A delegation representing the Congressional Task Force on Immigration Reform visited the Krome Service Processing Center (Krome) and the Miami International Airport (Airport) on June 10, 1995. In a June 27, 1995, letter to Congress, [ The letter was sent to Representative Elton Gallegly, Chairman of the Task Force on Immigration Reform, the Members of the Task Force, and Newt Gingrich, the Speaker of the House of Representatives.] which was signed by nearly 50 Immigration and Naturalization Service (INS) employees, the INS employees' union [ National Immigration and Naturalization Service Council of the American Federation of Government Employees.] alleged that INS management officials took actions to deceive the delegation as to the extent of illegal immigration problems in Miami.
The OIG investigation, initiated pursuant to that complaint, substantiated some of the most significant of the union's allegations, finding that various INS officials had deceived the delegation during its fact-finding visits to Krome and the Miami International Airport. The OIG report further made several recommendations regarding needed systemic reforms. The report also assigned responsibility to various INS personnel for having deceived a delegation from the Task Force during its visit to those two facilities. The administrative process for imposing discipline on those INS employees is still ongoing.
Our follow-up review included an examination of specific problems identified in the initial investigation. At Krome the initial investigation disclosed the following weaknesses: (1) overcrowded conditions, (2) housing of criminal aliens with non-criminal aliens, (3) the release of criminal aliens into the community, (4) the release of aliens who had not been medically cleared by the Public Health Service (PHS) or whose criminal histories had not been checked, and (5) inaccurate record-keeping systems for tracking the movement of aliens. At the Airport the initial investigation noted that there was no policy on inspectors wearing gear belts and no clear criteria for the detention of aliens in hard secondary inspection. We also found that detention logs were poorly maintained.
Upon receipt of the OIG report, the INS Commissioner took several actions. On June 20, 1996, she sent the Attorney General INS' Plan [ The Commissioner sent the Attorney General status reports on INS' implementation of its Plan on August 12, 1996, October 1, 1996, and February 20, 1997.] for responding to the OIG report. The Plan described INS' actions to: (1) affirm its commitment to accuracy and thoroughness in reporting information; (2) detail selected senior employees to Miami pending review of disciplinary actions against the INS employees whose misconduct was described in our report; and (3) assess policies related to the release of detainees, weapons worn by inspectors, and the handling of aliens in hard secondary. On June 23, the Commissioner ordered a Management Review Team (INS Review Team) to Miami to address the issues that were identified by the OIG report and to provide a comprehensive assessment of the Miami office's management deficiencies and needs.
The INS Review Team began its on-site review in Miami on June 24, 1996, and members of the Team remained on-site in Miami for about seven months. The INS Review Team submitted its Final Report on February 5, 1997. [ The INS Review Team submitted an Initial Report on July 26, 1996, and an Interim Report on September 10, 1996.] The INS Review Team initially focused its efforts on the systemic problems identified by the OIG, but expanded its review to include other significant issues that were contributing factors to those problems.
II. KROME SERVICE PROCESSING CENTER
The Krome Service Processing Center (Krome) is primarily an adult detention facility within INS' Miami District. The Detention and Deportation Program is under the direction of the Miami District Director; however, day-to-day responsibilities are under the direction of the Assistant District Director for Detention and Deportation (ADD-DDP). An Officer-in-Charge (OIC) manages Krome and reports to the ADD-DDP. Krome is a multi-building facility located on about 15 acres in the Florida Everglades, approximately 23 miles from downtown Miami.
A. Detainee Population
1. OIG Investigative Report Findings
Although Krome's rated capacity [ The rated capacity relates to the number of aliens who can be housed inside Krome in compliance with standards set by the American Corrections Association.] at the time was 226, approximately 400 aliens were being detained at the facility immediately prior to the Congressional delegation's visit on June 10, 1995. The review of population levels over a one-year period contained in our original Miami INS report established that large population increases and significant decreases were not uncommon. The male dorm was overcrowded and females were housed in the Public Health Service area. In general, when Krome had more criminal aliens than its isolation cells could accommodate, criminal aliens were housed together with the general alien detainee population. Felons and aggravated felons were housed together with non-felons and juvenile males within the male dormitory. In addition, it was the policy to allow female criminal aliens to be mixed together with the general female population because there was limited space for segregating females.
