Management Alert -

CBP Spends Millions 

Conducting Polygraph 

Examinations on 

Unsuitable Applicants 

August 4, 2017 

OIG-17-99-MA
 
 

 

 

DHS OIG HIGHLIGHTS
 

Management Alert – CBP Spends Millions Conducting 

Polygraph Examinations on Unsuitable Applicants
 

August , 2017 

Why We Did 

This Audit 

This report is part of an 

ongoing, department-wide 

audit about polygraphs. 

Because of planned 

increases in U.S. Customs 

and Border Protection 

(CBP) staffing, we believe it 

is important to identify and 

describe current 

inefficiencies in CBP’s 

hiring process to promote 

improvements and as a 

precursor to our main 

report. 

What We 

Recommend 

We recommend CBP 

improve its screening by 

establishing an in-person 

pre-security interview 

process, requiring 

examiners to use the oncall adjudication process, 

and discontinue testing of 

unsuitable applicants. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

CBP administered polygraph examinations to applicants who 

previously provided disqualifying information on employment 

documents or during the pre-test interview. This occurred 

because CBP’s process did not stop, and is not sufficient to 

prevent, unsuitable applicants from continuing through the 

polygraph examination. As a result, we estimated that 

between fiscal years 2013 and 2016 CBP spent about $5.1 

million completing more than 2,300 polygraphs for 

applicants with significant pre-test admissions of 

wrongdoing. 

If CBP implemented a security interview and improved 

utilization of the adjudicative process, it could put its funds 

to better use by focusing on applicants with the best chance 

of making it through the hiring process. Not doing so slows 

the process for qualified applicants; wastes polygraph 

resources on unsuitable applicants; and will make it more 

difficult for CBP to achieve its hiring goals. 

CBP Response 

CBP concurred with both recommendations and agreed that 

conducting the in-person pre-security interview prior to the 

polygraph examination is a best practice. However, CBP 

proposed its Office of Professional Responsibility take nearly 

18 months to conduct and review a study to determine the 

feasibility of incorporating a pre-security interview prior to 

the polygraph examination. CBP has already conducted a 

study, which recommended the pre-security interview, and 

CBP has recognized it as a best practice. We believe that 

CPB’s timeline is unreasonably long and will not assist CBP 

in meeting its hiring goals. 

CBP implemented recommendation 2 by issuing a policy 

requiring polygraph examiners to use the on-calladjudication process. 

www.oig.dhs.gov OIG-17-99-MA 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 

August 4 , 2017 

MEMORANDUM FOR: Kevin K. McAleenan 

Acting Commissioner 

U.S. Customs and Border Protection 

FROM: John Roth \.-nk'"\(o~ Q..... 

Inspector General 

SUBJECT: Management Alert ­ CBP Spends Millions Conducting 

Polygraph Examinations on Unsuitable Applicants 

For your action is our final report, Management Alert - CBP Spends Millions 

Conducting Polygraph Examinations on Unsuitable Applicants. We incorporated 

the formal comments provided by your office. 

The report contains two recommendations aimed at improving CBP's hiring 

process. Your office concurred with both recommendations. Based on 

information provided in your response to the draft report, we consider 

recommendation 1 unresolved and open and recommendation 2 resolved and 

closed. 

As prescribed by the Department of Homeland Security Directive 077-01, 

Follow-Up and Resolution for Office ofInspector General Report 

Recommendations, within 90 days of the date of this memorandum, please 

provide our office with a written response that includes your (1) agreement or 

disagreement, (2) corrective action plan, and (3) target completion date for each 

recommendation. Also, please include responsible parties and any other 

supporting documentation necessary to inform us about the current status of 

the recommendation. Until your response is received and evaluated, the 

recommendations will be considered open and unresolved. Please send your 

response or closure request to OIGAuditsFollowup@oig.dhs.gov. 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will 

post the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Don Bumgardner, 

Deputy Assistant Inspector General for Audits, at (202) 254-4100. 

www.oig.dhs.gov 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

The Anti-Border Corruption Act of 2010 requires U.S. Customs and Border 

Protection (CBP) law enforcement applicants to receive a polygraph 

examination before they are hired.1 CBP uses the polygraph examination as a 

tool to identify potential suitability and national security issues. CBP’s 

Credibility Assessment Division oversees the polygraph phase of the hiring 

process. The polygraph consists of three phases: 

x Pre-test Interview — examiners provide an explanation of the polygraph 

instruments and exam; ensure the equipment is working properly; obtain 

a waiver; and review the polygraph questions with the applicant. 

x Polygraph Examination — examiners ask applicants questions in two 

categories: suitability and national security. The suitability questions 

probe issues such as illegal drug use, involvement in serious crimes, and 

falsification of a job application. National security questions seek 

answers related to terrorist activity, unauthorized contact with foreign 

nationals, and the mishandling of classified information. 

x Post-test Interview — examiners review the polygraph exam results 

with the applicants. 

