United States Government Accountability Office

GAO Testimony 

Before the Subcommittee on 

Transportation Security and Infrastructure 

Protection, Committee on Homeland 

Security, House of Representatives

AVIATION SECURITY

TSA Is Enhancing Its 

Oversight of Air Carrier 

Efforts to Screen 

Passengers against Terrorist 

Watch-List Records, but 

Expects Ultimate Solution 

to Be Implementation of 

Secure Flight 

Statement of Cathleen A. Berrick 

Director, Homeland Security and Justice Issues 

For Release on Delivery

Expected at 2:00 p.m. EDT

September 9, 2008

 

GAO-08-1136T 
September 2008

What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 9, 2008

AVIATION SECURITY

TSA Is Enhancing Its Oversight of Air Carrier Efforts

to Screen Passengers against Terrorist Watch-List 

Records, but Expects Ultimate Solution to Be 

Implementation of Secure Flight 

Highlights of GAO-08-1136T, a testimony 

before the Subcommittee on 

Transportation Security and Infrastructure 

Protection, Committee on Homeland 

Security, House of Representatives 

Domestic air carriers are 

responsible for checking passenger

names against terrorist watch-list 

records to identify persons who 

should be denied boarding (the No 

Fly List) or who should undergo

additional security scrutiny (the

Selectee List). The Transportation 

Security Administration (TSA) is to 

assume this function through its 

Secure Flight program. However, 

due to program delays, air carriers

retain this role. This testimony 

discusses (1) TSA’s requirements 

for domestic air carriers to conduct 

watch-list matching, (2) the extent 

to which TSA has assessed 

compliance with watch-list 

matching requirements, and (3) 

TSA’s progress in developing

Secure Flight. This statement is 

based on GAO’s report on air 

carrier watch-list matching (GAO08-992) being released today and

GAO’s previous and ongoing 

reviews of Secure Flight. In

conducting this work, GAO

reviewed TSA security directives

and TSA inspections guidance and 

results, and interviewed officials 

from 14 of 95 domestic air carriers.

What GAO Recommends

GAO is not making any 

recommendations related to air 

carriers’ watch-list matching

programs because TSA initiated 

actions in April 2008 to strengthen 

related requirements and its 

oversight of air carriers’ 

implementation of these 

requirements. Regarding Secure

Flight, GAO previously made

recommendations to strengthen the 

program’s development. TSA 

generally agreed. 

TSA’s requirements for domestic air carriers to conduct watch-list matching 

include a requirement to identify passengers whose names are either identical 

or similar to those on the No Fly and Selectee lists. Similar-name matching is 

important because individuals on the watch list may try to avoid detection by 

making travel reservations using name variations. According to TSA, there 

have been incidents of air carriers failing to identify potential matches by not 

successfully conducting similar-name matching. However, until revisions were

initiated in April 2008, TSA’s security directives did not specify what types of

similar-name variations were to be considered. Thus, in interviews with 14 air 

carriers, GAO found inconsistent approaches to conducting similar-name 

matching, and not every air carrier reported conducting similar-name 

comparisons. In January 2008, TSA conducted an evaluation of air carriers 

and found deficiencies in their capability to conduct similar-name matching. 

Thus, in April 2008, TSA revised the No Fly List security directive to specify a

baseline capability for conducting watch-list matching and reported that it 

planned to similarly revise the Selectee List security directive. While

recognizing that the new baseline capability will not address all

vulnerabilities, TSA emphasized that establishing the baseline capability 

should improve air carriers’ performance of watch-list matching and is a good 

interim solution pending the implementation of Secure Flight. 

TSA has undertaken various efforts to assess domestic air carriers’ 

compliance with watch-list matching requirements; however, until 2008, TSA

had conducted limited testing of air carriers’ similar-name-matching 

capability. In 2005, for instance, TSA evaluated the capability of air carriers to

identify names that were identical—but not similar—to those in terrorist 

watch-list records. Also, TSA’s internal guidance did not specifically direct 

inspectors to test air carriers’ similar-name-matching capability, nor did the 

guidance specify the number or types of name variations to be assessed. 