2. Results of Follow-up Review
Using Krome's manual processing log, we examined daily alien population levels and movements for the period December 1, 1996, through May 31, 1997. The average daily population for the 6-month period totaled 265 detainees. The average daily population for each month during the period was computed as follows.
In an October 1996 memorandum, the Acting District Director stated that Krome's rated capacity was 226. During our follow-up visit, we were informed that Krome's rated capacity was raised to 274 during a June conference call between the Eastern Regional Office of INS, the Miami District Office, and Krome managers. However, nothing had been formalized in writing at the time of our review. This increase is justifiable based on the completed construction of one additional building.
According to Krome managers, Building 14 was under construction in October 1996 when the rated capacity was 226. They stated that Building 14 holds a total of 80 beds, thus increasing Krome's rated capacity to 306. However, the managers chose to set an operational capacity of 274 so that the maximum rated capacity of 306 would not become the norm. One side of Building 14 opened in January 1997. Both sides of the building were in use at the time of our visit.
The largest male dormitory, Building 11, has four sections. Sections A and B, each housing 60 detainees, were in use during our follow-up visit. However, Sections C and D (with a capacity of 16 detainees each) were closed due to water damage.
A new 300-bed detention facility (Building 8) was under construction and was expected to be completed by the end of July 1997. INS Headquarters staff estimated detainees would be moved into the building by the end of November 1997. Krome managers stated that they plan to use Building 8 to house male criminal aliens.
If the INS continues using existing dormitory space along with the 300-bed unit, Krome's rated capacity could approach 600. However, Krome's potential capacity could be considerably lower if alternate plans are made for use of current space. Several plans are under consideration for changes in detention space after Building 8 opens. Possible uses for existing buildings include: Sections A and B in Building 11 for housing females; Sections C and D in Building 11 for employee classrooms/training areas or a law library for the detainees; Section A of Building 14 for "overnights"-- detainees in transit from the airport; and Section B of Building 14 as an indoor recreation area and temporary housing during immigration emergencies. These considerations could significantly affect Krome's potential capacity at a time when detention capacity is at a shortage. In our judgment, the INS should carefully assess detention rates before allocating space for other activities.
During the initial investigation, we found that female detainees were held in the dormitory area within the PHS building shortly before the visit by the delegation. This area was originally intended to house aliens who had not yet been medically cleared to enter the general population. During our follow-up visit, we found substantial improvements in the housing for female detainees. However, female criminal aliens continue to be housed with non-criminal females due to limited segregation space.
During our follow-up visit, we toured the facility and it appeared that most male criminal detainees were being held in the dormitory area within the PHS building. However, once again, we found male criminal aliens housed with male non-criminal aliens. This was said to be a temporary arrangement until the completion of the new 300-bed facility for criminal aliens. When we raised concerns about housing criminal and non-criminal aliens together, INS Headquarters staff informed us that there is no requirement to separate criminal and non-criminal detainees.
We also reviewed INS' Deportable Alien Control System (DACS) [ DACS is an INS automated database containing information on the detention and deportation of illegal aliens.] printouts which reflected that some aggravated felons and other criminals were being housed in the general population. When reviewing a DACS report, we identified a female detainee whose data indicated that she was a criminal and insane. When asked where this detainee was being held, a Krome manager stated that she was housed with the other female prisoners because Krome did not have a segregation area for female criminals.
We examined the DACS Detention Inventory Report for June 16, 1997 [ We did not assess the accuracy of this DACS report.] and found that the 263 aliens detained included 212 males and 51 females. Of these 263 aliens, the report identified the following types of detainee categories:
26 aggravated felons (20 males, 6 females)
62 criminal violations, other than aggravated felony, narcotics, or INS violations (50 males, 12 females)
38 narcotics violations (29 males, 9 females)
95 INS violations (78 males, 17 females)
1 insane (1 female)
41 no codes (35 males, 6 females)
According to the printout, aggravated felons were housed in five different locations within the facility. Ten male aggravated felons were housed in Building 11, six females in Building 14-A, five males in Building 14-B, and five males in the PHS building. These data confirm our observation that criminal aliens were mixed in with the general population.
We also examined the detention of juveniles during the six-month review period and found that, according to the processing log, they were routinely moved to either Boystown or the Catholic Home within a few hours of their arrival at Krome. In one instance, a juvenile was housed at a Ramada Inn for one evening in the custody of a Detention Enforcement Officer because the Catholic Home would not accept him. We did note several escapes by juveniles from the Boystown facility. According to Krome managers, older juveniles escape from these housing facilities fairly often.
