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Report to Congressional Committees:

United States Government Accountability Office:

GAO:

February 2005:

Aviation Security:

Measures for Testing the Impact of Using Commercial Data for the Secure 
Flight Program:

GAO-05-324:

Contents:

Letter:

Appendix I: Briefing Slides:

Appendix II: Comments from the Department of Homeland Security:

Abbreviations:

DHS: Department of Homeland Security:

GAO: Government Accountability Office:

TSA: Transportation Security Administration:

United States Government Accountability Office:

Washington, DC 20548:

February 23, 2005:

Congressional Committees:

The Transportation Security Administration (TSA) is developing a new 
passenger prescreening program, known as Secure Flight. Under the 
Secure Flight program, TSA plans to take over, from commercial 
airlines, the responsibility for comparing identifying information of 
domestic airline passengers against information on known or suspected 
terrorists. TSA is also considering using commercial data as part of 
Secure Flight if the data are shown, through testing, to improve the 
results of these comparisons.[Footnote 1] In the 2005 Homeland Security 
Appropriations Act (Public Law 108-334, Section 522(d)), Congress 
mandated that, prior to testing the use of commercial data for Secure 
Flight, TSA develop measures to assess the impacts of using commercial 
data on aviation security, and that GAO review the measures. In 
response to that mandate, we reviewed TSA's measures for commercial 
data testing and briefed congressional staff on January 11, 2005, on 
our findings. This report documents the results of our review, which we 
presented in that briefing.

Currently, commercial airlines are responsible for the prescreening of 
passengers using terrorist watch lists provided by TSA, known as the no-
fly and selectee lists.[Footnote 2] However, as noted by the National 
Commission on Terrorist Attacks Upon the United States (9/11 
Commission), the watch lists used by the airlines do not include all 
terrorists or terrorism suspects because of concerns about sharing 
intelligence information with private firms and foreign 
countries.[Footnote 3] TSA expects that Secure Flight will improve 
passenger prescreening as compared with the current airline-operated 
process. For example, Secure Flight will utilize an expanded terrorist 
watch list that includes information not currently provided to air 
carriers for passenger prescreening. TSA also expects that by 
automating the prescreening process and applying consistent procedures 
for comparing passenger data against the expanded terrorist watch list, 
Secure Flight will reduce the number of false positive matches against 
the terrorist watch list as compared with the current process.

In preparing to take over passenger prescreening from domestic air 
carriers, TSA has begun initial Secure Flight testing to determine the 
ability of Secure Flight to effectively compare passenger-provided 
information contained in air carrier reservation systems against the 
expanded watch list in order to identify individuals known or 
reasonably suspected to be engaged in terrorism.[Footnote 4] TSA 
expects that results from these tests will be available in February 
2005. In addition, TSA plans to conduct a concept test to determine if 
the use of commercial data can improve the matching of passenger- 
provided information against the expanded watch list by identifying 
individuals who were incorrectly identified as being on a terrorist 
watch list (referred to as false positives) or who attempted to avoid 
detection by disguising their identity (referred to as false 
negatives).[Footnote 5] The commercial data concept test is also 
intended to determine if the accuracy of passenger-provided data 
contained in passenger records can be verified using commercial 
data.[Footnote 6] In January 2005, TSA issued a request for proposals 
in order to obtain a contractor to conduct commercial data concept 
testing. TSA expects to award the contract in late February 2005.

To determine the effectiveness of using commercial data, TSA developed 
initial measures for commercial data concept testing, such as the 
overall percentage of passenger-provided records from which identity 
can be verified using commercial data, and plans to refine the measures 
throughout the testing process. TSA expects to obtain the results of 
commercial data concept testing in April 2005. On the basis of these 
test results, the Department of Homeland Security (DHS) and TSA plan to 
make policy decisions regarding the use of commercial data as part of 
the overall Secure Flight program. TSA also plans to subsequently test 
additional functionality and the operations of Secure Flight before 
implementation, regardless of whether TSA incorporates the use of 
commercial data as part of Secure Flight.

