CBP Does Not Have a 

Comprehensive Strategy for 

Meeting Its LS-NII Needs 

September 28, 2020 

OIG-20-75 
September 28, 2020
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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 Sondra McCauley, 

Assistant Inspector General for Audits, at (202) 981-6000. 

www.oig.dhs.gov 
 

 

DHS OIG HIGHLIGHTS 

CBP Does Not Have a Comprehensive Strategy 

for Meeting Its LS-NII Needs 

September 28, 2020 

Why We Did 

This Audit 

CBP uses LS-NII imaging 

systems to examine large 

conveyances such as cars, 

trucks, buses, rail cars, 

and sea containers. These 

large-scale systems 

represent a majority of 

procurement costs 

associated with the NII 

program. Our objective 

was to determine to what 

extent CBP has a strategy 

for meeting its LS-NII 

equipment needs at U.S. 

locations. 

What We 

Recommend 

We made three 

recommendations to 

improve CBP’s acquisition 

planning for LS-NII needs 

and ensure effective 

investments for its NII 

program. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

U.S. Customs and Border Protection (CBP) does not 

have a comprehensive strategy for meeting its LargeScale Non-Intrusive Inspection (LS-NII) equipment 

needs at all CBP locations. Instead, CBP uses 

multiple plans, such as its Multi-Year Investment and 

Management Plan, and individual acquisition plans 

for each type of LS-NII equipment it may purchase. 

At times, these acquisition plans contained conflicting 

information and did not align with the program’s 

approved lifecycle cost estimate. 

This occurred because DHS and CBP acquisition 

officials did not provide effective oversight of CBP’s 

fragmented acquisition planning efforts and did not 

confirm acquisition plans aligned with LS-NII program 

objectives. Without improvements, CBP cannot 

ensure that its multi-million dollar investments in LSNII technology and equipment will help the 

component fulfill its mission of protecting U.S. 

borders. 

DHS Response 

DHS did not concur with recommendation 1 but 

concurred with recommendations 2 and 3. We 

consider recommendation 1 unresolved and open, 

and recommendations 2 and 3 resolved and open. 

Appendix A contains DHS’ management comments in 

their entirety. 

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Background 

U.S. Customs and Border Protection’s (CBP) mission is to safeguard America’s 

borders from dangerous people and materials while enabling legitimate trade 

and travel. CBP’s Non-Intrusive Inspection (NII) program helps fulfill this 

mission through a non-destructive means of examining the contents of 

conveyances and packages coming into the United States for threats, including 

drugs, weapons, or inadmissible persons. CBP’s NII program consists of largescale, and small-scale equipment. Our audit focused on large-scale nonintrusive inspection imaging (LS-NII) equipment, which represents the majority 

of the program’s procurement costs. 

Before the program transitioned to CBP in 2003, U.S. Customs Services used 

LS-NII equipment to examine large conveyances. CBP’s Office of Field 

Operations (OFO) and the Border Patrol are now the primary users of LS-NII 

equipment. As of September 2019, CBP reported having more than 300 LS-NII 

equipment deployed across 143 OFO and 28 U.S. Border Patrol locations. CBP 

officers and agents use LS-NII equipment to create x-ray images of large 

conveyances such as trucks, containerized cargo, personally operated vehicles, 

buses, and rail cars. LS-NII equipment can be mounted on trucks for mobility 

or installed at fixed locations, as shown in Figure 1. CBP uses a variety of LSNII equipment categorized as high, medium, or low energy to scan a 

conveyance. 

Figure 1. OIG Photos of Mobile LS-NII (left) and Fixed LS-NII (right) 

Source: Office of Inspector General (OIG) site visit to Laredo and Pharr, Texas 

CBP uses LS-NII equipment primarily in a secondary screening area to scan 

high-risk or flagged conveyances. CBP determines which conveyances will be 

scanned using a targeted inspection process based on targeting scores from a 

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cargo tracking system, as well as officer judgment.1 Once a conveyance is 

scanned, a CBP officer examines the LS-NII image on a viewing monitor for 

evidence of possible contraband, without having to perform a full manual 

examination of the conveyance’s contents. Figure 2 shows an LS-NII image of a 

tractor trailer. 