Records in TSA’s database for regular inspections conducted during 2007 

made reference to name-match testing in only 61 of the 1,145 watch-listrelated inspections that GAO reviewed. During the course of GAO’s review, 

and prompted by findings of the evaluation conducted in January 2008, TSA 

reported that its guidance for inspectors would be revised to help ensure air 

carriers’ compliance with security directives. Although TSA has plans to 

strengthen its oversight efforts, it is too early to determine the extent to which 

TSA will provide oversight of air carriers’ compliance with the revised 

security directives. 

In February 2008, GAO reported that TSA has made progress in developing 

Secure Flight but that challenges remained, including the need to more 

effectively manage risk and develop more robust cost and schedule estimates 

(GAO-08-456T). If these challenges are not addressed effectively, the risk of 

the program not being completed on schedule and within estimated costs is 

increased, and the chances of it performing as intended are diminished. TSA 

plans to begin assuming watch-list matching from air carriers in January 2009.

To view the full product, including the scope 

and methodology, click on GAO-08-1136T. 

For more information, contact Cathleen A. 

Berrick at (202) 512-3404 or

berrickc@gao.gov. 
Madam Chairwoman and Members of the Subcommittee: 

I am pleased to be here today to discuss GAO’s work assessing the 

Transportation Security Administration (TSA) and domestic air carrier 

efforts in conducting watch-list matching—or the matching of airline 

passenger information against terrorist watch-list records—a front-line 

defense against acts of terrorism that target the nation’s civil aviation 

system.1

 Domestic air carriers operating to, from, and within the United 

States are to conduct watch-list matching in accordance with requirements 

set forth by TSA. That is, air carriers are to conduct preboarding checks by

comparing passenger data—most prominently name and date of 

birth—against the No Fly List to identify individuals who should be 

prevented from boarding an aircraft, and against the Selectee List to 

identify individuals who must undergo enhanced screening at the 

checkpoint prior to boarding.2

 TSA has responsibility for overseeing how 

air carriers implement the watch-list-matching process, consistent with 

TSA requirements. Critical to this oversight effort are the agency’s 

inspectors—both the principal security inspectors who oversee 

implementation efforts at air carriers’ corporate security offices and the 

transportation security inspectors who oversee implementation efforts at 

airport locations. Beginning in 2009, under a program known as Secure 

Flight, TSA is to take over from air carriers the function of watch-list 

matching for domestic and ultimately international flights. Pending Secure 

Flight’s implementation, air carriers continue to have primary 

responsibility for conducting watch-list matching. In turn, TSA continues 

to have an important oversight responsibility to ensure that air carriers 

comply with watch-list-matching requirements. 

 1

For the purposes of this statement, domestic air carriers are those with operations based

in the United States that maintain full security programs in accordance with 49 C.F.R. part 

1544. The number of domestic air carriers has varied over time, for example, from 95 in 

2005 to about 70 in 2007. 

2

These lists contain applicable records from the Terrorist Screening Center’s consolidated 

database of known or appropriately suspected terrorists. Pursuant to Homeland Security

Presidential Directive 6, dated September 16, 2003, the Terrorist Screening Center—an 

entity that has been operational since December 2003 under the administration of the

Federal Bureau of Investigation—was established to develop and maintain the U.S. 

government’s consolidated terrorist screening database (the watch list) and to provide for 

the use of watch-list records during security-related screening processes. See GAO,

Terrorist Watch List Screening: Recommendations to Promote a Comprehensive and

Coordinated Approach to Terrorist-Related Screening, GAO-08-253T (Washington, D.C.: 

Nov. 8, 2007). 

Page 1 GAO-08-1136T 
My testimony today addresses (1) TSA’s requirements for domestic air 

carriers to conduct watch-list matching for domestic flights, (2) the extent

to which TSA has assessed domestic air carriers’ compliance with watchlist-matching requirements, and (3) TSA’s progress in developing and 

implementing the Secure Flight program. This statement is based on a 

report we released today3

 on air carrier watch-list-matching processes and 

TSA’s oversight of these efforts, as well as work we conducted on the 

Secure Flight program from August 2007 to January 2008,4

 with selected 

updates in September 2008. 

