The auditor general is weighing up whether to look into Immigration New Zealand's operations and restructure.
The MBIE business unit underwent two major overhauls as well as a change to its senior management structure.
A spokesman for the auditor general said it carried out a performance audit into Immigration New Zealand's changed programme in 2017.
"We generally follow up on recommendations from much of our performance audit work at least a couple of years afterwards," he said. "We are currently considering what follow-up work we might do on this specific matter. No decision has been made at this time."
Its 2017 report, evaluating Immigration New Zealand's $108m Vision 2015, said the agency needed to spell out the benefits and outcomes it envisaged, including those for the tourism industry and labour market.
Since then, those sectors and the international education industry have suffered a loss of millions of dollars as a result of visa processing delays.
Immigration lawyer Richard Small said it was high time for another look at Immigration New Zealand, which had since undergone an accelerated restructure.
The auditor general's office told him it had to priortise and focus on the big issues, he said.
"How on earth could they think that immigration wasn't a big issue, which other department has closed 13 out of 18 offices, which other department's been through that proportion of restructure [without] routine checks by the auditor general?
"Everything has come off right at the point, it seems that immigration jumped over the cliff in 2017, there's been no review of their forecasting by the auditor general and yet the routine stuff, all the way up to that was monitored," he said.
"If you're the statutory regulator, I think it's quite energy intensive to take on Immigration New Zealand."
He said he accepted that regulators had other genuine priorities, and they probably made a pragmatic call about whether they would get bang for their buck.
"And they probably look at immigration and say this is a highly politicised area, we need to be very careful before we dabble in it and I suspect that MBIE pushed back as no others pushed back.
"I'm not saying that in the direct way that there's influence, but I am saying that like the Ombudsman's office has done and mostly withdrawn from immigration that there is a pragmatic kind of thinking 'well are we going to make any real headway here?'
"Even if it didn't, objectively, I would like to hear them articulate why closing 13 out of 18 offices, acknowledging in Radio New Zealand and other media that they got the forecast wrong and unprecedented delays in accessing services, aren't objectively reasons the auditor general shouldn't at least do a routine review of the restructure."
Immigration New Zealand was approached for comment about its implementation of the auditor general's recommendations and whether it would welcome a further review.
Its general manager of enablement Stephen Dunstan said: "The Vision 2015 Programme was a large-scale business transformation project. The programme delivered, through a mix of technology and process change, modern, fit-for-purpose visa and identity management systems which are flexible, secure and more applicant-friendly.
"The Vision 2015 Programme subsequently enabled the Visa Services 2020 project which has reduced INZ's global footprint and moved more visa processing onshore. In addition, Visa Services 2020 has realised $11.9m in benefits so far and is expected to provide further financial benefits in terms of savings in 2019-20 and following years."