Monitoring Foreign Students in the United States: The Student and Exchange Visitor Information System (SEVIS)

CRS Report for Congress
Monitoring Foreign Students
in the United States:
The Student and Exchange
Visitor Information System (SEVIS)
Updated January 24, 2006
Alison Siskin
Analyst in Social Legislation
Domestic Social Policy Division

Congressional Research Service ˜ The Library of Congress

Monitoring Foreign Students in the United States:
The Student and Exchange Visitor
Information System (SEVIS)
Summary
There has been increased interest in monitoring foreign students while
maintaining the long tradition of permitting international scholars to study in the
United States. There are three main avenues for students from other countries to
temporarily come to the United States to study, and each involves admission as a
nonimmigrant. The three visa categories used by foreign students are: F visas for
academic study; M visas for vocational study; and J visas for cultural exchange.
Recently, the Department of Homeland Security (DHS) implemented an electronic
foreign student monitoring system.
When Congress enacted the Illegal Immigration Reform and Immigrant
Responsibility Act (IIRIRA) of 1996, it added statutory language mandating that the
Attorney General, in consultation with the Secretaries of State and Education,
develop by January 1, 1998, a program to collect data on foreign students from at
least five countries, and mandated that by 2003, the data collection include all
countries. IIRIRA required the former Immigration and Naturalization Service (INS)
to collect the information electronically “where practical.” The USA Patriot Act of
2001 included provisions to expand the foreign student tracking system and
authorized appropriations for the system, which was supposed to be funded through
fees, paid by the students. The Enhanced Border Security and Visa Entry Reform Act
of 2002 increased monitoring of foreign students and closed perceived loopholes.
The foreign student monitoring system created by the former INS, and mandated
in IIRIRA, is referred to as the Student and Exchange Visitor Information System
(SEVIS). SEVIS, which automated an existing manual data collection process,
became operational for all incoming students on February 15, 2003, the deadline for
all institutions which had previously been approved to admit foreign students to
apply for SEVIS certification and enter all new students into the SEVIS system. The
educational institutions were given until August 1, 2003 to enter all continuing
students into the system, and to have their SEVIS certification completed. Currently,
there are 599,617 active students in SEVIS.
There have been few stories in the press of foreign students having problems
entering the United States as a result of the implementation of SEVIS. Nonetheless,
schools have reported technical difficulties operating SEVIS, and reported
discrepancies between information received from different bureaus in DHS regarding
SEVIS operations and requirements. Additionally, some have noted delays in student
visa processing. Prior to the implementation of SEVIS it was difficult to know when
foreign students overstayed their visas. Through SEVIS, DHS should be able to
identify students who have violated the terms of their visas; however, some question
whether DHS has the staff to locate all student visa violators, and whether it is a
beneficial use of DHS resources to do so. Others are concerned that clerical errors
will lead to unwarranted enforcement actions. This report will be updated as needed.

Contents
Background ......................................................1
Legislative History of the Student Monitoring System.....................1
Illegal Immigration Reform and Immigrant Responsibility Act..........1
The USA Patriot Act...........................................2
Enhanced Border Security and Visa Reform Act......................2
Student and Exchange Visitor Information System (SEVIS)................3
Fee Collection................................................3
Admissions and Tracking Process.................................4
Issues .......................................................5
Management of SEVIS.....................................5
Technical Support.........................................6
Reporting Burdens.........................................6
Followup on Overstays.....................................7
Fee Collection............................................7
Delays in Visa Issuances....................................7

Monitoring Foreign Students in the United
States: The Student and Exchange
Visitor Information System (SEVIS)
Background
Since the Immigration Act of 1924, the United States has expressly permitted
foreign students to study in U.S. institutions. There are three main avenues for
students from other countries to temporarily come to the United States to study, and
each involves admission as a nonimmigrant. The three visa categories used by
foreign students are: F visas for academic study; M visas for vocational study; and
J visas for cultural exchange. While most nonimmigrants are admitted with visas
that have a precise expiration date, foreign postsecondary students are admitted for
“duration of status,” which lasts as long as they are full-time students or participating
according to the terms of their exchange programs.¹
Legislative History of the Student Monitoring
System
Illegal Immigration Reform and Immigrant Responsibility Act
When Congress enacted the Illegal Immigration Reform and Immigrant
Responsibility Act (IIRIRA) of 1996, it added statutory language mandating that the
Attorney General, in consultation with the Secretaries of State and Education,
develop by January 1, 1998, a program to collect the following data on foreign
students from at least five countries:
^!identity and address of the alien;
^!nonimmigrant classification of the alien (i.e., F, J, or M
classification), date of visa issuance, and any change or extension;
^!academic status of the alien (e.g., full-time enrollment); and
^!any disciplinary action taken by the school, college, or university as
a result of a crime committed by the alien.

