Department of Homeland Security 

Office of Inspector General 

The United States Coast Guard's 


Program for Identifying 


High Interest Vessels 


OIG-09-107 September 2009 


OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

In the aftermath of September 11, 2001, the U.S. Coast Guard established 

the High Interest Vessel Program as part of a larger, multifaceted effort to 

improve its ability to identify and respond to vessels, cargoes, and crews 

that might pose security risks to the United States. The purpose of our 

review was to determine whether improvements can be made to the 

application and oversight of the risk-based scoring matrix used by Coast 

Guard Sectors to identify high interest vessels that could pose security 

risks to the United States. 

The Coast Guard needs to take steps to ensure that its scoring matrix is 

being used as intended to identify high interest vessels. Sector personnel 

are not consistently interpreting the guidance for completing the scoring 

matrix, resulting in inaccurate vessel scores, and the Coast Guard’s 

oversight of matrix scoring could be improved to further reduce matrix 

reporting errors. Further, the Coast Guard Sectors do not consistently 

archive the scoring data, which could be used to assess implementation of 

the matrix and identify areas for improvement. Without an effective 

mechanism to evaluate program performance, the Coast Guard does not 

have adequate assurance that the layer of security provided by the 

identification of high interest vessels is operating effectively and that 

resources are appropriately used to board vessels posing the highest risks 

to national security. 

We made three recommendations to the Coast Guard to improve the 

application and oversight of the scoring matrix process for identifying 

high risk vessels. In response to our report, the Coast Guard concurred 

with our recommendations. We have incorporated the Coast Guard’s 

response to our recommendations in Appendix B. 

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Background 

Federal regulations require all U.S. and foreign flag commercial vessels 

greater than 300 gross tons, all vessels carrying certain dangerous cargo, 

all foreign flag vessels entering Coast Guard District Seven,1

 and all 

foreign recreational vessels to submit Notices of Arrival to the National 

Vessel Movement Center at least 96 hours before arrival. Each Notice of 

Arrival must contain specific information about the vessel, cargo, crew, 

and passengers (see Figure 1). 

In FY 2008, there were more than 68,000 arrivals to U.S. ports of vessels 

required to file such notices. The United States Coast Guard could 

mitigate the potential risks posed by these vessels by conducting security 

boardings on each one. However, the number of arrivals and the Coast 

Guard’s limited resources signal a need for a risk-based targeting 

approach. Figure 1. Excerpted Information 

Required in a Notice of Arrival 

The Coast Guard established its High 

Vessel Information Interest Vessel (HIV) Program to 

address increased U.S. maritime security Vessel name 

requirements in the aftermath of the Name of the registered owner 

terrorist events of September 11, 2001. Country of registry 

The program targets HIVs, or those that Name of the operator and charterer 

might pose high relative security risks to Voyage Information 

U.S. ports or alternate destinations. The Names of last five ports or places visited 

Coast Guard’s Foreign and Offshore Estimated dates and times of arrival and Vessel Activities Division manages the departure at U.S. port 

HIV Program, while the Coast Guard’s 24-hour point of contact 

35 Sector Commands (see Appendix C) Cargo Information 

are responsible for its implementation. A general description of cargo The Coast Guard also created the 

Dangerous cargo carried National Vessel Movement Center to be 

Information for Each Crewmember the central clearinghouse for Onboard and for Each Person Onboard 

notifications of vessels arriving at the in Addition to Crew 

United States. Nationality 

Passport or ID

While vessels use self-reported data to Position or duties on the vessel (crew)

submit the Notices of Arrival, the Coast Where the crewmember/person embarked 

Guard employs a multilayered approach Source: 33 C.F.R § 160.206 (2008) to verify this information. The National 

Vessel Movement Center reviews the 

Notices of Arrival to ensure their accuracy and completeness. The 

1 The Seventh District includes South Carolina, most of Georgia and Florida, the U.S. island possessions of Puerto 

Rico and the U.S. Virgin Islands, and the U.S. Naval reservations in the West Indies and on the northern coast of 

South America. 