During the pre- or post-test interviews, an applicant may provide information 

or admit to behavior that may disqualify him or her from employment 

eligibility, regardless of the results of the polygraph exam. For example, during 

a pre-test interview an applicant might admit to using illegal drugs or having 

committed other criminal activities. These admissions may disqualify the 

candidate, regardless of the results of the polygraph examination. 

Polygraph examiners do not make the final decision on suitability for 

employment. Instead, they forward polygraph test results and admissions to 

Personnel Security Division adjudicators, who use the information to determine 

suitability. The polygraph is one of several factors the adjudicators consider on 

suitability. CBP began an on-call adjudicator process in March 2015, which 

gives polygraph examiners direct access to adjudicators who can determine the 

suitability of an applicant’s admission instantaneously. 

1 Pub. L. No. 111-376. This requirement was recently waived for veterans who the 

Commissioner determines is suitable for employment, have a current/active Top Secret 

clearance and are able to access sensitive compartmented information, a current single scope 

background investigation, and who were not granted any previous waivers to obtain the 

clearance. See Pub. L. No. 114-328, § 1049. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

According to CBP, between fiscal years 2013 and 2016, it spent about $72.3 

million on the polygraph program and administered polygraph examinations to 

32,847 applicants. 

This polygraph report is part of a series of reports on DHS hiring and an 

ongoing, department-wide audit to determine whether DHS components have 

effective controls over the polygraph and complaint processes. A recent DHS 

Office of Inspector General (OIG) inspection report (OIG-17-05) noted CBP 

continues to have significant delays in hiring law enforcement personnel.2 

CBP’s hiring process took over 220 days in FY 2015. As part of the hiring 

process, polygraph examinations contribute to this delay. During the audit, the 

President issued an executive order calling for CBP to hire 5,000 additional 

agents. Given this mandate, we believe it important to identify and describe 

inefficiency in CBP’s hiring process to promote improvements and as a 

precursor to our main report. 

Results of Audit 

CBP administered polygraph examinations to applicants who previously 

provided disqualifying information on employment documents or during the 

pre-test interview. This occurred because CBP’s process did not stop, and is 

not sufficient to prevent, unsuitable applicants from continuing through the 

polygraph examination. As a result, we estimated CBP spent about $5.1 million 

completing more than 2,300 polygraphs for applicants with significant pre-test 

admissions. 

Disqualifying Admissions during the Pre-test Interview 

As part of our ongoing audit, we are analyzing a statistical sample of 380 

polygraph exams administered from FY 2013 to FY 2016. Of the 380 polygraph 

examinations under our review, 71 applicants (19 percent) made disqualifying 

admissions during the pre-test interview. For the purpose of this report, we 

focused on these 71 cases with unsuitable pre-test admissions.3 According to 

CBP’s data, about 2,300 applicants made unsuitable pre-test admissions and 

still completed the polygraph examination between FYs 2013 and 2016. CBP 

administered the polygraph examination — sometimes multiple examinations 

— to applicants who made unsuitable admissions. For example, applicants 

admitted to illegal drug use, drug smuggling, human trafficking, and to having 

close personal relationships with people who commit these crimes. 

2 DHS is Slow to Hire Law Enforcement Personnel, DHS OIG-17-05.
 3 At the time of this report, the analysis of the full statistical sample is not complete. Therefore, 

we selected and analyzed a judgmental sample of cases (the 71 of 380) with pre-test
 

admissions. The complete analysis will be part of a future report.
 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

In addition, CBP provided information for an applicant who, during the pre-test 

interview, admitted to participating in the gang rape of an intoxicated and 

unconscious woman. The examiner obtained a written statement in the pre-test 

yet continued with the exam for 5 hours after the admission and did not use 

CBP’s on-call adjudicative process. 

Disqualifying Admissions Do Not Prevent a Polygraph Examination 

CBP’s processes do not always remove applicants who provided disqualifying 

information on either their employment application or during the pre-test 

interview. Consequently, for example, CBP administered polygraph 

examinations to individuals who have admitted to such things as using illegal 

drugs within the last 2 years or committing serious crimes. Either of those 

actions would prevent someone from being eligible for employment as a CBP 

law enforcement officer. More thoroughly reviewing the application for 

disqualifying behavior before the polygraph test would prevent the waste of 

scarce polygraph resources. 