B. Release of Aliens Into the Community
1. OIG Investigative Report Findings
From a sample of 58 aliens released into the community, the original investigation disclosed that:
35 of 58 were not medically cleared by the Public Health Service;
4 of 58 had known criminal records;
18 of 58 had no evidence in Krome's files to indicate a criminal history check was performed before release; and
36 of 58 had no known criminal records.
2. Results of Follow-up Review
We selected a judgmental sample of 28 aliens released into the community in June 1997 to determine whether: (a) criminal histories were checked before placing an alien into custody and before his/her release; and (b) medical history checks/screenings were completed before an alien was placed into the general population and clearances were obtained before an alien's release.
a. Criminal Histories
We found that:
9 of 28 aliens released had known criminal records or indications of potential serious criminal activity;
4 of 28 had insufficient evidence [ On January 22, 1997, the Deputy Commissioner, INS, issued a policy memorandum requiring that CIS and NCIC checks be completed before an alien is released from INS custody. The memorandum further required that the printed information from the computer terminal be placed in the alien's A-file to indicate the results of the checks.] in the files to indicate a criminal history check was performed before release; [ The OIG Investigation staff ran NCIC queries on these four individuals and found that three of the four had no known criminal records and that the NCIC query could not be completed for the fourth. This last case was a stowaway from Nigeria.] and
15 of 28 had a criminal history check showing no known criminal records.
Our comments regarding the nine aliens with known criminal records follow.
One alien was convicted in 1994 of Conspiracy to Commit Aggravated Child Abuse and Third Degree Murder in connection with the killing of a 5-year-old child. She was also convicted of bank fraud in 1982. She was released from Krome under an Order of Supervision. [ An Order of Supervision allows the alien to be released from the INS detention facility and places the alien under certain restrictions. In this particular case, the alien was not allowed to travel outside of the State of Florida for a period of more than 48 hours without first notifying the ADD-DDP. Also, the alien was required to provide written notice of any change of residence within 48 hours and required to appear in person at the Miami District Office in June of each year.] The Alien file (A-file) contained a notice that the alien was convicted of a crime determined to be an aggravated felony. The file also included a memorandum from the PHS doctor indicating the detainee had an "incurable" disease and was being studied by the University of Miami. We noted that the alien reported a Tampa address approximately 250 miles away from Miami when she signed the Order of Supervision.
In June 1997, we requested documentation from Krome's Acting Officer-in-Charge to support excessive medical costs that he claimed were incurred for this detainee. As of September 3, 1997, the information has not been received. [Country of Origin - Trinidad]
One alien was convicted in 1988 of cocaine trafficking, an aggravated felony, and was imprisoned in Florida. In 1994, the alien was processed by INS and released on his own recognizance; however, deportation proceedings were never completed. In June 1997, INS served him with a Warrant for Arrest, and released him on a $25,000 bond the following day. [Dominican Republic]
Two individuals (a husband and wife) were detained and questioned by a Florida drug task force in June 1997 for transporting $200,000 in U.S. currency from New Jersey to Miami and possessing false immigration documents. The task force seized the $200,000, but turned the couple over to INS for the immigration violations. The A-file indicated they were "to be processed by USM for money fraud." Each alien was released by INS on $15,000 bond set by the Assistant Chief Border Patrol Agent. The A-file did not contain sufficient evidence to substantiate that criminal history checks had been properly performed prior to the aliens' release or that the aliens' fingerprints had been submitted to the Federal Bureau of Investigation (FBI). [ The OIG's query of INS' Central Index System showed that both aliens were born before 1956. The NCIC query results state that a large number of records for persons born prior to 1956 are not automated at the FBI and that a fingerprint card should be submitted if a search of nonautomated files is desired.] [Columbia]
One alien, originally paroled into the United States in 1980, had several convictions: a 1990 conviction for possession of cocaine; a 1994 conviction for possession of cocaine;, and 1996 convictions for sale, purchase, and/or delivery of cocaine, and threatening a public servant. He was sentenced to prison after each conviction. In May 1997, the District Director revoked the alien's parole because continued parole was against the public interest and recommended the alien be detained in custody pending removal proceedings. An Immigration Judge ordered the alien's removal on June 6, 1997. However ten days later, a District Deportation Officer and a Supervisory Deportation Officer recommended the alien's release on a Mariel Cuban Criminal Custody Worksheet. An INS Headquarters official authorized the alien's parole and he was released the same day. [Cuba]
One had several convictions in 1992 relating to drugs, tax evasion, and engaging in a continuing criminal enterprise. In 1982, the alien entered the country without proper documentation and was placed into exclusion proceedings; however, he was not detained at the time. In 1988, an Immigration Judge denied him asylum, but withheld his deportation. The decision was appealed, and, in 1992, the Board of Immigration Appeals upheld the Immigration Judge's ruling.