The United States Coast Guard’s Program for Identifying High Interest Vessels 

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National Vessel Movement Center then electronically transfers Notice of 

Arrival information to its Ship Arrival Notification System database, 

where it can be accessed by Coast Guard headquarters and Sector 

personnel who use it to complete the HIV targeting matrix. This matrix is 

a risk-based targeting tool that applies relative ranking based on maritime 

security concerns. Sector staff use multiple databases and intelligence 

data to complete the matrix, focusing on security factors such as the 

vessel’s size, cargo, operations, and security performance. Each of these 

security factors constitutes a component of the vessel’s HIV score. When 

a vessel’s HIV score meets or exceeds a specific number, the Sector 

Commander designates the vessel as an HIV and takes action to mitigate 

the risks it poses. 

The Coast Guard Intelligence Program also contributes to the HIV Program 

by conducting analyses that could affect a vessel’s HIV score. The Coast 

Guard Intelligence Coordination Center is the national-level coordinator for 

collection, analysis, production, and dissemination of Coast Guard 

intelligence. Its Coastwatch Branch screens Notice of Arrival information 

and performs federal database checks on arriving vessels, cargoes, crews, 

and passengers. 

In addition, the Coast Guard employs intelligence staffs at Area, District, 

and Sector levels. Each Area has a Maritime Intelligence Fusion Center 

that provides tactical intelligence analysis and collection, including vessel 

screening. The Maritime Intelligence Fusion Centers provide a threat 

warning when intelligence indicates that a vessel, person, or cargo poses a 

potential threat. Coast Guard vessel boarding teams directly verify Notice 

of Arrival information whenever Sector Commanders order a security 

boarding. 

Results of Review 

The Coast Guard needs to take steps to ensure that its scoring matrix is 

being used as intended to identify HIVs. Sector personnel are not 

consistently interpreting the guidance for completing the scoring matrix, 

resulting in inaccurate vessel scores, and the Coast Guard’s oversight of 

matrix scoring could be improved to further reduce matrix reporting errors. 

Further, the Coast Guard Sectors do not consistently archive the scoring 

data, which could be used to assess implementation of the matrix and 

identify areas for improvement. Without an effective mechanism to 

evaluate program performance, the Coast Guard does not have adequate 

assurance that the layer of security provided by the identification of HIVs is 

operating effectively, and that resources are used appropriately to board 

vessels that pose the highest risks to national security. 

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Matrix Scoring, Reporting, and Archiving 

The Coast Guard can reduce errors and inefficiencies by strengthening 

written guidance and ensuring oversight of the HIV matrix scoring 

process. For example, Commandant Instruction 16614.1B, High Interest 

Vessel Targeting Policy, provides guidance for Coast Guard Sectors to use 

the matrix to score vessels. The Instruction describes the matrix’s fields 

and lists sources for staff to consult when assigning points, but does not 

provide specific procedures on how to use Notice of Arrival information 

in the HIV targeting matrix, report HIV designations, and archive scored 

matrices. 

Because of the lack of clarity, Coast Guard Sectors misinterpret the 

guidance, resulting in errors and inefficiencies. For example, HIV 

Program officials at Coast Guard headquarters rescored 631 matrices from 

24 Sectors from June 2008 through January 2009 that were originally 

designated as HIVs by the Sectors and boarded. Those officials concluded 

that 14% of the selected matrices had been scored incorrectly and 

suggested the unnecessary use of Coast Guard resources by boarding 

vessels that may not have been high interest. Officials indicated that the 

error rate may have been lower than 14% because the reviewers did not 

have access to information originally used in the matrix. They also said 

that Sector misinterpretation of the Instruction and message guidance 

caused errors in assigning and deducting points from the matrix, primarily 

regarding port call history and prior boarding history. 

Improving Coast Guard oversight of matrix scoring could lead to reducing 

matrix reporting errors. For example: 

•	 Program officials indicated that for the matrices reviewed from June 

2008 through February 2009, there were 14 HIV-related reporting 

errors in the Maritime Information for Safety and Law Enforcement 

database. 

•	 Coast Guard HIV Program statistics indicated that one Sector reported 

no HIVs for calendar year 2008. However, officials at the Sector said 

that there were 66 HIVs designated during that year. Coast Guard 

headquarters officials acknowledged that this discrepancy was caused 

by Sector personnel not correctly entering vessels as HIVs in the 

Marine Information for Safety and Law Enforcement database. 