On-Call Adjudication Process 

Only an adjudicator can officially determine if an applicant is unsuitable. Prior 

to March 2015, when CBP began its on-call adjudicator process, examiners did 

not have an official method to confirm that an applicant’s pre-test admissions 

were in fact unsuitable and a basis for ending the exam. Rather, an examiner 

relied on the Assistant Special Agent in Charge (ASAC) to determine whether to 

discontinue testing based on an admission, which was later sent to 

adjudicators. The new process allowed polygraph examiners access to 

adjudicators who could determine the suitability of an applicant’s admission 

instantly; however, the ASAC or Quality Control division still approved the 

decision to end the examination. 

We found even with the on-call adjudication process, polygraph examiners 1) 

did not always use this resource; 2) continued the exam after an adjudicator 

determined the applicant was unsuitable; or 3) requested but did not receive 

an immediate suitability determination from an adjudicator, and the examiner 

continued to expend time and resources conducting additional polygraph 

examinations. 

Of the 71 polygraph exams we judgmentally selected to review, 43 (60 percent) 

occurred prior to March 2015. Examiners in the remaining 28 cases — 

ignored the on-call adjudicator process or the adjudicator’s 

determination (17); or 

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x
 

 

x

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

followed the process and either stopped the polygraph on applicants with 

disqualifying admissions or continued because the adjudicator did not 

deem the admission disqualifying (11). 

In an example of the latter category, an examiner contacted the on-call 

adjudicator after the applicant admitted to anger issues that led to recurring 

child abuse, one instance of domestic violence, and repeated vandalism. 

According to CBP, these crimes were disqualifying; however, the adjudicator 

did not make an unsuitable determination. As a result, CBP brought the 

applicant back the next day. The examiner presented the adjudicator with 

additional drug admissions and the adjudicator deemed the applicant 

unsuitable. 

In 2015, CBP’s Office of Administration conducted an assessment on CBP’s 

Pre-Employment Polygraph process.4 Its report acknowledged similar concerns 

and stated that, overall, the process is not efficient and examiners scheduled 

timeslots for unsuitable applicants to continue through the hiring process. The 

report also noted that 21 percent of applicants in the polygraph phase made 

disqualifying admissions during the pre-test interview. 

The report recommended that CBP address these inefficiencies by establishing 

an in-person security interview about 3 weeks prior to the polygraph 

examination. Other components and agencies use a security interview, or 

something similar, before the polygraph examination. The security interview 

uses a series of questions to determine whether an applicant meets the 

suitability requirements to continue through the hiring process. According to 

the report, a security interview would allow greater opportunity to screen out 

applicants who make unsuitable admissions and is the most cost-effective 

option. CBP did not implement this recommendation. Had CBP implemented 

the recommendation, it could have avoided testing unsuitable applicants, and 

potentially reduced the time it takes to hire. 

Process Improvements 

A recent DHS OIG inspection report (OIG-17-05) noted CBP’s FY 2015 hiring 

process for law enforcement personnel took over 220 days. With limited 

polygraph resources, CBP should focus on improving efficiency by removing 

unsuitable applicants from the process as soon as possible. 

Shortly after notification of our audit findings for this report, CBP formalized its 

on-call adjudication practice with a temporary (6 month) policy, effective May 

1, 2017. The new policy applies to a new polygraph format that CBP is 

exploring. The process now requires examiners to contact adjudicators when 

4 CBP’s Pre-Employment Polygraph Assessment, Final Report, September 2015 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

an applicant provides potentially disqualifying information. Nevertheless, the 

new policy does not require the polygraph exam to stop immediately after the 

adjudicator’s determination, rather it continues for a series of questions. 

Although this new policy is an improvement, it continues the practice of testing 

an unsuitable applicant longer than necessary, which wastes time and 

resources on an applicant who CBP already knows is unsuitable. CBP also has 

not addressed the Office of Administration recommendation to establish an inperson security interview prior to the polygraph examination. Doing so would 

further allow CBP to focus its limited polygraph resources on viable candidates 

and potentially reduce the time it takes to hire. 

Conclusion 

CBP administered polygraph examinations to unsuitable applicants. This 

occurred because CBP’s process did not stop, and is not sufficient to prevent, 

unsuitable applicants from continuing through the polygraph examination. 