Figure 2. LS-NII Image of a Tractor Trailer

Source: OIG photo of screen image taken during a site visit to Pharr, Texas 

CBP’s NII program is a Department of Homeland Security Level 1 major 

acquisition program with an approved Lifecycle Cost Estimate of over $4 

billion. CBP obligated approximately $350 million and spent $133 million to 

acquire and test LS-NII equipment during fiscal years 2016 through 2019. 

CBP purchased and tested different LS-NII equipment using contracts and 

interagency agreements. Level 1 major acquisition programs must follow the 

Federal Acquisition Regulation (FAR) and DHS policy, including the Homeland 

Security Acquisition Management Directive, and the Homeland Security 

Acquisition Manual. 

The FAR requires an agency to develop a written acquisition strategy tailored to 

the major system’s acquisition program and in accordance with FAR 

guidelines. The strategy is the program manager’s written plan to satisfy the 

mission need in the most effective, economical, and timely manner. Sections of 

the FAR governing acquisition planning allow specific contents of each plan to 

vary, depending on the nature, circumstances, and stage of the acquisition. 

DHS acquisition policy requires that major acquisition programs follow four 

phases outlined in the DHS Acquisition Lifecycle Framework, as shown in 

Figure 3. DHS uses the framework to ensure acquisitions receive consistent 

and efficient acquisition management, support, review, and approval 

throughout the lifecycle. The framework identifies the major steps in a 

1 CBP Border Patrol agents must have probable cause prior to using LS-NII. 

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OFFICE OF INSPECTOR GENERAL 

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successful acquisition program and the associated Acquisition Decision Events. 

The framework provides the basis for planning, governing, and executing 

acquisition programs. The LS-NII program predates DHS acquisition policy. 

However, since February 2016, CBP’s LS-NII program has been in the 

“produce/deploy/support/disposal” phase of the DHS Acquisition Lifecycle 

Framework. 

Figure 3. Acquisition Lifecycle Framework 

Need 

DHS defines a 

problem

Analyze/Select 

DHS identifies the 

alternatives and 

resource

requirements

Obtain 

DHS develops and 

evaluates 

capabilties

Produce/Deploy

Support/Disposal 

DHS produces and 

maintains 

capabilities

Source: OIG analysis of DHS Management Directive 102-01 

In order to progress through the framework phases, a program’s Acquisition 

Decision Authority must determine whether the program meets applicable 

criteria and approve it entering the next lifecycle phase. The Under Secretary 

for Management serves as the Acquisition Decision Authority for the NII 

program, and is also responsible for management and oversight of the 

Department’s acquisition policies and procedures. DHS policy also requires 

that Department officials review and approve several key acquisition 

documents, including: 

Mission Needs Statement – documents specific functional 

capabilities required to accomplish the Department’s mission 

and objectives, along with deficiencies and gaps in these 

capabilities. 

Operational Requirements Document – captures operational 

requirements and Key Performance Parameters and describes 

needed operational capabilities. 

Acquisition Program Baseline – establishes the critical cost, 

schedule, and performance parameters, expressed in 

measurable, quantitative terms that must be met to 

accomplish program goals. 

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Lifecycle Cost Estimates – identifies the resources and 

estimated costs for the entire life of a program, and those 

costs are reflected in the program’s acquisition program 

baseline. The Chief Financial Officer approves the initial 

estimate, and the component completes annual updates. 

Acquisition Plan2 –at the time of our audit, this document 

provided a top-level plan for the overall acquisition approach, 

types of acquisitions, and the strategy for acquiring future 

sustainment and support. Formal Acquisition Plans are 

required for Level 1 and 2 programs. Major information 

technology (IT) programs plans must be approved by the DHS 

Chief Procurement Officer (CPO) and DHS Chief Information 

Officer. 

In December 2019, the DHS CPO issued a memorandum allowing components 

to deviate from the FAR. According to the memorandum, much of the 

program-level content required by the FAR for DHS’ major acquisition 

programs is contained in separate program documentation required by the 

Homeland Security Acquisition Management Directive. In January 2020, DHS 

changed its acquisition policy to no longer require a consolidated acquisition 

strategy. Under the previous requirement, a consolidated strategy would have 

described acquisitions supporting a major system, as well as significant 

conditions and constraints affecting the acquisitions. 