To determine if the measures developed by TSA for commercial data 
testing are designed to identify impacts on aviation security, we 
reviewed and analyzed TSA's draft statement of work for commercial data 
concept testing, which includes the initial measures developed by TSA. 
Since the purpose of our review was to determine whether the measures 
identify impacts on aviation security, we assessed the measures against 
performance measurement criteria developed by GAO based on best 
practices.[Footnote 7] On the basis of our knowledge of the Secure 
Flight program and GAO performance measurement criteria, we determined 
whether TSA's measures are designed to reflect relevant impacts on 
aviation security and are consistent with attributes of successful 
performance measures. We also interviewed TSA officials responsible for 
Secure Flight development and oversight. The briefing slides, contained 
in appendix I, include the specific attributes that we used as criteria 
for evaluating TSA's measures, detailed information on our scope and 
methodology, and the results of our review of TSA's measures for 
commercial data testing. Appendix I also includes a list of TSA's 
initial measures for commercial data testing. We conducted our work in 
accordance with generally accepted government auditing standards from 
December 2004 to February 2005. GAO is also continuing to review TSA's 
measures for commercial data testing based on a follow-on congressional 
request.[Footnote 8]

In January 2005, we briefed your offices on the results of our review 
of TSA's measures for commercial data concept testing. In summary, we 
made the following key points in our briefing:

* TSA developed a concept test to determine the utility of using 
commercial data for Secure Flight as a first step in determining its 
impact on aviation security. The results of this test are intended to 
provide TSA the basis for refining performance measures identifying 
impacts on aviation security prior to subsequent testing, should DHS 
and TSA decide to pursue the use of commercial data.

* TSA developed initial measures for commercial data concept testing 
that are intended to provide information related to impacts on aviation 
security, including improvements in false positive and false negative 
rates. TSA, in coordination with the contractor, plans to refine these 
measures during concept testing--to include the establishment of 
performance targets--and prior to operationally testing the system, 
should DHS and TSA decide to pursue the use of commercial data.

* TSA measures developed to date for commercial data testing do not, 
and were not designed to, provide information on overall Secure Flight 
system operations (i.e., system response time, connectivity with air 
carriers, security, and privacy) or identify impacts of using 
commercial data on aviation security in an operational environment. 
Accordingly, the measures do not generally reflect attributes of 
successful performance measures for this purpose.

* Additional work reviewing TSA's refined measures, should DHS and TSA 
decide to pursue the use of commercial data for Secure Flight, would be 
needed to determine if the measures are designed to identify relevant 
impacts on aviation security, and reflect attributes of successful 
performance measures for that purpose.

We provided a draft of this report to DHS for its review and comment. 
In commenting on the draft report, DHS generally agreed with our 
findings. DHS's written comments are presented in appendix II. TSA also 
provided technical comments which we have incorporated into this report 
where appropriate.

We are sending copies of this report to the Secretary of the Department 
of Homeland Security and the Administrator of the Transportation 
Security Administration. We will also make copies available to others 
upon request. In addition, the report will be available at no charge on 
GAO's Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please 
contact me at (202) 512-3404 (berrickc@gao.gov) or Christine Fossett, 
Assistant Director, at (202) 512-2956 (fossettc@gao.gov). Other key 
contributors to this report were R. Denton Herring, Adam Hoffman, David 
Hooper, Tom Lombardi, and David Plocher.

Sincerely yours,

Signed by: 

Cathleen A. Berrick: 
Director, Homeland Security and Justice Issues:

List of Congressional Committees:

The Honorable Thad Cochran: 
Chairman: 
The Honorable Robert C. Byrd: 
Ranking Minority Member: 
Committee on Appropriations: 
United States Senate:

The Honorable Ted Stevens: 
Chairman: 
The Honorable Daniel K. Inouye: 
Ranking Minority Member: 
Committee on Commerce, Science, and Transportation: 
United States Senate:

The Honorable Jerry Lewis: 
Chairman The Honorable David R. Obey: 
Ranking Minority Member: 
Committee on Appropriations: 
House of Representatives:

The Honorable Don Young: 
Chairman: 
The Honorable James L. Oberstar: 
Ranking Minority Member: 
Committee on Transportation and Infrastructure: 
House of Representatives:

The Honorable Tom Davis: 
Chairman:
Committee on Government Reform:
House of Representatives:

The Honorable Adam H. Putnam:
House of Representatives:

[End of section]

Appendix I: Briefing Slides:

Review of TSA Measures for Secure Flight Commercial Data Testing:

Briefing for the Majority and Minority Staff of the Cognizant Senate 
and House Authorization, Appropriations, and Oversight Committees:

January 11 , 2005:

Briefing Outline:

* Background:

* Objective, Scope, and Methodology: 

* Summary:

* TSA Secure Flight Testing Approach:

* Concept Testing for Use of Commercial Data:

* Attributes of Successful Performance Measures:

* TSA Measures for Commercial Data Testing:

* List of TSA Measures for Commercial Data Testing from Draft Statement 
of Work:

Background:

The Transportation Security Administration (TSA) is developing a new 
passenger prescreening program, known as Secure Flight. Under this 
program:

* TSA will assume responsibility for checking airline passengers' names 
against no-fly and selectee lists and the Computer-Assisted Passenger 
Prescreening System (CAPPS I) rules, a task that is currently performed 
by air carriers. [NOTE 1] TSA will also check passenger names against 
an expanded terrorist watch list.

* TSA is also considering the use of commercial data (e.g., personally 
identifiable information that either identifies an individual or is 
directly attributed to an individual, such as name, address, and phone 
number) if it is shown, through testing, to be effective in mitigating 
false positives, identifying false negatives, or verifying passenger 
identification. [NOTE 2]

TSA has two testing efforts for the Secure Flight program:

* watch list/CAPPS I testing -a test to match historical passenger data 
against an expanded government watch list and CAPPS I rules.

* commercial data concept testing -a test of a methodology to determine 
if the use of commercial data can improve on the results of watch list/ 
CAPPS I testing.

At the conclusion of both tests, TSA plans to conduct additional Secure 
Flight system testing.

Objective, Scope, and Methodology:

Objective:

* Evaluate TSA measures for Secure Flight testing using commercial data 
to determine if they are designed to identify impacts on aviation 
security as required by Public Law 108-334, Section 522 (d).

Scope and Methodology:

* Reviewed TSA's draft statement of work, which includes the initial 
measures developed by TSA, and the draft request for proposals for 
commercial data concept testing, and interviewed TSA officials 
responsible for Secure Flight program development and oversight.

* Determined, on the basis of our knowledge of the Secure Flight 
program and performance measurement criteria GAO developed based on 
best practices (shown on slide 13), whether the measures are designed 
to reflect relevant impacts and whether they were prepared in 
accordance with attributes of successful performance measures.

* Utilized GAO personnel expert in performance measurement, 
contracting, and information systems development and testing issues.

* Conducted our work from December 2004 through January 2005 in 
accordance with generally accepted government auditing standards.

Summary:

* TSA developed a concept test to determine the utility of using 
commercial data for Secure Flight as a first step in determining its 
impact on aviation security. The results of this test are intended to 
provide TSA with the basis for refining performance measures that 
identify impacts on aviation security prior to subsequent testing, 
should the Department of Homeland Security (DHS) and TSA decide to 
pursue the use of commercial data.

* TSA developed initial measures for commercial data concept testing 
that are intended to provide information related to impacts on aviation 
security, including improvements in false positive and false negative 
rates. TSA, in coordination with the contractor, plans to refine these 
measures during concept testing-to include the establishment of 
performance targets-and prior to overall Secure Flight system testing, 
should DHS and TSA decide to pursue the use of commercial data.

* TSA measures developed to date for commercial data testing do not, 
and were not designed to, provide information on overall system 
operations (i.e., system response time, connectivity with air carriers, 
security, and privacy), or identify impacts of using commercial data on 
aviation security in an operational environment. Accordingly, the 
measures do not generally reflect attributes of successful performance 
measures for these purposes.

* Additional work reviewing TSA's refined measures, should DHS and TSA 
decide to pursue the use of commercial data for Secure Flight beyond 
concept testing, would be needed to determine if the measures are 
designed to identify relevant impacts on aviation security and reflect 
attributes of successful performance measures.

TSA Secure Flight Testing Approach:

TSA has two testing efforts for the Secure Flight program, as shown in 
figure 1 on the next slide:

Secure Flight test (watch list/CAPPS I):

* A test to match historical (June 2004) passenger data collected from 
air carriers against an expanded government watch list and CAPPS I 
rules.

* This test is being conducted by IBM and is expected to be completed 
in February 2005.

Commercial data test:

* TSA plans to award a contract to test the concept of using commercial 
data (concept testing). This test has two main objectives: to determine 
the value of commercial data (1) in mitigating false positives and 
identifying false negatives and (2) in verifying passenger 
identification.