Specifically, CBP 1) does not have a step, such as the security interview, to 

identify and remove applicants who provide disqualifying information well 

before they are scheduled to appear for a polygraph examination; 2) did not 

require examiners to consistently use the on-call adjudicator process until May 

2017; and 3) does not end the exam immediately after an unsuitable 

determination. As a result, CBP administered polygraph examinations to 

individuals who provided disqualifying information during the polygraph pretest interview. We estimated CBP spent about $5.1 million completing more 

than 2,300 polygraphs to applicants with significant pre-test admissions of 

wrongdoing between FYs 2013 and 2016.5 CBP could not hire these applicants 

regardless of their polygraph results. 

Subjecting unsuitable applicants to the polygraph examination has a direct 

impact on the high failure rate of the polygraph program and limits CBP’s 

capability to address its short- and long-term hiring needs. Given that DHS has 

committed to increase staffing, CBP should put its funds to better use by 

focusing its polygraph resources on applicants with the best chance of making 

it through the hiring process. Not doing so slows the process for qualified 

applicants, wastes polygraph resources on unsuitable applicants, and will 

make it more difficult to achieve its hiring goal. 

5 This figure could be higher because applicants make unsuitable admissions during the pretest, post-test, or both interviews. For the purposes of this alert, we only included pre-test 

admissions because we could not separate the “both” category. We will include this information 

in our final audit report. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendations 

Recommendation 1: We recommend that the Acting Commissioner of CBP 

establish an in-person pre-security interview well before the polygraph 

examination. 

Recommendation 2: We recommend that the Acting Commissioner of CBP 

amend the temporary (May 2017) polygraph policy and develop permanent 

policy and procedures that: 

1. apply to all polygraph screening methods; 

2. require polygraph examiners to contact on-call adjudicators after 

potentially disqualifying pre-test admissions; and 

3. ensure examiners immediately stop polygraph processes when applicants 

are deemed unsuitable. 

Management Comments and OIG Analysis 

CBP concurred with our recommendations and provided comments to the draft 

report. A summary of CBP’s response and our analysis follows. We have 

included a copy of the CBP’s management comments in their entirety in 

appendix A. CBP also provided technical comments to our report. We made 

changes to incorporate these comments, as appropriate. 

CBP raised concerns regarding our cost estimate for conducting polygraph 

examinations on applicants who made unsuitable admissions during the pretest interview. CBP said that our methodology may have resulted in an 

overstatement of cases and associated costs. As stated in the report, our 

estimate could have been higher because we excluded cases where applicants 

made unsuitable admissions during both the pre and post-test interviews. For 

purposes of this report, we only included pre-test admissions because we could 

not separate the “both” category. In addition, the cost estimate of $2,200 per 

polygraph is based on CBP’s budget information it provided at the time of the 

alert. As a result, our cost estimate was understated rather than overstated. 

CBP also noted that while there were cases in our sample that should not have 

progressed to the polygraph stage, many of the cases lacked sufficient 

information to make a suitability determination prior to polygraph testing when 

utilizing the "whole person concept." We asked CBP to review the cases we 

mentioned in the report, and adjudicators determined the applicants were 

unsuitable and should not have continued with the polygraph phase. Had CBP 

implemented the recommendation for an in-person pre-security interview it 

could have alleviated this concern. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Response to Recommendation #1: Concur. CBP agreed that conducting the 

in-person pre-security interview prior to the polygraph examination is a best 

practice. CBP’s Office of Professional Responsibility will conduct a feasibility 

review to assess the impacts of implementing an in-person pre-security 

interview prior to conducting a polygraph examination. According to CBP, 

adding a pre-security interview will force the restructuring of the hiring process 

and add further delays. Additionally, due to the volume of applicants that CBP 

receives, the feasibility review will identify resources needed to conduct this 

interview and administrative support resources to integrate this step in the 

hiring process. Once the feasibility review is complete, CBP will review 

recommendations and determine whether, based on CBP's current hiring 

process, it is feasible to implement the pre-security interview. 

OIG Analysis: CBP concurred but the comments and proposed actions are not 

responsive to the recommendation. CBP proposed nearly 18 months to conduct 

and review a study and make a determination for “the feasibility” of 

incorporating a pre-security interview in the hiring process. Based on this 

response, CBP did not commit to implementing our recommendation. We 

believe the length of time for the feasibility study is unreasonably long and 

does not help CBP achieve its hiring goals. As mentioned in the report, CBP 

already conducted an assessment of the hiring process which recommended 

the pre-security interview occur before the polygraph. 