¹ Parts of this report are taken from CRS Report RL31146, Foreign Students in the United
States: Policies and Legislation, by Ruth Ellen Wasem.

The law mandated that the data collection be extended to include all countries by
2003. IIRIRA required the former Immigration and Naturalization Service (INS)² to
collect the information electronically “where practical.” It also mandated that
educational institutions report this information to INS as a condition of continued
approval to enroll foreign students. In addition, the law required, as of April 1, 1997,
that the educational institutions collect a fee (not to exceed $100) from each of the
foreign students to remit to the Attorney General to carry out the program. The 106^th
Congress amended this provision so that the INS rather then the institutions would
collect the fee (P.L. 106-396).³
The USA Patriot Act
The USA Patriot Act (P.L. 107-56) included provisions to expand the foreign
student tracking system and authorized $36.8 million in appropriations for the foreign
student monitoring system. It also required that by January 1, 2003, the INS was to
have the foreign student tracking system established by §641 of IIRIRA fully
operational. The act required the Attorney General, in consultation with the
Secretary of State, to include information on the date of entry and port of entry on
every foreign student. The act also expanded the foreign student tracking system to
include “other approved educational institutions” such as air flight schools, language
training schools, or vocational schools approved by the Attorney General, in
consultation with the Secretaries of State and Education.
Enhanced Border Security and Visa Reform Act
The Enhanced Border Security and Visa Reform Act of 2002 (P.L. 107-173)
further strengthened the foreign student tracking system by establishing electronic
means to monitor and verify:
^!documentation of acceptance of student by approved school or
designated exchange program;
^!transmittal of documentation to the Department of State (DOS);
^!issuance of nonimmigrant visa to student or exchange visitor;
^!admission of student or exchange visitor to the U.S.;
^!notice to school or exchange program that nonimmigrant has been
admitted to the U.S.;
^!registration and enrollment of nonimmigrant in school or exchange
program; and

² The Homeland Security Act of 2002 (P.L. 107-296) abolished the Immigration and
Naturalization Service (INS) and transferred most of its functions to various bureaus in the
new Department of Homeland Security (DHS) effective Mar. 1, 2003. The Bureau of
Immigration and Customs Enforcement (ICE) within DHS is charged with maintaining the
foreign student tracking system.
³ Reportedly, the fee was not collected until Sept. 1, 2004.

^!any other relevant act by the nonimmigrant, including changing
schools or programs.⁴
Student and Exchange Visitor Information System
(SEVIS)
The foreign student monitoring system created by the INS is referred to as the
Student and Exchange Visitor Information System (SEVIS).⁵ SEVIS automated an
existing manual data collection process. INS issued a final rule regarding the
retention and reporting of information regarding foreign students on December 11,
2002. The December 11, 2002 regulation implemented SEVIS, establishing a
process for the electronic reporting of information on foreign students. SEVIS
became operational for all incoming students on February 15, 2003, the deadline for
all institutions which had previously been approved to admit foreign students to
apply for SEVIS certification⁶ and enter all new students into the SEVIS system.⁷ On
May 23, 2003, DHS issued an interim regulation, effective on the same date,
amending previous regulations dealing with foreign students and establishing the
verification and reporting procedures required for SEVIS.⁸ The educational
institutions were given until August 1, 2003, the same day in which all schools were
required to have their SEVIS certification completed, to enter all continuing students
into the system.
Fee Collection
IIRIRA required, as of April 1, 1997, that the educational institutions collect a
fee (not to exceed $100) from each foreign student to remit to the Attorney General
to carry out the program. On December 21, 1999, INS published a proposed
regulation regarding the collection of the fee by schools and remittance of the fees