* Based on the outcome of concept testing, DHS and TSA plan to make 
policy decisions regarding the use of commercial data as part of Secure 
Flight.

At the conclusion of both tests, TSA plans to award a contract in early 
March to conduct additional Secure Flight development and expects to 
commence overall system testing in early June 2005.

Figure 1: Secure Flight Testing Approach: 

[See PDF for image]

Source: GAO.

[End of figure]

Concept Testing for Use of Commercial Data:

* TSA's concept testing for the use of commercial data is limited in 
scope and purpose. TSA officials characterized this as a test of a 
methodology to determine if the use of commercial data can improve the 
results of matching passenger-provided information to the terrorist 
watch list. TSA officials said they plan to use the results of watch 
list and CAPPS I testing as the baseline for measuring improvements in 
accuracy achieved during commercial data concept testing.

* TSA officials stated that commercial data concept testing is not 
designed to provide information on overall system operations (i.e., 
system response time, connectivity with air carriers, security, and 
privacy) or identify impacts of using commercial data on aviation 
security in an operational environment.

* TSA officials stated that if DHS and TSA decide to incorporate 
commercial data as part of the Secure Flight system based on the 
results of concept testing, operational and related factors will be 
tested and measured in conjunction with overall Secure Flight system 
testing.

* TSA plans a two-phase approach for concept testing using commercial 
data:

Phase 1-the contractor will develop a testing methodology for using 
commercial data, including developing additional measures to test the 
effectiveness of commercial data to mitigate false positives, identify 
false negatives, and verify passenger identification.

Phase 2-the contractor will carry out the test methodology using June 
2004 passenger data obtained from air carriers and report results to 
TSA.

* At the conclusion of concept testing, the contractor will provide a 
separate evaluation of the costs to the government associated with 
commercial data usage. This evaluation, however, will not include costs 
to the airline industry.

* The contract period for concept testing is planned to be 6 weeks, at 
an estimated cost of $500,000.

Attributes of Successful Performance Measures:

* Sound performance measurement is important in providing decision 
makers with information on the achievement of program accomplishments, 
particularly progress toward meeting preestablished goals or targets, 
and the impacts of those accomplishments. Performance measurement 
focuses on whether a program has achieved its objectives, expressed as 
measurable performance standards.

* GAO has developed, based on prior work on performance measurement, 
nine attributes of successful performance measures, which are shown in 
table 1 on the next slide.

Table 1: Key Attributes of Successful Performance Measures:

Attributes: Linkage; 
Definitions: Measure is aligned with division and agencywide goals and 
mission and clearly communicated throughout the organization; 
Potentially adverse consequences of not meeting attribute: Behaviors 
and incentives created by measures do not support achieving division or 
agencywide goals or mission. 

Attributes: Clarity; 
Definitions: Measure is clearly stated and the name and definition are 
consistent with the methodology used to calculate it; 
Potentially adverse consequences of not meeting attribute: Data could 
be confusing and misleading to users. 

Attributes: Measurable target; 
Definitions: Measure has a numerical goal; 
Potentially adverse consequences of not meeting attribute: Can not tell 
whether performance is meeting expectations. 

Attributes: Objectivity; 
Definitions: Measure is reasonably free from significant bias or 
manipulation; 
Potentially adverse consequences of not meeting attribute: Performance 
assessments may be systematically over- or understated. 

Attributes: Reliability; 
Definitions: Measure produces the same result under similar conditions; 
Potentially adverse consequences of not meeting attribute: Reported 
performance data is inconsistent and adds uncertainty. 

Attributes: Core program activities; 
Definitions: Measures cover the activities that an entity is expected 
to perform to support the intent of the program; 
Potentially adverse consequences of not meeting attribute: Not enough 
information available in core program areas to managers and 
stakeholders. 

Attributes: Limited overlap; 
Definitions: Measure should provide new information beyond that 
provided by other measures; 
Potentially adverse consequences of not meeting attribute: Manager may 
have to sort through redundant, costly information that does not add 
value. 

Attributes: Balance; 
Definitions: Balance exists when a suite of measures ensures that an 
organization's various priorities are covered; 
Potentially adverse consequences of not meeting attribute: Lack of 
balance could create skewed incentives when measures over-emphasize 
some goals. 