As CBP noted, the pre-security interview is a best practice. Other law 

enforcement agencies we spoke with conduct a pre-security interview to obtain 

and review additional information about applicants prior to polygraph. CBP 

polygraph officials we spoke with also considered the pre-security interview an 

integral and missing step in the hiring process. During our review we found 

multiple examples of applicants with disqualifying information on their 

application documents. CBP could have removed these applicants had it 

conducted a thorough pre-security interview. We recognize this adds an 

additional step in the hiring process; however, it allows CBP’s polygraph 

program to focus on the best applicants and can ultimately reduce the overall 

time and cost to hire. 

The recommendation will remain unresolved and open until CBP provides 

milestones for incorporating the pre-security interview into the hiring process. 

Response to Recommendation #2: Concur. According to its response, CBP 

implemented this recommendation by issuing a policy memorandum that 

became effective on June 12, 2017, requiring all polygraph examiners to 

contact an on-call adjudicator and obtain a suitability determination any time 

potentially disqualifying information is obtained during a polygraph 

examination. CBP directed all polygraph managers and quality control 

personnel to review every polygraph examination to ensure compliance with 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

this new policy. Additionally, CBP made changes to its polygraph database to 

allow for better oversight of examiner compliance with the policy. Through 

these database changes, managers can easily determine whether any 

additional testing was performed following an unsuitable determination. Oncall adjudicators also make notations in the Integrated Security Management 

System if an unfavorable suitability determination is made resulting from an 

admission(s) made during a polygraph examination. According to CBP, since it 

issued the new policy, it is not aware of any policy violations that have 

occurred. 

OIG Analysis: CBP concurred with our recommendation and provided the 

June 12, 2017 memorandum addressing our recommendation. CBP also 

provided information showing the changes it made to the polygraph database. 

Since the new policy, we observed two polygraph examinations where an 

applicant made unsuitable admissions during the pre-test interview. In both 

cases, the examiner ended the exam after contacting an adjudicator who 

determined the applicant was unsuitable. This determination occurred in less 

than 10 minutes in both cases, which satisfied the intent of our 

recommendation. 

These efforts are responsive to the recommendation, and we consider it 

resolved and closed. 

Objective, Scope, and Methodology 

The Department of Homeland Security Office of Inspector General was 

established by the Homeland Security Act of 2002 (Public Law 107−296) by 

amendment to the Inspector General Act of 1978. 

This report is part of an ongoing department-wide audit to determine whether 

DHS components have effective controls over the polygraph and complaint 

processes. During the audit, the President issued an executive order calling for 

CBP to hire 5,000 additional agents. Given this mandate, we believe it 

important to identify and describe current inefficiencies in CBP’s hiring process 

to promote improvements and as a precursor to our main report. 

To identify and report inefficiencies in CBP’s hiring process we relied on our 

ongoing audit activities that — 

x analyzed the unsuitable admissions of applicants within a statistical 

sample pulled for the larger audit as well as other examples CBP 

provided; 

x confirmed the information by reviewing admissions, correspondence with 

CBP, and examiner notes; 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x	 interviewed officials from CBP’s Credibility Assessment Division, 

Personnel Security Division, Human Resource Management, and budget 

offices; and 

x	 analyzed a September 2015 internal report that CBP commissioned on 

Pre-Employment Polygraph Assessments; 

x	 used CBP’s budget information it provided at the time of the alert and 

estimated it cost CBP $2,200 per polygraph. We filtered the full universe 

of data to identify applicants CBP classified as having significant pre-test 

admissions and removed applicants that did not complete the polygraph 

examination. We identified about 2,300 applicants who proceeded with 

the examination although CBP’s data indicated they made unsuitable 

pretest admissions. We estimated CBP spent about $5.1 million ($2,200 

multiplied by 2,300) completing polygraphs for these applicants. 

We conducted the research for this Management Alert between February and 

March 2017 pursuant to the Inspector General Act of 1978, as amended, and 

according to generally accepted government auditing standards. 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 upon our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based 

upon our audit objectives. 

The Office of Audits major contributors to this report are Sean Pettersen, 

Director; Priscilla Cast, Analyst In-Charge; Gary Crownover, Program Analyst; 

Jeffrey Wilson, Program Analyst; Megan McNulty, Program Analyst; Robert 

Williams, Program Analyst; Christopher Yablonski, Auditor; Benjamin Wing, 

Auditor; Michael Redmond (Office of Investigations), Kevin Dolloson, 

Communications Analyst; Ellen Gallagher, Communications Analyst; and 

David DeHaven, Independent Referencer. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

CBP Response to the Alert 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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