•	 The Commandant Instruction contains the following reporting 

procedure: “For all HIV security boardings conducted, create a special 

note to expire in one year, that states the key reason why the vessel 

The United States Coast Guard’s Program for Identifying High Interest Vessels 

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was determined to be a HIV.” However, Coast Guard officials told us 

that from January through May 2009, 44% of the vessels designated as 

HIVs and boarded did not have special notes attached to their profiles. 

Commandant Instruction 16614.1B does not contain written procedures 

for archiving the results of past HIV matrices. Maintaining the scored 

matrices could serve several purposes. In addition to creating a vessel 

history, archiving would allow the Coast Guard to assess the accuracy, 

timeliness, completeness, and uniformity of HIV scoring, and identify 

emerging trends that could be used to improve the HIV matrix. However, 

because the completed matrices are classified, Coast Guard headquarters 

recommends that Sectors keep them for at least 3 days, or only long 

enough for analysts to review HIV designations. As a result, Sector 

Commands do not consistently retain past HIV scorings for future 

analysis. 

For example, the Pacific Area2

 electronic system archives 100% of scored 

HIV matrices. The Pacific Area also maintains all paper scored matrices 

for 3 days if its automated system is unavailable. In contrast, Atlantic 

Area3 Sectors have varying requirements for archiving completed 

matrices, ranging from 30 days to 6 months. The Atlantic Area’s 

automated database system, once operational, will provide a complete 

archive of all scored matrices. 

Coast Guard officials at headquarters have made efforts to improve Sector 

understanding and compliance with the Commandant Instruction on 

implementing the matrix process by issuing messages to the Sectors and 

answering questions from Sector personnel. Furthermore, at one District 

visited, an HIV Program official determines, on a limited basis, whether 

its Sectors are in compliance with the Instruction. This District also 

provides policy guidance and clarification when its Sectors have questions 

about the Instruction. Although these communications and clarifications 

may help, more detailed procedures with step-by-step instructions on how 

to use the HIV matrix could reduce errors and inconsistencies in HIV 

scoring, reporting, and archiving. 

Matrix Scoring Automation 

The Coast Guard could improve its efforts to automate matrix scoring to 

reduce the possibility of human errors. The extent of HIV matrix 

2 The Pacific Area Command is responsible for the maritime states of Alaska, California, Hawaii, Oregon, and 

Washington. The Command is also responsible for Arizona, Idaho, Montana, Nevada, and Utah, and extends from 

the North to the South Poles and across the Pacific to Asia. 

3 The Atlantic Area Command is responsible for the area east of the Rocky Mountains to the Arabian Gulf, from 

Canada to the Caribbean Sea. 

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automation depends on whether the Sector is located in the Pacific Area or 

the Atlantic Area. 

Sectors in the Pacific Area have made progress in automating the HIV 

matrix, but more could be done. Sector staff now complete HIV matrices 

online using software that automatically generates points and calculates 

scores. However, this automated process could benefit from a user 

interface to link the HIV matrix with other databases that supply relevant 

information. Creation of a user interface could reduce the current laborintensive requirement for personnel to search through multiple databases 

to complete the scoring matrix. 

In contrast, the Atlantic Area still completes the HIV matrix manually. 

The Atlantic Area is testing the matrix automation software, with a goal of 

having the system up and running by July 2009; however, officials feel 

that date may need to be moved back. 

Performance Measurement 

The HIV Program does not have methodologies in place to measure and 

evaluate program performance, such as the accuracy, timeliness, and 

completeness of HIV matrices and the uniformity of scoring across 

Sectors. The Coast Guard oversees the HIV Program through quality 

control reviews. Coast Guard headquarters analysts review samples of 

matrices resulting in HIV designations to determine whether the Sectors 

scored them according to the Commandant Instruction. As previously 

stated, from June 2008 through January 2009, 14% of the selected 

matrices were determined to have been scored incorrectly. Coast Guard 

officials indicate that this error rate is a reduction from a 24% error rate in 

April 2008. Although reduced, additional attention is needed to further 

reduce the 14% error rate. As a result, resources may have been used to 

board vessels that were not high interest. 

As part of these quality control reviews, analysts do not examine any 

scored matrices of vessels not designated as HIVs. Consequently, HIV 

Program officials could be overlooking errors in which a vessel should 

have been designated an HIV but was not. Although it may be difficult to 

assess the extent to which the HIV Program is improving security at U.S. 

seaports, output measures that assess HIV scoring matrix implementation 

would be useful to gauge program performance. Such a methodology 

would also help identify trends and areas for improvement. 