As a result of the 1992 conviction, the alien was initially sentenced to twelve years in federal prison, but his sentence was reduced to 88 months by a U.S. District Court in 1997. In June 1997, the alien was taken into custody by the INS upon his release from a federal prison facility in Florida. INS released him on parole the same month. [Cuba]
One alien had a criminal history dating back to prison in California (1975) for possession of heroin. In 1977, he was placed into formal deportation proceedings and an Immigration Judge released him on his own recognizance. However, the alien failed to appear for a deportation hearing in 1978. In 1994, the alien was convicted for possession of heroin for sale, an aggravated felony, and for violation of probation. INS gained custody of the alien in 1996 when he was released from jail. An Immigration Judge then ordered the alien be detained without bond and in September 1996 ordered the alien deported, but he was not. He has filed an appeal that is still pending.
Our review disclosed a discrepancy between INS' record keeping systems --one said the alien was released under a voluntary removal, and another said he was paroled. A letter in the A-file indicated that the alien suffered from diabetes resulting in kidney failure and that he was "more depressed than usual" since he learned of his father's death. The PHS recommended release for medical reasons--the alien was a candidate for renal dialysis and later for a possible renal transplant. [Mexico]
One alien had convictions in 1994 that included possession of cocaine and cannabis, use of drug paraphernalia, and obstructing a police officer. In May1997 the alien, who was a legally admitted permanent resident, was taken into custody by the INS as he attempted to re-enter the country through the Miami airport. The District Director authorized his parole and released him in June 1997. [Cuba]
One alien was convicted of theft by deception in 1996. He was released on $1,500 bond authorized by the Acting OIC. [Venezuela]
INS requested the names and A-numbers of the detainees in our sample who were released from Krome and who we considered to have had criminal records. INS' response is contained in Appendix I of this report. Because of privacy issues, we deleted aliens' names, A-numbers, and names of INS officials from the Appendix. The aliens identified in INS' response are not listed in the same order as they appear in this report.
While on-site in Miami, we discussed the recent release of these criminal aliens into the community with the Acting Supervisory Deportation Officer, the Acting OIC, and the District Director. We expressed our concern about the severity of some of the crimes committed by the detainees. The managers provided various explanations for the releases.
We were first told that the alien convicted of third degree murder of a 5-year-old child was released for "humanitarian" reasons, in that the PHS requested an early release due to her incurable disease -- lupus -- and that the University of Miami wanted to study her skin disease. Krome managers said that high medical costs were incurred for treatment of the alien. The Acting Supervisory Deportation Officer who authorized the release stated that he was directed to do so by the Acting OIC. The Deportation Officer further stated that although he did not personally agree with the release of the alien, he had not done anything illegal by authorizing her release. The Acting OIC later told us that the alien "didn't actually commit the murder...her husband did it." The District Director stated that he would be more concerned about this case had the alien committed the murder herself.
Court documents showed that the murder victim was a foster child in the alien's care. From the information we reviewed in the A-file, it appeared that the alien, the alien's husband, and her natural son were involved in the aggravated child abuse, which occurred over a period of days and resulted in the death of the child.
The Acting OIC and District Director informed us that, in some cases, the nationality of the aliens must be considered to fully understand the reasons behind their release. For example, one of the criminal aliens had his parole revoked, was ordered removed by an Immigration Judge, and was then released from Krome on parole. We were told that because Cubans cannot be deported, they are released. [ We note that the issue of removing Cuban aliens is complicated by longstanding U.S. policies against the repatriation of Cuban citizens. These policies have led the INS to adopt practices that reflect the U.S. government's handling of Cuban aliens, such as the promulgation of directives concerning the review of cases involving detained Mariel Cubans that permit parole release under prescribed circumstances.]
In general, we found that issues raised during the initial investigation concerning the release of aliens into the community were still evident at Krome. Although it appears that the District Director has wide discretion in the release of aliens, we seriously question the practice of releasing many of the criminals cited above . We believe that the release of convicted felons should be permitted only under narrowly tailored guidelines and only under extraordinary circumstances not present in many of the instances above.
b. Medical Histories and Clearances
We found that only one person in our sample of 28 had a formal Medical Alert and that this person was cleared by PHS before release. This information was provided by the PHS' Health Services Administrator. Further, PHS informed us that all detainees in our sample were medically screened. According to several detention officers, all detainees are medically screened immediately upon arrival, and all detainees are sent to PHS before release to have their booking cards stamped. We found that booking cards for 5 of the 28 aliens in our sample were not stamped by PHS; therefore, we were unable to confirm that the five aliens' medical records were checked for Medical Alerts before they were released.
Although we requested the medical file for each alien in our sample, the Health Services Administrator informed us that PHS policy prohibits the release of any detainee's medical file to non-medical personnel. The Acting OIC confirmed that PHS provided little information as to the medical condition of the detainees. Because we were denied access to the files, we relied on the Health Services Administrator's review of the aliens' medical records and the assertions he made concerning medical screenings and clearances.
Detention Enforcement Officers (DEO) and the Acting Chief DEO lacked knowledge as to the meaning of a Medical Alert. Krome's booking card contains a space for Medical Alert with boxes for "yes" and "no" answers. An explanation is requested for "yes" answers. We interviewed several DEOs to determine the basis for the information documented in the Medical Alert block. One DEO said she never entered yes or no; she just left it blank. Another DEO said that if the person were obviously in need of medical care, for example if they were bleeding when they arrived, he would mark yes. Yet another DEO stated that if there was any information in the file regarding medical prescriptions, he would mark yes. Clearly, there is no common understanding of the definition of the term, which reduces the category's meaning and utility.
The Health Services Administrator, PHS, advised us that PHS sends an INS Form I-834, Medical/Psychiatric Alert, to the Chief DEO and Chief Deportation Officer whenever a detainee has a condition that requires a medical clearance before release. We found that the Acting Chief DEO knew nothing about this form. The Health Services Administrator told us that no Medical Alerts had been issued since the DEO became the acting supervisor. We suggested to the District Director and the Acting OIC that PHS and INS need to improve communications on the Medical Alert process until permanent staff are selected.
C. Alien Tracking Systems
1. OIG Investigative Report Findings
According to the findings in the OIG's special investigative report, the movement of aliens was not accurately recorded and tracked in INS record systems (manual records versus computerized records). Three record-keeping systems were in use at Krome: a manual processing log, a local computer system, and the DACS.
2. Results of Follow-up Review
To discontinue unnecessary duplication between the previous local computer system and DACS, the Acting ADD-DDP informed us that she removed the local computer system software from all of the computers at Krome. The manual processing log is still being used and is considered to be the most reliable record of admissions and releases at the facility. We were told that DACS is updated immediately upon the alien's arrival and upon release from Krome. We physically observed the booking-in and booking-out process and verified this claim to be true when DACS was operable. At one point during our review, DACS was not accessible; therefore, immediate entry of detainees' data did not occur. Numerous complaints were raised by detention staff that the DACS system was "down" frequently. Further, we found notations in the processing log indicating that DACS information was not entered because the system was down.
There is a definite lack of communication between computer staff and detention staff. Computer personnel insist that DACS does not actually "go down" very often, and that detention staff simply do not know how to gain entry into the system. Detention staff agree that they could use more training, but insist the system is not available much of the time. When this occurs, the booking card information may not be entered into DACS until the next day.
We compared DACS entries to A-file and booking card information for the 28 aliens in our sample. We found three instances in which the status of release conflicted: in one case, DACS showed paroled instead of voluntary removal; in one case DACS showed paroled instead of bonded out; and in one case DACS showed released on own recognizance instead of released under Order of Supervision.