Effective January 2020, DHS began requiring that each CBP procurement of 

$25 million or more have a procurement strategy reviewed by the DHS CPO. 

The review is an early opportunity for the CPO to be aware of high-risk areas 

for a proposed procurement, obtain a description of the requirements, and 

know if the procurement is part of a major program. After the CPO’s review, 

an acquisition plan is required for firm-fixed price actions greater than or equal 

to $50 million, and actions other than firm-fixed price above the simplified 

acquisition threshold. If the procurement action is greater than or equal to 

$100 million, CBP is required to obtain CPO’s approval. This acquisition plan 

should provide a top-level plan for the overall procurement approach, 

sustainment, and support, as well as significant conditions and constraints 

2 The Homeland Security Acquisition Manual used ‘strategy’ and ‘plan’ interchangeably. In July 

2020, the Under Secretary for Management approved a revised Acquisition policy, which no 

longer requires a program-level Acquisition Plan. However, the policy indicates that DHS is 

considering incorporating acquisition program information critical for proper program oversight 

into existing, required acquisition program documents. 

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affecting the procurement. These CPO reviews are for individual procurement 

actions, not an overall major acquisition program. 

CBP designated OFO as the organization responsible for determining its LS-NII 

requirements for CBP Cargo and Conveyance Security. Although OFO is the 

primary user, Border Patrol also uses LS-NII equipment, which it obtains 

through OFO for use at designated checkpoints. 

The CBP Program Lifecycle Process Guide describes the roles of the 

Component’s Acquisition Executive (CAE) and the Acquisition Program 

Manager (APM). CBP’s CAE directs acquisition program management activities 

throughout the acquisition phases. The APM reports to the CAE and helps 

execute LS-NII procurements, making final scope of work decisions, as well as 

preparing and signing acquisition documents based on OFO requirements. 

In a 2015 report,3 the U.S. Senate explained it was aware that a significant 

portion of the imaging equipment was past its estimated 10-year lifespan. In a 

2016 explanatory statement, the House required CBP to develop a Multi-Year 

Investment and Management Plan (Management Plan) detailing its inventory, 

costs, forecasts, and Acquisition Program Baseline (APB). It also required that 

the APB align each technology acquisition to mission requirements.4 CBP’s 

focus in its 2016 Management Plan was to replace the oldest equipment and 

increase the total inventory to reach full operational capability. In 2018, CBP 

issued another Management Plan,5 and provided more details for requirements 

for a future NII program. 

Results of Audit 

CBP Does Not Have a Comprehensive Strategy for Meeting LSNII Needs 

CBP does not have a comprehensive strategy for meeting its LS-NII equipment 

needs at all CBP locations. CBP used multiple plans that contained conflicting 

information or did not align with the program’s approved lifecycle estimate. 

DHS and CBP acquisition officials did not provide effective oversight to confirm 

that CBP’s acquisition planning aligned with LS-NII program objectives. 

Without improvements, CBP cannot ensure that its multi-million dollar 

3 S. Rep. No. 114-68, at 36 (2015). 

4 Legislative Text and Explanatory Statement, Committee on Appropriations U.S. House of 

Representatives on H.R. 2029, at 923 (2016). 

5 Inspection and Detection Technology Multi-Year Investment and Management Plan (FY 2017-

FY2020), Fiscal Year 2017 Report to Congress, dated May 18, 2018. 

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investments in LS-NII technology and equipment will help the component fulfill 

its mission of protecting U.S. borders. 

Fragmented Plans Included Inconsistent and Unreliable Information 

CBP did not have a comprehensive acquisition strategy for meeting all 

locations’ LS-NII equipment needs. Although CBP provided us a 2017 

document titled, “Acquisition Strategy,” this strategy only described 

background information on the NII program and CBP’s intent to use fixed-price 

contracts to replace obsolete equipment. The “Acquisition Strategy” did not 

include all acquisitions supporting the major system or address significant 

conditions and constraints. Instead, CBP used its Multi-Year Investment and 

Management Plan, as well as several individual acquisition plans, to plan 

future LS-NII purchases. 