⁴ For further discussion and analysis, see CRS Report RL31146, Foreign Students in the
United States: Policies and Legislation, by Ruth Ellen Wasem.
⁵ From June 1997 to Oct. 1999, the INS conducted the first pilot program known as the
Coordinated Interagency Partnership Regulating International Students (CIPRIS) at 21
educational institutions in Georgia, Alabama, North Carolina, and South Carolina, at
Atlanta’s Hartsfield Airport, and at the Texas Service Processing Center. In July 2001, the
INS announced that the second phase of its foreign student monitoring system, referred to
as the Student and Exchange Visitor Information System (SEVIS), would begin at 12 Boston
area institutions in Nov. 2001.
⁶ Prior to the implementation of SEVIS, schools that wished to enroll foreign students had
to seek approval from DHS. Certification to enroll in SEVIS now functions as approval to
admit foreign students. The rules for certification are codified in 8 CFR §214.3. Institutions
which admitted foreign students prior to the creation of SEVIS were required to apply for
SEVIS certification. At this time, schools not certified to enroll in SEVIS cannot accept
foreign students.
⁷ Federal Register, vol. 67, no. 283, Dec. 11, 2002, pp. 76256-76280; Federal Register, vol.

68, no. 100, May 23, 2003, p. 28129.

⁸ Federal Register, vol. 68, no. 100, May 23, 2003, pp. 28129-28132.

to the Attorney General.⁹ INS received 4,617 comments on the regulation, the
majority of which responded that fee collection for a governmental agency was not
an appropriate activity for academic institutions. The 106^th Congress amended the
fee provision in IIRIRA so that INS rather than the institutions would collect the fee
(P.L. 106-396). Interim regulations on fee collection were issued on October 27,
2003,¹⁰ and the final regulation was issued on July 1, 2004.¹¹ The regulation specifies
that the fee is to be $100,¹² and can be paid electronically with a credit card, or by
mail with a check or money order drawn on a U.S. bank and payable in U.S. dollars.¹³
Since September 1, 2004, fees for the SEVIS program have been collected from
potential foreign students (i.e., those applying for student visas, or to change their
nonimmigrant status to students). The fee is not being collected from those who have
already been issued a student visa. The operating budget for SEVIS comes from the
fee collection.¹⁴
Admissions and Tracking Process
Foreign students who wish to study in the United States must first apply to a
SEVIS certified school. Once the student is admitted, the school enters the student’s
name and identifying information into the SEVIS system.¹⁵ The foreign student may
then apply for a student visa with the United States Embassy or Consulate in their
home country.¹⁶ The consular officer then enters the visa information into SEVIS,
confirming that the student is in the SEVIS database. The consular officer also
checks the prospective student against other databases to ascertain whether the
student is eligible for a visa (i.e., the prospective student is not a security risk, does
not have criminal record, or any other issue which would render the prospective
student inadmissible to the United States under the Immigration and Nationality
Act).¹⁷

⁹ Federal Register, vol 64, no. 244, Dec. 21, 1999, pp. 71323-71331.
¹⁰ Federal Register, vol. 68, no. 207, Oct. 27, 2003, pp. 61148-61157.
¹¹ Federal Register, vol. 69, no. 126, July 1, 2004, pp. 39814-19827.
¹² Applicants for J-1 visas who work as au pairs, camp counselors, or participants in summer
work travel programs are subject to a reduced fee of $35, while J-1 visa holders who are
visitors in an exchange program sponsored by the federal government are exempt from
paying the fee. IIRIRA §431(e) as amended by §110 of P.L. 106-553 (signed into law on
Dec. 21, 2000).
¹³ This regulation also exempts from paying the fee aliens who paid the SEVIS fee, but their
original visa application was denied, if they reapply for a student visa within nine months.
¹⁴ Prior to the fee collection, the operating budget for SEVIS came from general DHS/INS
appropriations. Congress only appropriated funds specifically for SEVIS in FY2002.
¹⁵ This process generates an I-20 form (Certificate of Eligibility for Nonimmigrant Student
Status) which is generated by the SEVIS computer program.
¹⁶ A visa may only be issued within 90 days of the course of study registration date.
Applications received more than 90 days in advance are held until a visa can be issued.
¹⁷ For more information on the role of consular officers in determining eligibility for
nonimmigrant visas see CRS Report RL31381, U.S. Immigration Policy on Temporary
(continued...)