Attributes: Governmentwide priorities; 
Definitions: Each measure should cover a priority such as quality, 
timeliness, and cost of service; 
Potentially adverse consequences of not meeting attribute: A program's 
overall success is at risk if all priorities are not addressed. 

Source: U.S. General Accounting Office, Tax Administration: IRS Needs 
to Further Refine Its Tax Filing Season Performance Measures, GAO-02-
143 (Washington, D.C.: Nov. 22, 2002).

[End of table]

TSA Measures for Commercial Data Testing:

* TSA has developed initial measures for commercial data concept 
testing as part of the draft statement of work. The contractor is to 
develop additional measures-to include the establishment of performance 
targets-in consultation with TSA, as part of the test methodology. (See 
slide pages 16-18 for the list of TSA measures.)

* TSA officials stated that the draft statement of work for concept 
testing was purposely designed to provide vendors with flexibility to 
leverage commercial knowledge and expertise in developing proposals and 
identifying additional measures.

* According to TSA officials, measures for concept testing are intended 
to provide quantitative data that will be used to make policy decisions 
regarding the use of commercial data as part of the Secure Flight 
system.

* TSA's initial measures for concept testing are intended to provide 
information related to impacts on aviation security, including 
improvements in false positive and false negative rates. TSA, in 
coordination with the contractor, plans to refine these measures during 
concept testing and prior to Secure Flight system testing, should DHS 
and TSA decide to pursue the use of commercial data.

* Because of the scope of concept testing, TSA measures developed to 
date do not identify impacts of using commercial data on aviation 
security in an operational environment. Accordingly, the measures do 
not generally reflect attributes of successful performance measures for 
this purpose.

* Additional work reviewing the refined measures, should DHS and TSA 
decide to pursue the use of commercial data for the Secure Flight 
System beyond concept testing, would be needed to determine if they are 
designed to identify relevant impacts on aviation security and reflect 
attributes of successful performance measures.

TSA Measures for Commercial Data Testing from Draft Statement of Work:

Identity verification measures:

* confidence percentage, or likelihood, of verification, and which 
characteristics (individually or in combination) best supported 
verification;

* confidence percentage, or likelihood, of accuracy during verification;

* overall percentage of records on which identity can be verified;

* description of criteria for passenger non-verification, reasons for 
ambiguity (e.g., missing specific information, incorrect information);

* percentage of records meeting the criteria for non-verification;

* distinguishing characteristics of non-verified identities to ensure 
fair handling and to ensure profiling is not used;

* commonalities among false positives mitigated and commonalities 
between false positives not mitigated;

* indicators that prove or disprove identity;

* record data elements that provide the most value for matching to 
commercial data for identity validation;

* percentage of records that contained the data characteristics that 
best supported verification; and:

* average verification rates using passenger data as compared to 
industrv standards.

False positive reduction and false negative identification measures:

* percentage of positives matches against the watch list determined to 
be false positives (mitigated) by using commercial data to amplify 
passenger-supplied information;

* augment sets of records determined to be false positives with 
commercial data. Provide the enhanced records to the government to re- 
run though the Secure Flight Platform to determine whether the 
additional information was effective in avoiding false positive matches 
against the watch list; and:

* percentage of positives against the watch list that could neither be 
confirmed as a positive match or eliminated as false positives through 
the commercial data amplification process that remained false positives;

* determine what information would have been required to finally clear 
those positive matches that could not be confirmed or eliminated after 
amplification;

* record data elements that provide the most value for the mitigation 
of false positives;

* augment sets of records determined to be cleared (no match against 
the watch list) with commercial data. Provide this information to the 
government to re-run on the Secure Flight Test Platform to determine if 
the addition of commercial data resulted in watch list matches not 
previously identified (false negatives).

Cost evaluation measures:

* total cost to deploy identity verification;

* unit cost per identity verified;

* total cost to deploy false positive watch list match reduction (or 
false negative match identification);

* unit cost per false positive reduced;

* total cost of identity verification and false positive reduction (or 
false negative identification); and:

* unit cost of identity verification and false positive reduction.

NOTES: 

[1] CAPPS I rules are behavioral characteristics used to select 
passengers who require additional security scrutiny at airport security 
checkpoints.

[2] A false positive is an individual who was misidentified as a 
positive match when matching passenger data against a terrorist watch 
list. A false negative is an individual on a terrorist watch list who 
avoids detection when passenger data are matched against a terrorist 
watch list by disguising his or her true identity. 