Recommendations 

To improve High Interest Vessel Program performance, we recommend 

that the Commandant of the Coast Guard: 

The United States Coast Guard’s Program for Identifying High Interest Vessels 

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Recommendation #1: Clarify guidance and provide oversight to ensure 

that the High Interest Vessel scoring matrix is used as intended, and that 

resulting scoring data is accurately reported and archived. 

Recommendation #2: Complete automation of the High Interest Vessel 

matrix scoring process. 

Recommendation #3: Develop and implement a performance mechanism 

to evaluate High Interest Vessel scoring matrix implementation and 

identify trends and areas for improvement. 

Management Comments and OIG Analysis 

The Coast Guard provided specific comments to this report and 

recommendations, which are attached as Appendix B. The Coast Guard 

concurred with the three recommendations in our report. We consider the 

three recommendations resolved, but they will remain open until the Coast 

Guard provides details and documentation on corrective actions taken so 

that we can determine whether the actions adequately address the 

substance of our findings and recommendations. 

Management Comments to Recommendation #1 

The Coast Guard concurred with our recommendation to clarify guidance 

and provide oversight to ensure that the HIV scoring matrix is used as 

intended and that resulting scoring data is accurately reported and 

archived. The Coast Guard stated that it is revising user guidance to 

include more detailed directions regarding the application of the matrix 

and reporting designation of a vessel as a HIV. The Coast Guard also 

provided details of other proposed oversight improvements in response to 

Recommendation #3. 

OIG Analysis 

We consider the Coast Guard’s proposed actions responsive to this 

recommendation. By revising the guidance for scoring the HIV matrix 

and providing more detailed directions on applying the matrix and 

reporting designation of a vessel as a HIV, Sector misinterpretation of the 

instructions should be reduced, resulting in a lower error rate of matrix 

scoring. We consider this recommendation resolved, but it will remain 

open until the Coast Guard provides evidence of revised user guidance to 

include more detailed directions on how to apply the matrix and report 

HIV designations. 

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Management Comments to Recommendation #2 

The Coast Guard concurred with our recommendation to complete 

automation of the HIV matrix scoring process. 

OIG Analysis 

We consider the Coast Guard’s proposed actions responsive to this 

recommendation. Our concern with some Sectors not archiving the results 

of past HIV matrices will be resolved as automation is completed. The 

Coast Guard has made progress in automating the HIV scoring process. 

We observed the automated system used in the Pacific Area and also the 

progress being made in the Atlantic Area. We consider this 

recommendation resolved, but it will remain open until the Coast Guard 

provides evidence that the automation of the HIV scoring process has been 

completed in the Atlantic Area. 

Management Comments to Recommendation #3 

The Coast Guard concurred with our recommendation to develop and 

implement a performance mechanism to evaluate HIV scoring matrix 

implementation, and identify trends and areas for improvement. The 

Coast Guard stated that program officials and analysts intend to implement 

regular audits of Notices of Arrival that were not scored as HIVs to 

measure the accuracy of both automated and hand written matrix scores. 

In addition, the Coast Guard response stated that program officials have 

established a standard error rate that, when exceeded, will trigger more 

extensive review of the HIV instruction application at the Sector level. 

OIG Analysis 

We consider the Coast Guard’s proposed actions responsive to this 

recommendation. As detailed in this report, Coast Guard program 

officials and analysts were reviewing selected matrices that were scored as 

HIVs, but did not examine those matrices that did not score high enough 

to be designated as an HIV. Our concern was that program officials could 

be overlooking errors when a vessel was incorrectly not designated as an 

HIV. Also, establishing a standard error rate that when exceeded, will 

trigger more extensive reviews of HIV instructions should be useful in 

gauging program performance, identifying trends, and pinpointing areas 

needing improvement. 

We consider this recommendation resolved, but it will remain open until 

the Coast Guard provides evidence that regular audits are being conducted 

and provides initial results from establishing a standard error rate. 

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OIG Response to General Management Comments (Appendix B) 

The Coast Guard also commented that the draft report did not reflect 

improvements in matrix scoring due to Coast Guard oversight. The Coast 

Guard cited statistics showing a reduction in the matrix recording error 

rate from 24% in April 2008 to 14% at the time of our review. We have 

revised the report to note the reduction cited by the Coast Guard, but 

believe more improvement is needed because possibly one in seven 

vessels continue to be incorrectly scored through the use of the matrix. 