When the student arrives at a port of entry in the United States, an immigration
inspector confirms that the student has a record in the SEVIS database, and enters the
student’s arrival into the SEVIS database. The schools are then responsible, 30 days
after the start of the academic term, to note in the SEVIS system if the student has
shown up for class, and the course of study being pursued. The school has an
ongoing responsibility to report any change in the student’s status (i.e., expulsion,
suspension, change in major, graduation) in SEVIS. Schools are also required to
provide information on people who have derivative status (such as a student’s spouse
or child) on a student’s visa.
Issues
Management of SEVIS. Congress has held several hearings on SEVIS.¹⁸
Although no hearings have been held after the full implementation of SEVIS, many
of the issues raised during the hearings seem to remain. There are reportedly issues
with SEVIS that stem from the abolition of INS and the division of many of its
functions into three components in DHS — the Bureau of Citizenship and
Immigration Services (USCIS), the Bureau of Immigration and Customs
Enforcement (ICE), and the Bureau of Customs and Border Protection (CBP).
SEVIS was developed by the INS’ Immigration Services Division which is now part
of USCIS, but responsibility for SEVIS was placed in ICE. Reportedly, as of
November 1, 2003, all SEVIS responsibilities have been transferred to ICE.
Specifically, ICE is responsible for maintaining the SEVIS database, SEVIS policy,
and certifying schools. Nonetheless, schools have reported discrepancies between
information received from USCIS and ICE regarding SEVIS operations and
requirements. The lack of consistent information and guidance has reportedly led to
some frustration, but the consistency of information may improve now that all SEVIS
functions are concentrated in one bureau. Others have noted problems with
inexperienced staff in the new DHS, and the difficulty of people at the district levels
(who are under USCIS and with whom the schools have the most contact) in getting
information from ICE.¹⁹

¹⁷ (...continued)
Admissions, by Ruth Ellen Wasem. For more information on specific databases (such as
TIPOFF and CLASS) which are used by consular officers to aid in determining an
applicant’s eligibility for a visa see CRS Report RL31019, Terrorism: Automated Lookout
Systems and Border Security Options and Issues, by William J. Krouse and Raphael F. Perl.
¹⁸ For example, House Committee on Science, Dealing with Foreign Students and Scholars
in the Age of Terrorism: Visa Backlogs and Tracking Systems, Mar. 26, 2003; House
Subcommittee on Immigration, Border Security, and Claims, Nonimmigrant Student
Tracking: Implementation and Proposed Modifications, hearing, Apr. 2, 2003; House
Subcommittee on Infrastructure and Border Security, Balancing Security and Commerce,
hearing, June 13, 2003.
¹⁹ Conversation with Victor Johnson, of NAFSA, Association of International Educators,
Nov. 20, 2003. (Hereafter cited as Conversation with Victor Johnson.)

Nonetheless, there have been few stories in the press of foreign students having
problems entering the United States as a result of the implementation of SEVIS.²⁰
Possibly one reason is that, to aid in the transition to SEVIS, DHS established a
SEVIS Response Team to work with inspectors, schools and students to resolve
issues and problems related to student admissions to the United States.²¹ In fact,
some have praised DHS’ responsiveness to issues raised by the schools.²²
Technical Support. In addition, Johnny N. Williams, Interim Director,
Immigration Interior Enforcement at ICE, testified that since SEVIS is a new system
that was developed and deployed under an aggressive schedule, that he could not
guarantee that there would not be technical problems with the system, but that the
department would work quickly to address the problems.²³ Indeed, as predicted,
schools have reported technical difficulties operating SEVIS, and noted that to
circumvent some of the technical problems, they need to create incorrect records.²⁴
Other concerns have been expressed about the fact that SEVIS system information
is kept by record number and not names. Some students have more than one record
and this can make it difficult to update the database, and possibly cause issues when
and if SEVIS becomes part of U.S. VISIT, DHS’ automated entry/exit system.
Reporting Burdens. Additionally, some contend that SEVIS has placed an
added burden on schools, as they are now responsible for noting in the SEVIS system
changes of those accompanying the students such as spouses and children. They are
required to report on people who are not enrolled in their institutions.
Schools are required to note in SEVIS when a student has entered the country,
but has not shown up for classes. Thus, schools are supposed to be notified when a
student enters at a port of entry (POE), but, reportedly, this does not always happen.