Regarding air carrier watch-list matching, we reviewed TSA’s security 

directives and related guidance applicable to watch-list matching; 

interviewed responsible officials at TSA headquarters; conducted 

interviews (both in-person and via telephone) with officials from domestic 

air carriers to discuss their implementation of watch-list-matching 

requirements;5

 analyzed watch-list-related inspections that TSA conducted 

during fiscal year 2007 to ensure that air carriers were in compliance with

applicable requirements; and reviewed the results from a special emphasis 

assessment that TSA conducted in 2005 and a special emphasis inspection 

it conducted in January 2008, both of which addressed air carriers’ 

capability to conduct watch-list matching.6

 Regarding the Secure Flight 

program, we reviewed systems development, privacy, and other 

 3

GAO, Aviation Security: TSA Is Enhancing Its Oversight of Air Carrier Efforts to

Identify Passengers on the No Fly and Selectee Lists, but Expects Ultimate Solution to Be

Implementation of Secure Flight, GAO-08-992 (Washington, D.C.: Sept. 9, 2008). 

4

GAO, Aviation Security: Transportation Security Administration Has Strengthened

Planning to Guide Investments in Key Aviation Security Programs, but More Work 

Remains, GAO-08-456T (Washington, D.C.: Feb. 28, 2008). 

5

Our selection of the 14 air carriers was based, in part, on operational size with the goal of 

obtaining a range of sizes. Although the 14 air carriers (selected from a total of 95 air 

carriers required to perform watch-list matching during calendar year 2005) represent a 

range in the types of air carriers that conduct watch-list matching, and, according to our 

calculations, accounted for approximately 70 percent of all passengers that boarded 

domestic flights in 2005, the results of our interviews are not generalizable to the domestic 

operations of all domestic air carriers. However, our selection allowed us to understand 

how watch-list matching was performed for the majority of passengers flying domestically

in 2005, although we did not independently verify each air carrier’s reported method of 

implementation. 

6

Special emphasis assessments and special emphasis inspections are nonroutine activities 

undertaken at the direction of TSA headquarters. According to TSA, a special emphasis

assessment addresses a vulnerability that generally is not tied to a regulation, while a 

special emphasis inspection is tied to a regulatory requirement. 

Page 2 GAO-08-1136T 
documentation, and interviewed Department of Homeland Security (DHS), 

TSA, and contractor officials. We conducted these performance audits 

from July 2006 to September 2008 in accordance with 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 on the audit 

objectives. We believe that the evidence obtained provides a reasonable

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

Through its security directives, TSA has issued requirements for watch-list 

matching, which include identifying passengers with names similar to 

those on the No Fly and Selectee lists. Before undertaking revisions of the 

relevant security directives in 2008, TSA expected air carriers to conduct

similar-name matching but TSA’s security directives did not specify how 

many and what types of such name variations air carriers should compare. 

Consequently, in interviews with 14 air carriers, we found inconsistent 

approaches to conducting similar-name matching. Some carriers 

compared more name variations than others; in addition, not every air 

carrier reported conducting similar-name comparisons. Air carriers that 

conduct only exact-name comparisons and carriers that conduct relatively 

limited similar-name comparisons are less effective in identifying watchlisted individuals who travel under name variations. Also, due to 

inconsistent air carrier processes, a passenger could be identified as a 

match to the watch list by one carrier and not by another. In April 2008, 

during the course of our review, TSA revised and issued the No Fly List 

security directive to specify a baseline capability for similar-name 

matching to which all air carriers must conform. Also, in August 2008, TSA 

officials reported that the agency was in the process of similarly revising 

the Selectee List security directive to require the same baseline capability.7

TSA officials acknowledged that the new baseline capability will not 

address all vulnerabilities identified by TSA. However, the officials stated 

that the new baseline capability was a good interim approach for 

improving air carriers’ matching efforts because, among other reasons, it 

will strengthen watch-list matching without requiring investment in a 

solution that will be replaced when Secure Flight is implemented. 

Summary 

 7

TSA officials did not provide us a targeted issuance date for the revised Selectee List

security directive. 

