a more fundamental point about American democracy, and
questions like it would probably serve as a better index of
knowledge.

I Combine the U.S. history and government exam with the
English-language requirement. Because this is a written, fill-in-
the-blank test, applicants who pass should be assumed to have met
the English-language reading and writing requirements. They would
not have to read sentences to their INS interviewers nor would they
have to write down sentences dictated to them—two popular
practices right now. This reform would save these extra steps and
cut down on the amount of time needed for interviews.

10 CEO Policy Brief

I INS headquarters should monitor the testing procedures in all district offices to ensure their uniform nature. Furthermore, if the INS wants to continue its practice of allowing private vendors to offer the U.S. history and government test, it must immediately begin an aggressive quality-control program to guarantee the integrity of all involved. Absent this reform, the INS should abandon contract testing entirely.

By meeting these goals, the INS would ensure that its testing on U.S. history and government is fair and meaningful. It would also put the INS in compliance with a law that, at least for the moment, it carelessly flouts. The U.S. attorney general has broad powers to make rules and regulations governing the content and administration of the U.S. history and government examination.20 There is no reason why the INS cannot begin immediately to write and adopt a set of national standards that would make its testing more fair and more meaningful.

11 Citizenship for Granted