²⁰ For examples of stories see “Student Tracking System a Bear,” Times Union (Albany,
NY), Sept. 4, 2003, p. B3; Susanne Gamboa, “Nearly 200 Who Tried to Enter U.S. on
Student Visas Turned Away,” Associated Press, Sept. 9, 2003; and Kendra Hamilton,
“Spending Time on SEVIS,” Black Issues in Higher Education, vol. 20, no. 15, Sept. 11,
2003, pp. 24-26. Asa Hutchinson, the Undersecretary for BTS, reported that one of the
cases turned away led the agency to investigate a possible conspiracy to bring people
illegally to the United States. See Asa Hutchinson, “190 Missing from Database Turned
Away,” Milwaukee Journal Sentinel, Sept. 10, 2003, p. A4.
²¹ Jill Drury, Director, SEVIS Program Office, Bureau of Immigration and Customs
Enforcement, Memorandum for All Academic Institutions that Admit Foreign Students, July

25, 2003.

²² Conversation with Victor Johnson.
²³ Technical difficulties have included bleeding — the unintended merging of data from one
school to another, intermittent inability of schools to access the system, inability of schools
to use the batch mode of data entry, inability to alphabetize entries, and problems with real-
time access. Johnny N. Williams, Interim Director, Immigration Interior Enforcement,
Bureau of Immigration and Customs Enforcement, and David Ward, President, American
Council on Education, Testimony before the House Subcommittee on Immigration, Border
Security, and Claims, Nonimmigrant Student Tracking: Implementation and Proposed
Modifications, hearing, Apr. 2, 2003.
²⁴ Conversation with Victor Johnson.

As a result, schools are worried about sanctions that may be applied if they do not
report a student who failed to attend classes, and who the school was unaware had
entered the country.²⁵
Followup on Overstays. Furthermore, prior to the implementation of
SEVIS it was difficult to know when foreign students overstayed their visas, because
the visas lack a fixed termination date and schools, although required to report
students who stopped attending, were not required to systematically report data on
the progress of each foreign student. Through SEVIS, DHS should be able to
identify students who have violated the terms of their visas;²⁶ however, some have
questioned whether DHS has the staff to locate all student visa violators, and whether
it is a beneficial use of DHS resources to do so. There are also concerns that SEVIS
errors will lead to unwarranted enforcement action taken against innocent students.
Fee Collection. Concerns have been raised about the methods available for
students to pay the SEVIS fee, specifically that it may be difficult for some foreign
students to pay the fee in either of the prescribed manners: electronically with a credit
card, or by mail with a check or money order drawn on a U.S. bank and payable in
U.S. dollars. DHS addressed this issue in the regulation contending that the fee
payment rules will not be much of a burden on students as most have already made
similar types of payments to apply to schools, and to take standardized tests that are
sometimes required for admission. DHS also noted that many foreign banks are able
to issue checks or money orders drawn on U.S. banks. In addition, DHS said that it
will accept payment from a third party and will explore other payment possibilities
in the future including conducting a pilot program with DOS to collect the fee at
consular offices.²⁷ Furthermore, some are concerned that the fee is excessive and will
discourage students from studying in the United States. Others note that immigration
services are supported by fees, not by appropriations, and that the foreign students,
not the taxpayers, should be responsible for funding SEVIS. DHS contends that it
studied the fee issue, and will reexamine the fee every two years to determine if the
fee amount is appropriate.²⁸
Delays in Visa Issuances. Lastly, one issue tangentially related to SEVIS,²⁹
which has been receiving interest, is reports of delays in issuing student visas.
Nonetheless, the delays appear to be the result of increased screening by DOS

²⁵ Ibid.
²⁶ Johnny N. Williams, Testimony, Nonimmigrant Student Tracking, Apr. 2, 2003.
²⁷ Federal Register, vol. 69, no. 126, July 1, 2004, p. 39817. Some groups, such as NAFSA:
Association of International Educators, have suggested having the Department of State
(DOS) collect the fee at the same time that the fee for the visa application is collected.
Others contend that this would cause an extra burden on DOS and would be an added cost
for those whose visa applications were not approved.
²⁸ Federal Register, vol. 69, no. 126, July 1, 2004, p. 39816.
²⁹ For examples see Jaime Swanson, “In the Dark: Foreign Students May Have to Wait
Months for Visas,” Northern Star, Sept. 22, 2003, p. A4; Eric Rowley, “International
Students, Faculty Have Long Delays for Visas,” Iowa State Daily, p. A1.