Also, the Coast Guard raised concerns regarding our statement that “the 

Coast Guard does not have adequate assurance that all HIVs are correctly 

identified and that resources are used appropriately to board vessels that 

pose the highest risks to national security”. We have revised the report to 

clarify that we are only addressing the layer of security provided by the 

high interest vessel program. We also state in the Executive Summary 

that the HIV program is part of a larger, multifaceted effort to improve the 

Coast Guard’s ability to identify and respond to vessels, cargoes, and 

crews that might pose security risks to the United States. Regarding the 

appropriate use of resources, Coast Guard analysts noted that vessels 

scored as an HIV in error and boarded could cause a “possible 

unnecessary use of resources.” 

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Appendix A 

Purpose, Scope, and Methodology 

The purpose of our review was to determine whether improvements can be 

made to the application and oversight of the risk-based scoring matrix 

used by Coast Guard Sectors to identify high interest vessels that could 

pose security risks to the United States. 

To accomplish this objective, we reviewed applicable laws, regulations, 

Commandant Instructions, and Department of Homeland Security and 

Coast Guard procedures and reports relating to Coast Guard intelligence 

and high interest vessels entering U.S. seaports. We then interviewed 

officials and obtained supporting documentation at the Office of 

Intelligence and Criminal Investigations and the Office of Operations at 

U.S. Coast Guard headquarters in Washington, DC. 

We interviewed Coast Guard officials at the Intelligence Coordination 

Center, the Maritime Intelligence Fusion Centers, the National Vessel 

Movement Center, and the Foreign and Offshore Vessel Activities 

Division. We also visited the Office of Naval Intelligence, co-located 

with the Coast Guard’s Intelligence Coordination Center at the National 

Maritime Intelligence Center. In addition, we met with an official from 

the U.S. Customs and Border Protection’s National Targeting Center. 

We interviewed officials and observed matrix scoring procedures at 

various locations. Field Area and District Coast Guard units we visited 

included Atlantic and Pacific Area Maritime Intelligence Fusion Centers 

and District offices in Boston, MA; Alameda, CA; and Seattle, WA. 

Sector Commands we visited included Boston, MA; Hampton Roads, VA; 

Los Angeles–Long Beach, CA; Portland, OR; San Diego, CA; and Seattle, 

WA. We also sent and received questionnaires from the Sector 

Commands in Boston, MA; Portland, OR; and Seattle, WA. We visited 

Field Intelligence Support Team units in Baltimore, MD; Boston, MA; 

Hampton Roads, VA; Los Angeles–Long Beach, CA; Portland, OR; San 

Diego, CA; and Seattle, WA. 

We performed initial fieldwork from June 2006 through June 2007. We 

updated our audit work from December 2008 through February 2009. Our 

review was conducted under the authority of the Inspector General Act of 

1978, as amended. We conducted this performance audit in accordance 

with generally accepted government auditing standards, except that we 

relied on Coast Guard data and did not verify data against original 

documentation. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. 

The United States Coast Guard’s Program for Identifying High Interest Vessels 

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Appendix A 

Purpose, Scope, and Methodology 

We appreciate the cooperation and courtesies extended to our review team 

by Coast Guard officials. Major contributors to this report are identified 

in Appendix D. 

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Appendix B 

Management Comments to Draft Report 

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Appendix B 

Management Comments to Draft Report 

The United States Coast Guard’s Program for Identifying High Interest Vessels 


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Appendix C 

Maps of Coast Guard Areas, Districts, and Sectors 

The United States Coast Guard’s Program for Identifying High Interest Vessels 


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Appendix D 

Major Contributors to This Report 

Brooke Bebow, Director 

Barry A. Russell, Project Lead 

 LaTrina McCowin, Auditor 

 Elizabeth Clark, Program Analyst 

 Victor Leung, Program Analyst 

 Emily Pedersen, Program Analyst 

 Rebecca Mogg, Program Analyst 

Gary Alvino, Referencer 

The United States Coast Guard’s Program for Identifying High Interest Vessels 

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Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Operations 

Chief of Staff for Policy 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

USCG Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as appropriate 

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