Page 3 GAO-08-1136T 
Although TSA assessed air carriers’ compliance with watch-list-matching 

requirements through a special emphasis assessment conducted in 2005 

and through planned inspections conducted in conjunction with annual 

inspection cycles, the agency had tested similar-name matching to only a 

limited extent until 2008. For instance, the 2005 special emphasis 

assessment focused on air carriers’ capability to identify passenger names 

that were exact matches with names on the No Fly List, but did not 

address the capability to conduct similar-name matching. Also, during the 

most recent annual inspection cycle (fiscal year 2007), although some TSA 

inspectors tested air carriers’ effectiveness in conducting similar-name 

matching, the inspectors did so at their own discretion and without 

specific evaluation criteria. However, during a special emphasis inspection 

conducted in January 2008, TSA found deficiencies in the capability of air 

carriers to conduct similar-name matching.8

 Thereafter, following TSA’s 

revision of the No Fly List security directive in April 2008, officials planned 

to issue new guidance for inspectors to better ensure compliance by air 

carriers with requirements in the new security directive. Further, in 

September 2008, TSA updated us on the status of its efforts with watch-list 

matching. Specifically, TSA provided us with the results of a May 2008 

special emphasis assessment of seven air carriers’ compliance with the 

revised No Fly List security directive. TSA generally characterized the 

results of the May 2008 special emphasis assessment as positive. Further, 

TSA officials noted that the agency’s internal handbook, which provides 

guidance to transportation security inspectors on how to inspect air 

carriers’ compliance with requirements, including watch-list-matching 

requirements, was being revised, and was expected to be released later 

this year. Officials indicated that the new inspection guidance would be 

used in conjunction with TSA’s nationwide regulatory activities plan for 

fiscal year 2009. While these actions and plans are positive developments, 

it is too early to determine the extent to which air carriers’ compliance 

with watch-list-matching requirements will be assessed based on the new 

security directives since these efforts are still underway and have not been

completed. 

Moreover, in February 2008, we reported that TSA has made significant 

progress in developing Secure Flight, but that challenges remained in a 

number of areas, including the need to more effectively manage risk and 

develop more robust cost and schedule estimates. We made a number of 

 8

TSA reported that the January 2008 special emphasis inspection covered 52 domestic air 

carriers and 31 foreign air carriers. 

Page 4 GAO-08-1136T 
recommendations to strengthen TSA’s efforts in these areas, to which TSA 

agreed and has begun to take corrective actions. We will continue to 

evaluate TSA’s efforts to develop and implement Secure Flight and its 

progress in addressing these recommendations as part of our ongoing 

review.9

TSA is responsible for ensuring air carriers’ compliance with regulatory 

requirements, including requirements reflected in TSA security directives. 

Related to watch-list matching, TSA outlines air carrier requirements in 

the No Fly List Procedures security directive, requiring domestic air 

carriers to conduct checks of passenger information against the No Fly 

List to identify individuals who should be precluded from boarding flights,

and the Selectee List Procedures security directive, directing domestic air 

carriers to conduct checks of passenger information against the Selectee 

List to identify individuals who should receive enhanced screening (e.g., 

additional physical screening or a hand-search of carry-on baggage) before 

proceeding through the security checkpoint. Since 2002, TSA has issued 

numerous revisions to the No Fly and Selectee list security directives to 

strengthen and clarify requirements, and has issued guidance to assist air 

carriers in implementing their watch-list-matching processes. 

Background 

TSA conducts inspections of air carriers throughout the year as part of 

regular inspection cycles based on annual inspection plans to determine 

the extent to which air carriers are complying with TSA security 

requirements. These inspections are based on inspection guidelines known 

as PARIS prompts,10 which address a broad range of regulatory

 9

Our review of TSA’s progress with Secure Flight is being conducted in response to

requests from the U.S. Senate (Committee on Commerce, Science, and Transportation, and

its Subcommittee on Aviation Operations, Safety, and Security; Committee on

Appropriations, Subcommittee on Homeland Security; Committee on Homeland Security 

and Governmental Affairs; and Committee on the Judiciary) and the U.S. House of 

Representatives (Committee on Transportation and Infrastructure, Committee on 

Homeland Security, and Committee on Oversight and Government Reform). In addition, 

the Consolidated Appropriations Act, 2008, requires that we report to the Committees on 

Appropriations of the Senate and House of Representatives on DHS’s certification of 10 

conditions outlined in section 522(a) of the Department of Homeland Security 

Appropriations Act, 2005, related to the development and implementation of the Secure

Flight program. See Pub. L. No. 110-161, Div. E, § 513, 121 Stat. 1844, 2072-73 (2007). 