However, we determined these plans contained conflicting information and did 

not align with the program’s approved lifecycle cost estimate. For example, 

CBP’s Management Plan called for purchasing 17 multi-energy portals in FY 

2016 through FY 2020. However, CBP’s approved 2016 lifecycle cost estimate 

reflected no needed requirement for the multi-energy portals. Additionally, the 

same lifecycle cost estimate included a requirement for 25 units of high-energy 

rail equipment, compared to 19 in its Management Plan. However, CBP did not 

have an approved high-energy rail acquisition plan for procurements in that 

period. See Table 1 for a comparison of equipment quantities by plan and 

approved cost estimate. 

Table 1. Comparison of Equipment Quantities for FY 2016 to FY 2020 

Type of LS-NII 

Equipment 

Multi-Year 

Investment 

and 

Management 

Plan 

Approved 

Lifecycle 

Cost Estimate 

Individual 

Acquisition 

Plans 

Multi-Energy Portal 

High-Energy Rail 

Medium-Energy Portal 

Low-Energy Portal 

Low-Energy Mobile 

Medium-Energy Mobile 

17 

19 

0 

34 

15 

60 

0 

25 

26 

9 

39 

82 

0 

0 

0 

34 

28 

78 

Source: OIG analysis of CBP documents 

In addition, CBP reported inconsistent inventory data to Congress. In its 

Management Plan to Congress, CBP reported its strategy to replace aging 

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equipment in the NII program. One of CBP’s goals was to ensure deployed LSNII equipment was under 10 years of age by the end of FY 2021. We compared 

and analyzed data from CBP’s LS-NII inventory database and its Management 

Plan (see Appendix B). We determined the data was not reliable because it did 

not align with inventory quantities reported by CBP in management briefings to 

DHS decision makers. 

Inadequate Oversight of CBP’s Acquisition Planning Activities 

These problems occurred because DHS and CBP acquisition officials did not 

provide effective oversight of CBP’s fragmented acquisition planning efforts. 

Specifically, we determined the DHS CPO did not review any of the acquisition 

plans for conflicting information or to ensure they aligned with the intended 

program objectives. The DHS Chief Information Officer responsible for DHS’ 

Information Technology priorities, policies, and standards also had not 

reviewed the plans. According to CBP, this was because the individual plans 

did not reach the spending thresholds that would initiate DHS Headquarters 

reviews. Although the Acquisition Decision Authority (ADA) may tailor an 

acquisition program’s document requirements as needed, such modifications 

were not documented in any acquisition decision memorandum, nor was a 

waiver written to document why a comprehensive program strategy was not 

needed. 

While DHS removed the requirement for a consolidated strategy, using multiple 

plans to guide purchases for a program increases the need for management 

oversight. In addition it decreases oversight in the identification of potential 

deficiencies in areas such as the quantity of equipment needed. Without a 

comprehensive strategy, consistent plans, and reliable inventory data, DHS 

and CBP acquisition officials are not able to effectively monitor program 

performance. 

Resulting Equipment Purchases May Not Meet CBP Mission Needs 

CBP has no assurance that its investments in LS-NII equipment will help fulfill 

its mission of protecting U.S. borders. To illustrate, CBP purchased LS-NII 

equipment that does not have an established APB. CBP’s individual 

acquisition plans included low-energy LS-NII equipment for scanning privately 

owned vehicles and buses. In order to deploy these additional vehicle 

scanners, CBP received permission from the ADA to purchase equipment 

beyond what the program needed to be fully operational. However, the 

program’s APB did not identify the extent to which CBP should scan personal 

vehicles. Having an approved APB sets formal metrics for measuring actual 

program performance against program goals and helps alert management to 

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potential problems, such as cost growth, requirements creep, and schedule 

slips. 