consular officers and not the implementation of SEVIS. In May 2003, DOS released
a notice on the current visa processing situation which stated:
Responding to the attacks of September 11, 2001,...[v]isa applications are now
subject to a greater degree of scrutiny than in the past. For many applicants, a
personal appearance interview is required as a standard part of visa processing.
Additionally, applicants affected by these procedures are informed of the need
for additional screening at the time they submit their applications and are being
advised to expect delays. The time needed for adjudication of individual cases³⁰
will continue to be difficult to predict.
For example, the Government Accountability Office (GAO) released a study
examining the length of time for a science student or scholar from a foreign country³¹
to get a visa. GAO found that DOS is unable to easily identify the amount of time
that it takes to process visas for science students or scholars, and that the time it takes
to adjudicate a visa depends largely on whether the applicant has to undergo a Visa
Mantis check. Visa Mantis is a type of specialized clearance procedure, known as the
security advisory opinion (SAO) used to screen visa applicants for employment or
study that would give the foreign national access to controlled technologies, e.g.,³²
those that could be used to upgrade military capabilities. GAO examined a random
sample of Visa Mantis cases for science students or scholars sent from U.S. consular
posts between April and June 2003, and found it took an average of 67 days for the
security check to be processed. In September 2003, GAO visited posts in China,
India, and Russia and found many Visas Mantis cases that had been pending 60 days
or more.
DOS responded to the GAO study and noted that a backlog did occur in the³³
summer of 2002 when DOS mandated a response to all SAO requests, including
Visa Mantis checks. That requirement, combined with the sudden increase in
requests for SAO’s following the attacks of September 11, 2001, overburdened the
system. DOS contends new processes have solved many of the problems³⁴

encountered during the start-up period.
³⁰ Notice on Current Visa Processing Situation available at [http://www.travel.state.gov/
specialnotice.html ].
³¹ U.S. Government Accountability Office, Border Security: Improvements Needed to
Reduce Time Taken to Adjudicate Visas for Science Students and Scholars, GAO-04-371,
Feb. 2004.
³² U.S. Government Accountability Office, Export Controls: Department of Commerce
Controls Over Transfers of Technology to Foreign Nationals Needs Improvement, GAO-02-

972, Sept. 2002.

³³ Prior to that time, posts were often only notified if the background check revealed
something negative about the applicant. If posts had not received information on an
applicant’s SAO after 60 days, the post assumed that the applicant was cleared.
³⁴ Testimony of Deputy Assistant Secretary of State for Visa Services Janice L. Jacobs, in
U.S. Congress, House of Representatives Committee on Science, The Conflict Between^th^nd
Science and Security in Visa Policy: Status and Next Steps, hearings, 108 Cong., 2 sess.,
(Feb. 25, 2004). (Hereafter cited as Testimony, Janice L. Jacobs.)

In addition, new regulations, implemented on July 7, 2003, which limited the
ability of consular officers to waive the personal appearance for nonimmigrant visa
applicants,³⁵ have increased the wait time for an interview and may extend the visa
processing time of students seeking to come to the United States. Other factors
including the biometric visa program and staffing levels have also been cited as
affecting visa processing times.³⁶ Nonetheless, DOS has instructed all visa-
adjudicating posts to make special arrangements to facilitate visa interviews for
students and researchers, and some posts reserve appointment slots for students, or
assign specific days to student processing.

³⁵ Personal interviews are generally required for foreign nationals seeking nonimmigrant
visas. Interviews, however, may be waived in certain cases. Prior to the Sept. 11, 2001,
terrorist attacks, personal interviews for applicants for visitor visas reportedly were often
waived. Under the current regulation, personal interview waivers may be granted only to
children under age 16, persons 60 years or older, diplomats and representatives of
international organizations, aliens who are renewing a visa they obtained within the prior
12 months, and individual cases for whom a waiver is warranted for national security or
unusual circumstances. Federal Register, vol. 68, no. 129, July 7, 2003, pp. 40127-40129.

22 CFR §41.102.

³⁶ By Oct. 2004, all visas issued by the United States must use biometric identifiers (e.g.,
finger scans) in addition to the photograph that has been collected for some time.
Testimony, Janice L. Jacobs.