10PARIS is the acronym for the Performance and Results Information System, which is

TSA’s inspections database. This database assists TSA management by providing factual 

and analytical information on the compliance of TSA-regulated entities. There are

approximately 1,700 PARIS prompts, which serve as guidelines for TSA inspectors. 

Page 5 GAO-08-1136T 
requirements (including airport perimeter security and cargo security, as 

well as screening of employees, baggage, and passengers). With respect to

watch-list matching, inspection guidelines instruct inspectors regarding 

the aspects of air carrier watch-list matching that should be tested, such as 

whether air carriers are comparing the names of all passengers against 

names on the most current No Fly and Selectee lists in accordance with 

the procedures outlined in TSA’s security directives. 

TSA conducts watch-list-related inspections at air carriers’ corporate 

security offices (where policies and procedures are established on how 

watch-list matching is to be performed) and at airports (where policies 

and procedures for responding to a potential match are implemented). 

TSA’s principal security inspectors are responsible for conducting 

inspections at domestic air carriers’ corporate headquarters. These 

inspectors assess air carriers’ compliance with security requirements and 

provide direct oversight of air carriers’ implementation of and compliance 

with TSA-approved security programs. Field inspectors—known as 

transportation security inspectors—conduct watch-list-related inspections 

at airports. They are responsible for a multitude of TSA-related activities,

including conducting inspections and investigations of airports and air 

carriers, monitoring compliance with applicable civil aviation security 

policies and regulations, resolving routine situations that may be 

encountered during the assessment of airport security, participating in 

testing of security systems in connection with compliance inspections, 

identifying when enforcement actions should be initiated, and providing 

input on the type of action and level of penalty commensurate with the 

nature and severity of a violation that is ultimately recommended to TSA’s

Office of Chief Counsel. 

To further enhance commercial aviation security and as required by the 

Intelligence Reform and Terrorism Prevention Act of 2004, TSA is 

developing an advanced passenger prescreening program known as 

Secure Flight to assume from air carriers the function of matching 

passenger information against government-supplied terrorist watch lists 

for domestic, and ultimately international, flights.11 Through assumption of 

the watch-list-matching function from the air carriers, Secure Flight is 

intended to ensure a higher level of consistency than current air carrier 

watch-list matching and also help remedy possible misidentifications if a 

 11See Pub. L. No. 108-458, § 4012(a), 118 Stat. 3638, 3714-18 (2004) (codified at 49 U.S.C. § 

44903(j)(2)(C)). 

Page 6 GAO-08-1136T 
passenger’s name is similar to one found on a watch list. According to TSA 

plans, Secure Flight’s benefits, once the program becomes operational, 

will include 

• eliminating inconsistencies in current air carrier watch-list matching 

procedures, 

• decreasing the risk of unauthorized disclosure of sensitive watch-list 

information, 

• reducing the number of individuals who are misidentified as being on 

the No Fly or Selectee lists, and 

• integrating the redress process so that individuals are less likely to be

improperly or unfairly delayed or prohibited from boarding an aircraft. 

TSA expects to begin assuming from air carriers the watch-list matching 

function for domestic flights in January 2009, and to assume this function 

from U.S. Customs and Border Protection for flights departing from and to 

the Unites States by fiscal year 2010.

Since the terrorist attacks of September 11, 2001, TSA has imposed, 

through security directives, requirements for watch-list matching, which 

include identifying passengers with names similar to those on the No Fly 

and Selectee lists—a process TSA refers to as similar-name matching. 

Identifying passengers with names similar to those on the No Fly and 

Selectee lists is a critical component of watch-list matching because 

individuals may travel using abbreviated name forms or other variations of 

their names. Therefore, searching for only an exact match of the 

passenger’s name may not result in identifying all watch-listed individuals. 