[End of slide presentation] 

[End of section]

Appendix II: Comments from the Department of Homeland Security:

U.S. Department of Homeland Security: 
Washington, DC 20528:

February 11, 2005:

Ms. Cathleen A. Berrick:
Director, Homeland Security and Justice Issues: 
U.S. Government Accountability Office:
441 G Street, NW: 
Washington, D.C. 20548:

Dear Ms. Berrick:

Thank you for the opportunity to comment on GAO's draft report 
entitled, "Measures for Testing the Impact of Using Commercial Data for 
the Secure Flight Program," GAO-05-324. TSA generally concurs with this 
initial report and looks forward to continued cooperation with GAO 
throughout the Secure Flight Program development process. TSA is 
confident Secure Flight will meet our goals of improving the security 
of domestic air travelers and reducing passenger airport screening time 
while protecting privacy and civil liberties.

In the 2005 Homeland Security Appropriations Act Congress mandated that 
prior to testing, TSA develop measures to assess the impact of using 
commercial data on aviation security and that GAO review those measures 
before TSA tests commercial data (P.L. 108-334). TSA is complying with 
this directive, and has designed and will continue to refine these 
measures as it prepares to initiate testing - subject to GAO review and 
Congressional notification. As GAO described, in addition to the Secure 
Flight test using watch list information and CAPPS I rules, TSA is 
planning two phases of concept testing for the use of commercial data. 
The results of the tests will be used to determine the potential cost, 
feasibility, and effectiveness of using commercial data for Secure 
Flight. These tests are scheduled to begin in late February or early 
March. Following completion of this testing, policy decisions regarding 
whether and to what extent commercial data will be utilized in Secure 
Flight will be made.

As the GAO recognized, the measures in this report are designed to 
evaluate the effectiveness of using commercial data within a test 
environment. TSA recognizes that additional Congressional review will 
be required once the results of the commercial data tests become 
available. However, it is important to emphasize the clear distinction 
between the effectiveness testing currently underway, and the 
operational testing that can only be done later in the program 
development process. Until connectivity with the airlines is 
established, operational testing is not feasible. Consequently, many 
questions relating to operational effectiveness will necessarily remain 
unanswered until after the conclusion of testing.

Thank you again and we look forward to continued cooperation with the 
GAO on your reporting requirements for the House and Senate 
Appropriations Committees per P.L. 108.334 and any further reporting 
requested.

Sincerely,

Signed by: 

Steven J. Pecinovsky:

Acting Director, 
Departmental GAO/IG Liaison: 
Office of the Chief Financial Officer: 

[End of section]

FOOTNOTES

[1] Commercial data are maintained by private companies and can include 
personally identifiable information that either identifies an 
individual or is directly attributed to an individual, such as name, 
address, and phone number. 

[2] To conduct passenger prescreening, airlines also compare passenger 
data against the Computer-Assisted Passenger Prescreening System (CAPPS 
I) rules, which are behavioral characteristics associated with the way 
an airline ticket is purchased. The CAPPS I rules are intended to 
identify individuals who should receive additional security scrutiny.

[3] The 9/11 Commission Report: Final Report of the National Commission 
on Terrorist Attacks Upon the United States (Washington, D.C.: July 
2004).

[4] These reservation systems contain detailed information about an 
individual's travel on a particular flight, including information 
provided by the passenger when making a flight reservation. Such 
information can include (1) passenger name, (2) reservation date, (3) 
travel agency or agent, (4) travel itinerary information, (5) form of 
payment, (6) flight number, and (7) seating location.

[5] The purpose of the concept test is limited to identifying the 
utility of using commercial data in improving the effectiveness of 
comparing passenger information against the terrorist watch list in a 
test environment. 

[6] To obtain data for Secure Flight testing, TSA issued an order in 
November 2004 requiring domestic airlines to provide passenger records 
for the month of June 2004. 

[7] Performance measurement is used to provide information on the 
achievement of program accomplishments, particularly progress toward 
meeting preestablished goals or targets, and the impacts of those 
accomplishments.

[8] TSA's final statement of work for commercial data testing, issued 
subsequent to our briefing, includes a revised set of measures for the 
use of commercial data. We will assess these revised measures as part 
of our follow-on review of TSA's commercial data test.

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