We compared DACS detention total reports for May 15, May 19, and May 28, 1997, to the totals contained in the manual processing log and found that the overall populations matched. However, when we attempted to verify the accuracy of individual arrivals and releases recorded in DACS for the period May 1 through May 31, 1997, we encountered several problems. A DACS report was specially run by Krome detention staff so that we could compare the entries to the information contained in the manual processing log. The comparison disclosed that:
505 new arrivals on the processing log were not listed on the DACS report,
26 releases on the log were not listed on the DACS report,
2 escapes on the log were not listed on the DACS report,
2 releases on the DACS report were not on the processing log, and
discrepancies existed, such as data entry differences and duplicate entries.
While on-site, we could not determine whether the DACS system is inaccurate, particularly in regard to arrivals, or if the personnel who generated the reports were not familiar with the query process and, thus, made significant errors in compiling the data.
D. Other Krome Matters
This section includes a discussion of events that have occurred at Krome in the past year that do not specifically relate to the initial OIG investigation. However, we consider them to be significant.
1. American Corrections Association (ACA) Accreditation
Staff at Krome are developing ACA policies, which will be used as standard operating procedures for the facility. As of June 12, 1997, Krome's Accreditation Manager, Krome, indicated that 36 policies had been signed, 49 had been reviewed and were awaiting signature, 53 were currently under review, and 28 were in the first stage of the drafting process. There are a total of 440 ACA standards used as guidelines to write these policies.
Of the 36 policies that have been signed, only three related to areas being addressed during our follow-up visit: (1) Medical Screening (New Arrivals), (2) Health Screenings and Examinations, and (3) Responsible Medical Authority. All three policies were signed January 29, 1997.
The medical screening policy includes areas to be covered during screening of new arrivals and requires that the screening be conducted by qualified health care personnel upon arrival at the facility. (Detailed procedures are contained in the Policies and Procedures Manual for the INS Health Services Division.) It is the PHS' responsibility to ensure that screening is completed prior to placing a detainee into the general population.
The health screening policy pertains to intrasystem transfers and requires that aliens receive a health screening upon arrival at the facility and prior to their placement in the general population. Again, only qualified health care personnel may conduct the screening.
The medical authority policy states that the Medical Facility Officer in Charge, a licensed physician, is designated the Responsible Care Authority for all health care activities conducted at the facility. Final medical judgment rests with the Responsible Health Authority.
We acknowledge Krome's effort to comply with ACA standards and undergo accreditation. However, during our visit, we were informed that the initial target date of April 1997 [ The INS Commissioner's February 20, 1997 memorandum to the Attorney General transmitting the INS Review Team's final report stated that the Krome Policies and Procedures Manual was expected to be completed by the end of April. Also, the goal for ACA accreditation was July 1, 1997.] provided to the Attorney General for completion of the Krome Policies and Procedures Manual had been unrealistic. According to Krome staff, the constant changeover in management has impeded the progress of compiling the manual.
2. Management Vacancies
As a result of the initial OIG investigation, Krome's OIC was removed from her position in August 1996. She was subsequently assigned to the Miami District Office (Detention and Deportation). Over the past year, the OIC position at Krome has been filled on a temporary basis by seven different INS employees. We were informed that the OIC job vacancy (GS-14) was formally announced, but there was only one applicant. The applicant was not selected. Further, the Deputy OIC position at Krome has been filled by temporary details of INS staff. At the Miami District Office, the Assistant District Director position for Detention and Deportation has been filled by temporary details since early 1997. On August 21, 1997, we were told that the District Director had selected an Assistant District Director for Detention and Deportation; however, the person had not yet reported for duty.
We recognize that the number of Detention Enforcement Officers and Deportation Officers on staff at Krome has almost doubled in the past year and that numerous physical improvements have been made to the facility. However, stability in managerial positions, at Krome and in the District, must be attained to ensure accountability of actions, effective long- term planning, continuity in leadership, and consistency in instructions provided to detention and deportation staff.
E. Conclusion on Krome
While we noted improvements in overcrowded conditions, the processing of juveniles, working toward ACA accreditation, and deletion of duplicate record-keeping systems, areas of concern still exist at Krome. Dangerous, convicted felons and other types of criminals continue to be released from Krome into the community. Male and female felons were not totally segregated from non-criminal male and female detainees.
Regarding record keeping, we found that some criminal history checks were not properly documented prior to the aliens' release; confusion exists among staff as to the proper designation of Medical Alerts on the booking card; and discrepancies still exist between Krome's manual processing log and the DACS.