Before undertaking revisions of the relevant security directives in 2008, 

TSA expected air carriers to conduct similar-name matching, but TSA’s 

security directives did not specify how many and what types of such name 

variations air carriers should compare. Consequently, the 14 air carriers 

we interviewed reported implementing varied approaches to similar-name 

matching. Some carriers reported comparing more name variations than 

others, and not every air carrier reported conducting similar-name 

comparisons. Air carriers that conduct only exact-name comparisons and 

carriers that conduct relatively limited similar-name comparisons are less 

effective in identifying watch-listed individuals who travel under name 

variations. Also, due to inconsistent air carrier processes, a passenger 

could be identified as a match to a watch-list record by one carrier and not 

by another, which results in uneven effectiveness of watch-list matching. 

Moreover, there have been incidents, based on information provided by

Prior to April 2008, 

TSA Watch-ListMatching 

Requirements Were 

Broad and Allowed 

Air Carriers 

Discretion in 

Comparing Name 

Variations, Which 

Resulted in Less 

Effective Processes 

Page 7 GAO-08-1136T 
TSA’s Office of Intelligence, of air carriers failing to identify potential 

matches by not successfully conducting similar-name matching. 

Generally, TSA had been aware that air carriers were not using equivalent 

processes to compare passenger names with names on the No Fly and 

Selectee lists. However, in early 2008 the significance of such differences 

was crystallized during the course of our review and following TSA’s 

special emphasis inspection of air carriers’ watch-list-matching capability. 

On the basis of these inspection results, in April 2008, TSA issued a revised 

security directive governing the use of the No Fly List to establish a 

baseline capability for similar-name matching to which all air carriers must 

conform. Also, TSA announced that it planned to similarly revise the 

Selectee List security directive to require the new baseline capability.12 

According to TSA officials, the new baseline capability is intended to 

improve the effectiveness of watch-list matching, particularly for those air 

carriers that had been using less-thorough approaches for identifying 

similar-name matches and those air carriers that did not conduct any 

similar-name comparisons. However, because the baseline capability 

requires that air carriers compare only the types of name variations 

specified in the security directive, TSA officials noted that the new 

baseline established in the No Fly List security directive is not intended to

address all possible types of name variations and related security 

vulnerabilities. Agency officials explained that based on their analysis of 

the No Fly and Selectee lists and interviews with intelligence community 

officials, the newly established baseline covers the types of name 

variations air carriers are most likely to encounter. TSA officials further 

stated that these revised requirements were a good interim solution 

because, among other reasons, they will strengthen security while not 

requiring air carriers to invest in significant modifications to their watchlist matching processes, given TSA’s expected implementation of Secure 

Flight beginning in 2009. If implemented as intended, Secure Flight is 

expected to better enable the use of passenger names and other 

identifying information to more accurately match passengers to the 

subjects of watch-list records. 

 12In September 2008, TSA informed us that the revised Selectee List security directive was 

still in the agency’s internal clearance process, and did not provide us a targeted issuance 

date. 

Page 8 GAO-08-1136T 
Until 2008, TSA had conducted limited testing of air carriers’ similar-namematching capability, although the agency had undertaken various efforts 

to assess domestic air carriers’ compliance with watch-list matching 

requirements in the No Fly and Selectee list security directives. These 

efforts included a special emphasis assessment conducted in 2005 and 

regular inspections conducted in conjunction with annual inspection 

cycles. However, the 2005 special emphasis assessment focused on air 

carriers’ capability to prescreen passengers for exact-name matches with 

the No Fly List, but did not address the air carriers’ capability to conduct

similar-name comparisons. Regarding inspections conducted as part of 

regular inspection cycles, TSA’s guidance establishes that regulatory 

requirements encompassing critical layers of security need intensive 

oversight, and that testing is the preferred method for validating 

compliance. However, before being revised in 2008, TSA’s inspection 

guidelines for watch-list-related inspections were broadly stated and did 

not specifically direct inspectors to test air carriers’ similar-namematching capability. Moreover, TSA’s guidance provided no baseline 

criteria or standards regarding the number or types of such variations that 

must be assessed. Thus, although some TSA inspectors tested air carriers’ 

effectiveness in conducting similar-name matching, the inspectors did so 

at their own discretion and without specific evaluation criteria. 