In addition, a CBP official explained CBP has deployed 11 of 17 Under Vehicle 

Inspection Systems (UVIS), a technology used to scan under vehicles, even 

though they were not included in any of the acquisition plans. CBP deployed 

the UVIS without identifying any performance parameters in the APB. Having 

all critical LS-NII equipment identified in a plan with performance parameters 

is key to ensuring CBP can measure how well the equipment accomplishes its 

goal and confirming that the planned acquisitions are the best selections. 

Also, CBP deployed Medium-Energy Mobile LS-NII systems in 2014. However, 

according to a CBP official, system capability testing was conducted and 

completed afterwards, and was limited to testing of the technical standards for 

imaging equipment. CBP could not provide documentation showing simulated 

threats such as narcotics, explosives, and firearms were included. CBP 

entered into an interagency agreement with the Naval Surface Warfare Center 

to conduct tests of CBP’s LS-NII equipment effectiveness, as well as CBP 

officers’ probability of detecting hidden threats after the equipment was 

deployed. CBP will not know whether the LS-NII equipment deployed at 

locations is adequately identifying weapons and narcotics until the testing is 

complete. 

Further, CBP plans to purchase equipment with increased capabilities without 

ensuring the equipment is the optimal solution. Specifically, CBP’s 

Management Plan calls for purchasing more than 23 multi-energy LS-NII 

equipment through FY 2021, but CBP did not prepare a test plan for assessing 

the equipment's operational effectiveness and suitability. CBP obligated $45 

million through an interagency agreement and for testing equipment prior to 

having a required testing plan for ensuring the correct testing measures have 

been identified and tests are likely to generate the data needed to make 

informed acquisition decisions. In fact, CBP completed construction at one 

port for multi-energy LS-NII installation without ensuring the technology is 

suitable and effective. Additionally, the intent of multi-energy LS-NII 

equipment is to increase the use of LS-NII equipment by screening more than 

high-risk targets. The new equipment may provide CBP the ability to scan 100 

conveyances per hour, compared to the program’s current minimum objective 

of 20 per hour. CBP plans to purchase this equipment, even though it does not 

have the staff necessary to examine the additional images. 

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Conclusion 

Past audit reports highlighted the Department’s challenges overseeing highdollar, high-risk major acquisitions. Recognizing the importance of the NII 

program’s role in the nation’s border security, Congress appropriated more 

than $500 million for the NII program in FY 2019. However, without adequate 

department-level oversight, CBP may continue to use an ineffective, fragmented 

planning approach that circumvents key acquisition controls. It is critical that 

both DHS and CBP work together to ensure CBP has a strategy that identifies 

and aligns LS-NII capabilities to meet mission goals and objectives. 

Recommendations 

Recommendation 1: We recommend the DHS Under Secretary for 

Management require the acquisition program office to develop an approved 

strategy that aligns its NII key acquisition documents and CBP’s evolving LSNII needs with investments in critical LS-NII equipment. 

Recommendation 2: We recommend the Component Acquisition Executive in 

CBP work with the program to implement procedures to ensure better 

alignment and tracking of reliable data for LS-NII. 

Recommendation 3: We recommend the Component Acquisition Executive in 

CBP ensure the NII strategy encompasses an approved Acquisition Program 

Baseline that includes key performance baselines for all critical LS-NII 

equipment. 

Management Comments and OIG Analysis 

The Department provided formal written comments in response to the draft 

report. We also received technical comments and incorporated them in the 

report where appropriate. We included a copy of the Department’s response in 

its entirety in Appendix A. The Department concurred with recommendations 

2 and 3, but did not concur with recommendation 1. 

The Department and CBP disagreed with our overall audit conclusion that the 

Department lacks a comprehensive strategy for its LS-NII system and 

questioned the conclusions and assertions in our report. During our audit, 

CBP told us that the Multi-Year Investment Management and Investment Plan 

to Congress was CBP’s overall strategy for meeting its LS-NII needs. After our 

draft report was issued, CBP stated that it did not use its Multi-Year 

Investment and Management Plan to plan future LS-NII procurements. We 

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believe these inconsistencies highlight the need for a single, cohesive 

acquisition strategy approved by DHS to guide the program manager in 

satisfying the mission need and allow for comprehensive program oversight. 

DHS and CBP stated the report did not provide clarity as it relates to 

compliance with acquisition activities. Specifically, DHS and CBP stated we 

did not acknowledge that the program has an approved Acquisition Program 

Baseline. We disagree with the Department’s assertion. As we acknowledged 

in the report, DHS has an Acquisition Program Baseline (APB). However, the 

existing APB does not include performance parameters for critical LS-NII 

equipment used to scan privately owned vehicles and buses. 

DHS stated it was exempt from having a Test and Evaluation Master Plan 

(TEMP). However, according to DHS policy, if capability developers and 

acquisition decision authorities want to know if a system works as intended, it 

must be tested. Exempting the program from having to develop a TEMP will 

not provide DHS with certainty that the equipment is operationally effective 

and suitable. 

DHS asserted we misstated the approval authority for the NII acquisition plan. 

We disagree with this assertion. Our report correctly reflects the acquisition 

plan review requirements in place at the time of our audit. We also noted that 

DHS changed the requirements in December 2019. 

DHS emphasized the audit took 26 months to complete. Although we recognize 

the length of the audit, it is meant to provide constructive recommendations to 

ensure that both DHS and CBP work together to ensure CBP has a strategy 

that identifies and aligns LS-NII capabilities to fulfill CBP mission goals and 

objectives. 

A summary of the Department’s responses and our analysis follows. We 

consider recommendation 1 unresolved and open, and recommendations 2 and 

3 resolved and open. 

DHS Response to Recommendation 1: Non-concur. As CBP’s Non-Intrusive 

Inspection program office is in the process of updating the legacy NII program’s 

Life-Cycle Cost Estimate and APB to reflect increased funding and its impact 

on NII quantities to achieve Full Operational Capability, a separate strategy 

document for the NII program is not warranted. The target completion date for 

the legacy Life-Cycle Cost Estimate and APB is March 2021, and the program’s 

Life-Cycle Cost Estimate and APB will be updated annually, if necessary. 

These documents are approved by the DHS Chief Financial Officer and 

Acquisition Decision Authority. This approach helps accommodate the 

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evolution of CBP’s NII needs geographically and over time, based upon changes 

in traffic patterns, traffic volumes, commodities, surges of particular threats, 

etc. 

Within the next 10 – 18 months, CBP plans to enter the “Obtain” phase for a 

new program, entitled NII-I. This program will include procurement of 

additional NII systems that will transition to the new NII-I program. CBP 

presented a strategy at the NII-I Acquisition Decision Event-1 held on 

November 13, 2019. CBP believes further refinement and formalization of the 

strategy will occur through the NII-I acquisition process, and that it is the 

appropriate area to focus future strategic planning. 

OIG Analysis of DHS Response: We disagree with DHS’ response to 

recommendation 1. We believe CBP should still develop a strategy for the 

current NII program because this program is scheduled to sunset in 2035, and 

Congress has provided a significant amount of funding for the current 

program. CBP needs a strategy for the LS-NII portion of the program in the 

event the new program does not progress as planned. Although DHS did not 

concur with this recommendation, DHS is considering incorporating 

acquisition program information, critical for proper program oversight, into 

existing required acquisition program documents. In addition, in its response 

to our draft report, DHS stated that a strategy incorporating the current and 

future NII procurements will be formalized. Until DHS takes appropriate 

action, we consider this recommendation unresolved and open. 

DHS Response to Recommendation 2: Concur. CBP Office of Acquisitions 

will implement either a checklist or additional reviews for the NII program to 

ensure it reports consistently on the program data. Estimated Completion 

Date: June 30, 2021. 

OIG Analysis of DHS Response: We consider these actions responsive to the 

recommendation. The recommendation will remain resolved and open until 

DHS provides documentation of its procedures and we verify it satisfies the 

intent of our recommendation. 

DHS Response to Recommendation 3: Concur. As discussed during our July 

29, 2020 audit exit conference, CBP believes the program is already compliant, 

as part of the current APB/Life-Cycle Cost Estimate (FY 2020) revision. CBP 

Office of Acquisitions will double check that the Full Operational Capability 

changes approved to date are captured, and we will determine if any changes to 

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the Operational Requirements Document are warranted. Estimated 

Completion Date: June 30, 2021. 

OIG Analysis of DHS Response: We consider these actions responsive to the 

recommendation. The recommendation will remain resolved and open until 

DHS provides documentation showing its analysis of critical equipment that 

should be incorporated in its Acquisition Program Baseline and we verify it 

satisfies the intent of our recommendation. 

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. 

We conducted this audit of U.S. Customs and Border Protection Large-Scale 

Non-Intrusive Inspection imaging systems to determine to what extent CBP has 

a strategy for meeting its need for LS-NII equipment at U.S. locations. To 

achieve our objective, we interviewed DHS officials from the Office of Program 

Accountability and Risk Management and the Science and Technology 

Directorate, as well as CBP’s Office of Acquisition, Laboratories and Scientific 

Services Directorate, Office of Field Operations, U.S. Border Patrol, and 

Container Security Initiative. 

We also obtained and reviewed public laws, DHS directives, congressional 

budget requests, policies, CBP portfolio reviews, CBP’s NII acquisition strategy, 

individual acquisition plans, and acquisition program documentation. We 

reviewed relevant Government Accountability Office and OIG reports. In 

addition, we performed site visits and observed NII operations at 13 land 

border crossings, 4 border patrol checkpoints, and 7 seaports. We reviewed NII 

equipment inventories, and utilization reports. We obtained inventory data 

from CBP and assessed its accuracy by comparing it to inventories reported in 

CBP’s management plans, as well as its acquisition reviews. We could not 

reconcile the inventories and determined the information was not reliable 

enough to measure CBP’s ability to replace its older equipment. We used LSNII usage data provided by CBP to determine which locations we would visit. 

We did not test the usage data because we did not draw conclusions. However, 

we determined it would be sufficient to assist with our survey site visit 

selections. 

Lastly, we reviewed the program’s financial data to identify LS-NII acquisition 

costs. This included a review of LS-NII contract actions between FY 2016 and 

FY 2019. Since Federal regulation mandates that all Federal agencies report 

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contract actions data in the Federal Procurement Data System-Next Generation 

(FPDS-NG), we queried FPDS-NG as a control to ensure data quality. 

We conducted this performance audit between September 2018 and July 2020 

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 objective. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based upon our audit objective. 

The Office of Audit major contributors to this report are Carolyn Hicks, Director; 

Shamika Morris, Audit Manager; Matthew Noll, Auditor-In-Charge; Connie Tan, 

Auditor; Willard Stark, Auditor; Aaron Naas, Program Analyst; Otis Uwagbai, 

Program Analyst; Stephen Wheeler, Data Analyst; Lindsey Koch, 

Communications Analyst; Marissa Weinshel, Independent Referencer; and 

David Kinard, Independent Referencer. 

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Appendix A 

DHS Comments to the Draft Report 

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Appendix B 

Analysis of LS-NII Inventory Age 

Inventory 

Reported to 

OIG 

Inventory Reported 

in 

 Multi-Year 

Investment and 

Management 

Plan* 

Inventory 

Reported in 

Mid-Year 

Portfolio 

Review** 

Inventory Reported 

to 

Acquisition Review 

Team 

FY 16 

Total 

Inventory 

315 307 310 305 

Over 10 

Years Old 115 84 130 133 

FY 17 

Total 

Inventory 

310 No Data Available 305 302 

Over 10 

Years Old 126 No Data Available 121 124 

FY 18 

Total 

Inventory 

305 No Data Available No Data Available 319 

Over 10 

Years Old 135 No Data Available No Data Available 117 

Source: OIG review and analysis of CBP documents 

* The inventory reported in the 2018 Multi-Year Investment and Management 

Plan only contains inventory data for FY 16. 

** The inventory reported in an April 2018 Mid-Year Portfolio review contains 

inventory data for FY 14 through March 2018. 

www.oig.dhs.gov 20 OIG-20-75 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Under Secretary, Office of Strategy, Policy, and Plans 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 21 OIG-20-75 
Additional Information and Copies 

To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General 

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

Follow us on Twitter at: @dhsoig. 

OIG Hotline 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click 

on the red "Hotline" tab. If you cannot access our website, call our hotline at 

(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305