Until a 2008 Special 

Emphasis Inspection, 

TSA Had Conducted 

Limited Testing of Air 

Carriers’ Capability to 

Perform Similar-Name

Matching 

In response to our inquiry, six of TSA’s nine principal security inspectors 

told us that their assessments during annual inspection cycles have not

included examining air carriers’ capability to conduct certain basic types 

of similar-name comparisons. Also, in reviewing documentation of the 

results of the most recent inspection cycle (fiscal year 2007), we found 

that available records in TSA’s database made references to namematching tests in only 6 of the 36 watch-list-related inspections that 

principal security inspectors conducted, and in only 55 of the 1,109 

inspections that transportation security inspectors conducted.13 Without 

baseline criteria or standards for air carriers to follow in conducting 

similar-name comparisons, TSA has not had a uniform basis for assessing 

compliance. Further, without routinely and uniformly testing how 

effectively air carriers are conducting similar-name matching, TSA may not 

have had an accurate understanding of the quality of air carriers’ watchlist-matching processes. 

 13According to TSA data, these 1,145 watch-list-related inspections (36 plus 1,109) covered 

60 domestic air carriers, and most of the air carriers were inspected multiple times. 

Page 9 GAO-08-1136T 
However, TSA began taking corrective actions during the course of our 

review and after it found deficiencies in the capability of air carriers to 

conduct similar-name matching during the January 2008 special emphasis 

inspection.14 More specifically, following the January 2008 inspection, TSA 

officials reported that TSA began working with individual air carriers to 

address identified deficiencies. Also, officials reported that, following the

issuance of TSA’s revised No Fly List security directive in April 2008, the 

agency had plans to assess air carriers’ progress in meeting the baseline

capability specified in the new security directive after 30 days, and that the 

agency’s internal guidance for inspectors would be revised to help ensure

compliance by air carriers with requirements in the new security directive. 

Further, in September 2008, TSA updated us on the status of its efforts 

with watch-list matching. Specifically, TSA provided us with the results of 

a May 2008 special emphasis assessment of seven air carriers’ compliance 

with the revised No Fly List security directive. Although the details of this 

special emphasis assessment are classified, TSA generally characterized 

the results as positive. Also, the TSA noted that it plans to work with 

individual air carriers, as applicable, to analyze specific failures, improve 

system performance, and conduct follow-up testing as needed. Further, 

officials noted that the agency’s internal handbook, which provides 

guidance to transportation security inspectors on how to inspect air 

carriers’ compliance with requirements, including watch-list-matching 

requirements, was being revised and was expected to be released later this

year. Officials stated that the new inspection guidance would be used in 

conjunction with TSA’s nationwide regulatory activities plan for fiscal year 

2009. However, while these actions and plans are positive developments, it 

is too early to determine the extent to which TSA will assess air carriers’ 

compliance with watch-list-matching requirements based on the new 

security directives since these efforts are still underway and have not been

completed. 

 14According to TSA officials, the January 2008 special emphasis inspection covered 52 

domestic air carriers and 31 foreign air carriers.

Page 10 GAO-08-1136T 
Over the last 4 years, we have reported that the Secure Flight program 

(and its predecessor known as the Computer Assisted Passenger 

Prescreening System II or CAPPS II) had not met key milestones or 

finalized its goals, objectives, and requirements, and faced significant 

development and implementation challenges.15 Acknowledging the 

challenges it faced with the program, in February 2006, TSA suspended the 

development of Secure Flight and initiated a reassessment, or 

rebaselining, of the program, which was completed in January 2007. In 

February 2008, we reported that TSA had made substantial progress in 

instilling more discipline and rigor into Secure Flight’s development and 

implementation, including preparing key systems development 

documentation and strengthening privacy protections.16 However, we 

reported that challenges remain that may hinder the program’s progress 

moving forward. Specifically, TSA had not (1) developed program cost and 

schedule estimates consistent with best practices, (2) fully implemented 

its risk management plan, (3) planned for system end-to-end testing in test

plans, and (4) ensured that information-security requirements are fully 

implemented. If these challenges are not addressed effectively, the risk of

the program not being completed on schedule and within estimated costs 

is increased, and the chances of it performing as intended are diminished. 

DHS Has Made 

Progress in 

Developing and 

Implementing the 

Secure Flight 

Program, but 

Challenges Remain 

That May Hinder the 

Program Moving 

Forward 

To address these challenges, we made several recommendations to DHS 

and TSA to incorporate best practices in Secure Flight’s cost and schedule 

estimates and to fully implement the program’s risk-management, testing, 

and information-security requirements. DHS and TSA officials generally 

agreed to implement the recommendations and reported that they are 

making progress doing so. According to TSA officials, the “initial cutover” 

or assumption of the watch-list matching function from one or more air 

carriers for domestic flights is scheduled to begin in January 2009. 

However, as of July 2008, TSA had not developed detailed plans or time 

frames for assuming watch-list matching from all air carriers for domestic 

flights. We will continue to evaluate TSA’s efforts to develop and 

implement Secure Flight and its progress in addressing our prior 

recommendations as part of our ongoing review.

 15See GAO, Aviation Security: Progress Made in Systematic Planning to Guide Key

Investment Decisions, but More Work Remains, GAO-07-448T (Washington, D.C.: Feb. 13, 

2007). 

16See GAO, Aviation Security: Transportation Security Administration Has 

Strengthened Planning to Guide Investments in Key Aviation Security Programs, but 

More Work Remains, GAO-08-456T (Washington, D.C.: Feb. 28, 2008).

Page 11 GAO-08-1136T 
Until the Secure Flight program is implemented, TSA’s oversight of air 

carriers’ compliance with watch-list-matching requirements remains an 

important responsibility. In this regard, TSA’s April 2008 revision of the No

Fly List security directive—and a similar revision planned for the Selectee

List security directive—are significant developments. The April 2008 

revision establishes a baseline name-matching capability applicable to all 

domestic air carriers. Effective implementation of the baseline capability 

should strengthen watch-list-matching processes, especially for those air 

carriers that had been using less-thorough approaches for identifying 

similar-name matches. Concurrently, revised internal guidance for TSA’s 

inspectors can help ensure that compliance inspections of air carriers are 

conducted using the standards specified within the security directives as 

evaluation criteria. At the time of our review, TSA was in the initial stage

of revising the internal guidance for inspectors. As a result, it is too early 

to determine the extent to which updated guidance for principal security

inspectors and transportation security inspectors will strengthen oversight

of air carriers’ compliance with the security directive requirements. Going 

forward, TSA officials acknowledge that the baseline capability specified 

in the revised No Fly List security directive and the similar revision 

planned for the Selectee List security directive—while an improvement—

does not address all vulnerabilities identified by TSA and does not provide 

the level of risk mitigation that is expected to be achieved from Secure 

Flight. Thus, TSA officials recognize the importance of—and the 

challenges to—ensuring continued progress in developing and deploying 

the Secure Flight program as soon as possible. 

Concluding 

Observations 

Madam Chairwoman, this concludes my statement. I would be pleased to 

answer any questions that you or other members have at this time. 

Page 12 GAO-08-1136T 
For questions regarding this testimony, please contact Cathleen A. Berrick,

Director, Homeland Security and Justice Issues, at (202) 512-3404 or 

berrickc@gao.gov. 

Other key contributors to this statement were Mona Blake, Danny R. 

Burton, Ryan Consaul, R. Eric Erdman, Michele C. Fejfar, Richard B. 

Hung, Thomas F. Lombardi, Sara Margraf, Victoria E. Miller, Maria 

Soriano, and Margaret Vo. 

Page 13 GAO-08-1136T 

GAO Contact and 

Staff 

Acknowledgments 

(440759) 
This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
GAO’s Mission The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “E-mail Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, DC 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Ralph Dawn, Managing Director, dawnr@gao.gov, (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, DC 20548 

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER