BORDER SECURITY

Additional Steps 

Needed to Ensure 

That Officers Are 

Fully Trained

Report to Congressional Requesters

December 2011

GAO-12-269

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-269, a report to 

congressional requesters

December 2011

BORDER SECURITY

Additional Steps Needed to Ensure That Officers 

Are Fully Trained

Why GAO Did This Study

Recent incidents involving potential 

terrorists attempting to enter the 

country highlight the need for a vigilant 

and well-trained workforce at the 

border. U.S. Customs and Border 

Protection (CBP), within the 

Department of Homeland Security, is 

the lead federal agency in charge of 

inspecting travelers and goods for 

admission into the United States. 

About 20,000 CBP officers play a 

central role in ensuring that CBP 

accomplishes its mission of securing 

the border while also facilitating the 

movement of millions of legitimate 

travelers and billions of dollars in 

international trade. GAO was asked to 

assess the extent to which CBP has 

(1) revised its training program for 

newly hired CBP officers in accordance 

with training standards and 

(2) identified and addressed the 

training needs of incumbent CBP 

officers. GAO analyzed data and 

documentation related to the agency’s 

training efforts, such as its covert test 

program and its training records. GAO 

also interviewed CBP officials and CBP 

officers. This is a public version of a 

sensitive report that GAO issued in 

October 2011. Information CBP 

deemed sensitive has been redacted.

What GAO Recommends

To improve CBP training efforts, GAO

recommends that the CBP

Commissioner evaluate the “Back to 

Basics” training course; analyze covert 

test results; establish a policy for 

training responsibilities, including

oversight of training records; and, 

conduct a training needs assessment. 

CBP concurred with the

recommendations and is taking steps 

to address them. 

What GAO Found

CBP revised its training program for newly hired CBP officers in accordance with 

its own training development standards. Consistent with these standards, CBP

convened a team of subject-matter experts to identify and rank the tasks that 

new CBP officers are expected to perform. As a result, the new curriculum was 

designed to produce a professional law enforcement officer capable of protecting 

the homeland from terrorist, criminal, biological and agricultural threats. In 

addition, the curriculum stated that the CBP officer is to draw conclusions and 

take appropriate action to identify behavioral indicators displayed by criminals, 

effectively interview travelers to identify potential threats, identify fraudulent 

documents, and use technology in support of the inspection process.

CBP has taken some steps to identify and address the training needs of its 

incumbent CBP officers, but could do more to ensure that these officers are fully 

trained. GAO examined CBP’s results of covert tests conducted over more than 

2 years and found significant weaknesses in the CBP inspection process at the 

ports of entry that were tested. In response to these tests, CBP developed a 

“Back to Basics” course in March 2010 for incumbent officers but has no plans to 

evaluate the effectiveness of the training. Moreover, CBP has not conducted an 

analysis of all the possible causes or systemic issues that may be contributing to 

the test results. Further evaluation of the training and causes underlying covert 

test results could help inform CBP about whether the training is sufficient to 

address the weaknesses identified by the covert tests or if adjustments are 

needed. In addition, CBP offices are responsible for recording their employees’ 

training records; however, CBP does not have a policy that assigns responsibility 

to port management to ensure that their staff enter data into its training records 

system completely and accurately. A policy outlining the roles and responsibilities 

of offices and positions for training could help clarify which offices and positions 

are responsible for identifying and addressing training needs and for holding 

these offices accountable for their responsibilities. Moreover, CBP currently does 

not have reliable training completion records to ensure CBP officers received 

required training or other training relevant to their assigned duties. Based on 

GAO’s analysis of training records, more than 4,000 customs officers have not 

completed the immigration fundamentals, immigration law, and agricultural 

fundamentals courses, although they were required to complete them during a 

cross-training program. According to CBP, the training completion records are 

incomplete, and it is unlikely that the officers did not complete the required crosstraining. Nevertheless, without reliable training records; CBP cannot provide 

reasonable assurance that all customs officers completed the required crosstraining. Further, CBP has not conducted a needs assessment that would identify 

any gaps between identified critical skills and incumbent officers’ current skills

and competencies. A needs assessment could enhance CBP’s ability to ensure 

its workforce is training to meet its mission.

View GAO-12-269. For more information, 

contact Richard M. Stana at (202) 512-8816 or 

StanaR@gao.gov.
Page i GAO-12-269 Border Security

Letter 1 

Background 4

CBP Revised Its Training for Newly Hired CBP Officers Consistent 

with Its Training Standards 11

CBP Has Taken Steps to Identify and Address Incumbent Officer 

Training Needs but Could Do More to Improve Oversight 16

Conclusions 25

Recommendations for Executive Action 26

Agency Comments and Our Evaluation 26

Appendix I Customs and Border Protection Officer Staffing Policy and 

Specialized Teams 30

Appendix II Mandatory and Specialized Courses for CBP Officers 32

Appendix III Comments from the Department of Homeland Security 35

Appendix IV GAO Contact and Staff Acknowledgments 38

Table

Table 1: Overview of OTD Training Development Standards 12

Figures

Figure 1: Percentage of Legacy Officers In the Workforce, Fiscal 

Year 2004 to July 16, 2011 6

Figure 2: National Training Plan Expenditures for CBP Employee 

Training, Fiscal Years 2008 to 2011 (projected) 9

Figure 3: Overview of Revised Training Program for Newly Hired 

CBP Officers 14

Figure 4: Key CBP Offices and Positions Involved in Incumbent 

CBP Officer Training 19

Contents
Page ii GAO-12-269 Border Security

Abbreviations

CBP Customs and Border Protection

DHS Department of Homeland Security

FDAU Fraudulent Document Analysis Unit

FLETA Federal Law Enforcement Training Accreditation

IA Office of Internal Affairs

NTP National Training Plan

OFO Office of Field Operations

OPM Office of Personnel Management

OTD Office of Training and Development

SME subject matter expert

TAB Training Advisory Board

TRAEN Training Records and Enrollment Network

VLC Virtual Learning Center

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

United States. The published product 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.
Page 1 GAO-12-269 Border Security

United States Government Accountability Office

Washington, DC 20548

December 22, 2011

Congressional Requesters

The September 11, 2001, terrorist attacks, as well as recent incidents 

involving potential terrorists attempting to enter the country, highlight the 

need for a vigilant and well-trained workforce at the border. Since the 

creation of the Department of Homeland Security (DHS) in 2003, U.S. 

Customs and Border Protection (CBP)—a component within DHS—

serves as the lead federal agency in charge of inspecting travelers and 

goods entering the United States at air, land, and sea ports of entry.1

CBP officers, who number about 20,000, play a central role in carrying 

out this responsibility. A highly trained CBP officer corps is critical to 

ensure that CBP accomplishes its dual mission of securing the border by 

refusing attempted illegal entry to the United States and facilitating the 

cross-border movement of millions of legitimate travelers and billions of 

dollars in international trade. Since the creation of the CBP officer position 

in 2003 and the subsequent development of the original CBP officer basic 

training curriculum, the role of the CBP officer has involved increased 

emphasis on countering threats posed by terrorists and others attempting 

to fraudulently enter the country with altered or genuine travel 

documents.2

In 2007, we reported on vulnerabilities and inefficiencies in traveler 

inspections, including challenges ports of entry faced in delivering 

required training to CBP officers.

 As a result, CBP has revised its training to reinforce the law 

enforcement mindset within the CBP officer.

3

 

1

CBP consists of the following component offices: the Office of Air and Marine, the Office 

of Border Patrol, and the Office of Field Operations. 

Specifically, we reported that CBP did 

not know the extent to which legacy officers had received required cross2

The original CBP officer curriculum was launched in 2004 and subsequently revised in 

2009. 

3

GAO, Border Security: Despite Progress, Weaknesses in Traveler Inspections Exist at 

Our Nation’s Ports of Entry, GAO-08-219 (Washington, D.C.: Nov. 5, 2007). For GAO 

products related to document security, see GAO, Border Security: Security of New 

Passports and Visas Enhanced, but More Needs to Be Done to Prevent their Fraudulent 

Use, GAO-07-1006 (Washington, D.C.: July 31, 2007) and GAO, Combating Terrorism: 

Additional Steps Needed to Enhance Foreign Partners Capacity to Prevent Terrorist 

Travel, GAO-11-637 (Washington, D.C.: June 30, 2011).

 
 

Page 2 GAO-12-269 Border Security

training and whether newly hired officers were fully proficient in their 

required duties.4

In this context, you asked us to assess the extent to which CBP has 

(1) revised its training program for newly hired CBP officers in accordance 

with its training standards since the launch of the curriculum in 2004 and 

(2) identified and addressed the training needs among incumbent CBP 

officers. 

Therefore, we recommended that the agency develop 

data on cross-training to determine whether the officers received the 

required training. We also recommended that the agency incorporate 

specific tasks into the on-the-job training program for newly hired officers 

and measure officer proficiency in performing those tasks. CBP generally 

agreed with our recommendations and we discuss actions it has taken in 

response to these recommendations later in this report.

This report is a public version of the prior sensitive report that we 

provided to you. DHS deemed some of the information in the prior report 

as Sensitive Security Information (SSI), which must be protected from 

public disclosure. Therefore, this report omits sensitive information about 

the specific results related to CBP’s covert testing. Although the 

information provided in this report is more limited in scope, it addresses 

the same questions as the sensitive report. Also, the overall methodology 

used for both reports is the same.

To address our first objective, we analyzed the process CBP followed to 

revise its curriculum for newly hired CBP officers against its Office of 

Training and Development (OTD) standards.5

 

4

Legacy officers are former inspectors from the U.S Customs Service, the U.S. 

Immigration and Naturalization Service, and the U.S. Department of Agriculture.

We reviewed and analyzed 

documents related to the design and implementation of the curriculum 

review process, including reports identifying the key job tasks for newly 

hired CBP officers and describing the curriculum review process, trainee 

evaluations of the former basic academy and pretest of the new basic 

academy, and other training-related documents. We interviewed relevant 

officials from the Office of Field Operations (OFO), OTD, and the Field 

5

OTD standards are based in part on federal laws and regulations, including the 

Government Employees Training Act (5 U.S.C. §§ 4101-4120) and its implementing 

regulations (5 C.F.R. pt. 410), as well as Executive Order No. 11,348, 32 Fed. Reg. 6335 

(Apr. 20, 1967), as amended (“Providing for the Further Training of Government 

Employees”). 
 

Page 3 GAO-12-269 Border Security

Operations Academy who are responsible for designing and 

implementing the revised curriculum.

To address our second objective, we analyzed the results of CBP covert 

testing of document fraud6 detection at ports of entry for the period 

April 2009 through August 16, 2011, and interviewed officials at the Office 

of Internal Affairs (IA) to understand the methodology of covert testing 

operations.7

 

6

For the purpose of the tests, CBP used travel documents that in part or in whole have 

been altered, counterfeited, stolen, presented by someone other than the rightful holders, 

or who received it by legitimate means through misrepresentation. According to IA, CBP 

focused their tests on genuine documents that were presented fraudulently in all of the 

covert tests except two which used counterfeit documents.

We assessed the reliability of the covert test data by verifying 

CBP’s calculations of the covert test interdiction rate. We found these 

data to be sufficiently reliable for our purpose. We also analyzed relevant 

CBP training policies and procedures for incumbent officers, CBP course 

offerings for incumbent officers, and CBP’s job task analysis that 

identifies the differences between the former and new basic academy 

training to identify possible incumbent officer training needs. We obtained 

and reviewed relevant data from CBP’s Training Records and Enrollment 

Network (TRAEN) for the period 2004 through 2011, as well as 

supplemental data from OTD. We assessed the reliability of the TRAEN 

data by (1) interviewing knowledgeable officials about how training 

completion is documented, and how the completions are entered in 

TRAEN; (2) reviewing relevant documentation; and, (3) comparing 

TRAEN records to training completion records we obtained directly from 

select field offices. We determined the TRAEN data were not sufficiently 

reliable to demonstrate CBP officer training completion and training 

needs, as discussed later in this report. Further, we interviewed OFO and 

OTD officials on CBP efforts to address any identified training needs and 

compared these efforts with OTD training standards. To assess CBP 

policies for tracking, overseeing, and evaluating incumbent officer 

training, we interviewed officials at the OFO Training branch, the Office of 

Field Programs, the Office of Passenger Admissibility, and Passenger 

Programs, including the Fraudulent Document Analysis Unit (FDAU) and 

the Enforcement Policy office.

7

CBP covert tests of document fraud inspections began in April 2009 and are ongoing. We 

selected August 16, 2011, due to the end of our data collection period. 
 

Page 4 GAO-12-269 Border Security

We also visited three ports of entry—John F. Kennedy International 

Airport, Laredo land port, and Dallas-Fort Worth International Airport—

during January and February 2011 to observe CBP officer inspections 

and to interview CBP officers and port management regarding incumbent 

CBP officer training and inspection policies and procedures. We selected 

John F. Kennedy International Airport and Dallas-Fort Worth International 

Airport because of the large volume of international passenger traffic 

going through these airports. We selected Laredo land port because the 

postacademy course was piloted at this port of entry. Our observations 

helped us understand CBP officer passenger inspections. We also 

interviewed officials with training-related responsibilities at CBP 

headquarters, the New York field office, and three land ports of entry we 

visited— John F. Kennedy International Airport, Laredo land port, and 

Dallas-Ft. Worth International Airport. Our observations from these visits 

and interviews are illustrative and provide insights but are not 

generalizable to all ports of entry across the country.

The scope of our review was limited to training provided to all CBP 

officers who serve in the passenger environment at ports of entry with an 

emphasis on passenger admissibility. It did not include training on 

customs procedures, radiation detection or training provided to those 

CBP officers who serve as canine specialists, or those who may serve in 

the cargo environment.

We conducted this performance audit from December 2010 to December 

2011, 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 our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

CBP is the lead federal agency charged with interdicting terrorists, 

criminals, and inadmissible travelers at ports of entry while facilitating the 

flow of legitimate travel and commerce at the nation’s borders. In March 

2003, inspectors from the three legacy agencies—the Department of 

Justice’s U.S. Immigration and Naturalization Service, the Department of 

the Treasury’s U.S. Customs Service and the Department of Agriculture’s 

Animal and Plant Health Inspection Service—were merged to form CBP. 

As part of the merger, CBP cross-trained CBP officers to simultaneously 

perform immigration and customs inspection functions as well as identify 

and refer possible agricultural violations for further inspection. DHS stated 

Background 
 

Page 5 GAO-12-269 Border Security

that the ability to use inspectors interchangeably for immigration and 

customs inspection functions would allow the agency to more effectively 

use its personnel and accelerate the processing of legitimate travelers, 

thereby enabling CBP to more effectively enhance efforts to secure the 

border. OFO—one of the CBP component offices—manages and deploys 

CBP officers who operate within 20 field offices, and 329 ports of entry 

composed of airports, seaports, and designated land ports of entry 

throughout the United States plus selected locations overseas.8

As of July 2011, nearly 20,000 CBP officers operated at U.S. ports of 

entry and other locations overseas. The total number of onboard CBP 

officers peaked in fiscal year 2009 at 21,339 but declined in fiscal years 

2010 and 2011 to 20,431.9 According to OFO, the decline in the onboard 

number of CBP officers is due, in part, to a decline in traveler volume 

resulting in a decline in collected user fees that fund CBP officers located 

at airports and seaports.10

 

8

CBP also has preclearance operations at 15 international ports in Aruba, Bahamas, 

Bermuda, Canada, and Ireland, where travelers are processed for advance approval to 

enter the United States prior to departure from the respective airport. 

At the end of fiscal year 2004, there were 

about 18,000 CBP officers, the majority of whom were legacy officers 

from the Department of Treasury’s U.S. Customs Service, followed by 

legacy officers from the Department of Justice’s U.S. Immigration and 

Naturalization Service and the Department of Agriculture’s Animal and 

Plant Health Inspection Service. Since fiscal year 2007, the total number 

of legacy officers has declined. As of July 2011, 45 percent of the CBP 

officer workforce was comprised of legacy officers. Since fiscal year 2007, 

the annual attrition rate of legacy officers has declined from 6.5 percent to 

2.4 percent in fiscal year 2010. Figure 1 illustrates the percentage of 

legacy CBP officers compared to the total CBP officer workforce over 

time.

9

As of July 16, 2011, approximately 1 percent of CBP officers worked in CBP offices other 

than the Office of Field Operations. 

10CBP collects user fees to recover certain costs incurred for processing, among other 

things, air and sea passengers; and various private and commercial land, sea, air, and rail 

carriers and shipments. These fees were created by the Consolidated Omnibus Budget 

Reconciliation Act of 1985 (COBRA) and are deposited into the Customs User Fee 

Account. CBP also receives appropriations, including a Salaries and Expenses 

appropriation. To pay for certain expenses, it reimburses its salaries and expenses 

appropriation from its COBRA collections. 

Staffing, Budgeting, and 

Training
 

Page 6 GAO-12-269 Border Security

Figure 1: Percentage of Legacy Officers In the Workforce, Fiscal Year 2004 to 

July 16, 2011

CBP officer responsibilities for passenger inspection are primarily focused 

at the primary and secondary inspection areas at ports of entry. In the 

primary inspection area, CBP officers are expected to rapidly analyze 

passenger admissibility by sufficiently questioning the passenger, 

examining the passenger’s travel documents, and using appropriate

technology to identify those passengers that can be immediately admitted 

into the United States or need to be referred to a secondary inspection 

area for a more thorough inspection, if necessary. Specifically, CBP 

officers in the primary inspection area are expected to first examine travel 

documents by comparing the document to the passenger and then ask 

questions to confirm the identity of the traveler. They also may inspect 

travelers’ luggage. CBP officers who serve in the secondary inspection 

area conduct closer inspection of travel documents and possessions and 

can use multiple law enforcement databases to verify the traveler’s 

identity, background, and purpose for entering the country. CBP officers 

may also serve in specialized teams to support the inspection functions at 

CBP Officer Responsibilities 

for Passenger Inspections 
 

Page 7 GAO-12-269 Border Security

the ports of entry. For example, CBP established the Passenger Analysis 

Unit team, which is responsible for cross-checking passenger data in 

automated systems to identify high-risk passengers before they enter the 

country. Appendix I provides more detail on CBP officer staffing policy 

and OFO specialized teams.

OFO is to coordinate with OTD to ensure that component training 

complies with OTD training standards. In the case of CBP officers, OFO 

and OTD share responsibility for ensuring that newly hired and incumbent 

CBP officers are sufficiently trained. OTD is responsible for designing, 

developing, delivering, and evaluating CBP-wide training courses and 

establishing training standards and policies for the program, while OFO is 

responsible for identifying the training requirements of CBP officers, 

providing subject-matter experts to assist in the development and 

instruction of some training courses, and reviewing training that is 

developed. OFO established a training branch in 2003 to serve as a 

liaison between OTD and OFO. OFO also established FDAU in 2005, 

which performs analyses of fraudulent documents that have been seized 

to identify global patterns and trends. FDAU is to provide training and 

training materials to enhance CBP officers’ abilities to detect fraudulent 

documents and thereby increase the number of interceptions through the 

sharing of information within CBP and DHS and with other U.S. and 

foreign government agencies.

OTD is also responsible for overseeing and managing the CBP training 

budget, known as the National Training Plan (NTP), and prioritizing 

training development and delivery via the Training Advisory Board 

(TAB).11 Also, OTD developed and manages the Virtual Learning Center 

(VLC) where CBP officers can take self-paced courses on a variety of 

topics.12

 

11TAB is comprised of the Deputy Commissioner and the Assistant Commissioners from 

CBP offices, such as OTD, Office of Administration, OFO, Office of Border Patrol, Office of 

Air and Marine and Human Resources Management. The TAB is responsible for ensuring 

that training requirements are identified and prioritized so that CBP resources are 

matched to the component agency’s priority needs.

Further, OTD operates and manages basic and advanced 

training schools for CBP officers. Specifically, OTD operates the Field 

Operations Academy, which trains and prepares newly hired CBP 

Officers for deployment to U.S. ports of entry. OTD is responsible for 

managing and overseeing CBP’s official training records system, Training 

12According to OTD officials, there are over 2,000 courses on the VLC. 

CBP Training Responsibilities
 

Page 8 GAO-12-269 Border Security

Records and Enrollment Network (TRAEN), and the Academy Course 

Management System, a training scheduling and tracking system that 

OFO uses to monitor newly hired CBP officers’ successful completion of 

basic training. Each year, OTD is to request that the CBP offices provide 

a list of specific training courses and the approximate number of 

participants they would like to send to training. OTD is to compile these 

requests and present them to TAB, which is to review and prioritize the 

courses to be delivered that year. In addition, TAB approves the total NTP 

budget amount for each fiscal year. On the basis of the Board’s priorities, 

OTD is to develop the NTP budget for the fiscal year and is also 

responsible for monitoring the delivery of the training and managing the 

NTP budget during the year. The NTP budget funds the delivery of 

training for all CBP offices—including training for OFO—for a single fiscal 

year. In fiscal year 2009, CBP training expenditures peaked due, in part, 

to receipt of supplemental funding to hire and train CBP officers and 

Border Patrol agents. Since fiscal year 2009, CBP’s NTP budget 

expenditures have declined due to increasing budget constraints. 

Figure 2 displays CBP’s actual NTP budget expenditures from fiscal 

years 2008 through 2010 and its projected end-of-year expenditures for 

fiscal year 2011. OFO has also funded the development and delivery of 

its own training courses for CBP officers when they have not received 

funding from the NTP.13

 

13In fiscal year 2007, OFO spent about $1.1 million on the development of the fraudulent 

document examination course and other courses which, at the time, were not funded by 

the NTP. OFO’s expenditures for training courses have declined as the courses have 

been funded by the NTP budget.
 

Page 9 GAO-12-269 Border Security

Figure 2: National Training Plan Expenditures for CBP Employee Training, Fiscal 

Years 2008 to 2011 (projected)

IA has oversight authority for all aspects of CBP operations, personnel, 

and facilities. IA is responsible for ensuring compliance with all CBP-wide 

programs and policies and operates a covert test program to ensure 

compliance. Following the issuance of the results of our covert tests of 

border security in May 2008,14

 

14GAO, Summary of Covert Tests and Security Assessments for the Senate Committee on 

Finance, 2003-2007, 

CBP initiated covert tests to evaluate 

CBP’s capabilities to detect document fraud. Specifically, CBP focused its 

tests on evaluating CBP’s detection of impostors, or individuals who 

attempt to enter the United States fraudulently by using a genuine, 

unaltered travel document that belongs to another person. CBP also 

continued covert tests to detect cargo containing illicit radioactive 

GAO-08-757 (Washington, D.C.: May 2008). This report summarizes 

our findings of covert test and security assessment work performed for the Senate 

Finance Committee and reported at hearings from January 2003 to September 2007.

Specifically, we concluded that terrorists could use counterfeit identification to pass 

through most of the tested ports of entry with little chance of being detected.
 

Page 10 GAO-12-269 Border Security

material, among others.15

All newly hired CBP officers are required to complete a basic training 

program and demonstrate proficiency in CBP officer duties. Incumbent 

CBP officers are required to take mandatory courses such as information 

technology security, occupational safety, and human trafficking 

awareness, among others. CBP provides most mandatory courses on a 

one-time or annual basis via the VLC. OFO has mandatory course 

requirements, such as fraudulent document detection, and has also 

developed specialized courses for incumbent officers assigned to 

specialized teams. However, CBP does not require that all CBP officers 

assigned to specialized teams complete the specialized training 

developed for that team. According to OFO, management must balance 

the operational needs of the port with the availability of the training. 

Appendix II lists examples of mandatory and specialized courses for CBP 

officers for fiscal year 2011.

OFO uses these ongoing test results to identify 

potential training needs.

As we previously reported, in 2003, CBP initiated a multiyear crosstraining program to equip new and legacy officers with the tools 

necessary to perform primary immigration and customs inspections, and 

sufficient knowledge to identify agricultural inspections in need of further 

examination.16

 

15CBP previously conducted covert tests of radioactive material detection from April 2007 

through August 2008. CBP conducted 28 tests at 22 of the nation’s busiest seaports of 

entry. CBP has designated the results of these tests as Sensitive Security Information 

(SSI). 

CBP required all legacy customs officers complete three 

courses—covering immigration fundamentals, immigration law, and 

agriculture fundamentals—regardless of where they were assigned. All 

legacy immigration officers were required to complete three courses—

customs fundamentals, customs law, and agriculture fundamentals—

regardless of where they were assigned. Further, based on their 

assignment, legacy officers were required to complete additional courses 

specific to their assignment and port environment. In June 2011, CBP 

officially retired the cross-training courses and replaced them with revised 

modules. OFO instructed managers, supervisors, and training officers to 

use these new materials as refresher training for officers who transfer to a 

16GAO, Border Security: Despite Progress, Weaknesses in Traveler Inspections Exist at 

Our Nation’s Ports of Entry, GAO-08-219 (Washington, D.C.: Nov. 5, 2007).

CBP Officer Training 
 

Page 11 GAO-12-269 Border Security

new assignment or environment or who return to inspection duties after 

an extended absence.

CBP has prepared training development standards for all CBP training 

programs and courses to ensure that training delivered to CBP 

employees meets established quality standards of instruction and 

evaluation. OTD standards are based, in part, on federal laws and 

regulations, which require agencies to establish training programs that 

support their mission and meet specified standards, including identifying 

training needs, prioritizing these needs, and evaluating the results of 

training programs and plans.17 Also, CBP develops and revises its basic 

training for new CBP officers to meet Federal Law Enforcement Training 

Accreditation (FLETA) standards, which provide law enforcement 

agencies with an opportunity to voluntarily demonstrate that they meet an 

established set of professional standards and receive appropriate 

recognition. Finally, Standards for Internal Control in the Federal 

Government provide criteria for the management and oversight of agency 

operations, including training programs.18

In 2009, CBP revised its training program for new officers in accordance 

with its training development standards. These standards are based on 

legal standards that guide the development of training in the federal 

government and standards that guide federal law enforcement training.19

 

17Relevant federal laws and regulations include the Government Employees Training Act 

(5 U.S.C. §§ 4101-4120); Executive Order No. 11,348, 32 Fed. Reg. 6335 (Apr. 20, 1967), 

as amended; and 5 C.F.R. pt. 410. See also 5 C.F.R. pt. 330 (providing general guidelines 

for federal agencies on recruitment, selection, and placement); 29 C.F.R. pt. 1607 

(providing uniform guidelines for the federal government on developing employee 

selection procedures that comply with federal antidiscrimination laws). 

OTD standards also contain specific guidance related to the following 

phases: (1) planning, (2) analysis, (3) design, (4) development, (5) 

evaluation, and (6) delivery of the course curriculum, which CBP adhered 

to in revising its training program. Table 1 provides an overview of the 

18Internal control standards provide a framework for agencies to achieve effective and 

efficient operations and ultimately to improve accountability. See GAO, Standards for 

Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: 

November 1999).

19These standards include 5 C.F.R. pt. 410 and 29 CFR pt. 1607, and FLETA 

accreditation standards.

CBP Training Standards

CBP Revised Its 

Training for Newly 

Hired CBP Officers 

Consistent with Its 

Training Standards
 

Page 12 GAO-12-269 Border Security

OTD training development phases and related standards and our 

assessment of how CBP efforts met these standards in revising its 

training for newly hired officers.

Table 1: Overview of OTD Training Development Standards

Training development phases and related standards

Was 

standard 

met?

Planning–-This phase involves the development of required documents 

necessary to initiate a training effort that adheres to FLETA Standards, 

including updating and validating the curriculum every 3-5 years. 

Yes

Analysis–- This phase of curriculum development involves convening a 

panel of subject matter experts identifying the needs, evaluating content, 

defining the target audience, and identifying the critical job tasks.

Yes

Design–-This phase requires the development of course goals, lesson 

objectives, and specific skills and knowledge the trainee will obtain. It also 

includes identifying the appropriate delivery method and location.

Yes

Development–-This phase involves the process of creating and submitting 

draft and final course materials, including gathering and organizing course 

content by removing redundant or unnecessary information and dividing the 

content into a logical structure of lessons and topics.

Yes

Evaluation – This phase involves determining training effectiveness. This 

also includes delivering the pilot course in a controlled environment and 

ensuring that the curriculum is aligned with the agency mission.

Yes

Delivery Considerations – This phase involves the delivery of the pilot 

course as well as the final acceptance of training materials.

Yes

Source: GAO analysis of CBP information.

OTD standards state that the training curriculum should be current, valid, 

and updated once every 3 to 5 years. CBP began the process of revising 

its training for new officers in 2009 after the initial launch of the CBP 

Officer curriculum in 2004, consistent with OTD standards for updating 

the training curriculum every 5 years. OTD, as well as other federal law 

enforcement training standards, state that programs should first identify 

the critical tasks that the individual is expected to perform in order to 

determine what training is needed. Consistent with these standards, OTD 

convened a team of subject matter experts (SMEs) to identify and rank 

the tasks that new CBP officers are expected to perform.20

 

20The team of subject-matter experts consisted of CBP officers from field locations and the 

training unit staff from the CBP Field Office Academy, the U.S. Department of Agriculture, 

and the OFO and OTD Headquarters Offices, including the OTD Research and Evaluation 

Branch. 

The team 
 

Page 13 GAO-12-269 Border Security

identified a total of 138 critical tasks that newly hired CBP officers are 

expected to perform within the first 2 years of employment. These 

included conducting thorough and accurate research to support 

inspections and investigations, and preparing thorough and accurate 

reports covering significant incidents and intelligence. Once the tasks 

were identified, the panel of SMEs compared the identified tasks to the 

tasks addressed in the existing curriculum to identify any skill gaps. OTD 

then developed specific courses with appropriate lessons and topics to 

ensure that these tasks were addressed in the new curriculum. For 

example, new modules on evidence preservation and secondary report 

writing were incorporated in the revised curriculum to address identified 

officer skill gaps in handling evidence and writing. Consistent with the 

OTD standard that requires a test run of a complete and approved course 

in a controlled environment by selected individuals representing the 

course’s learning audience, the new CBP officer curriculum was piloted to 

test its content and delivery prior to its launch in February 2011. As a 

result, the new officer training program course was expanded from about 

15 to 18 weeks and approximately 30 to 35 percent of the new officer 

curriculum is new or updated and expanded. Thus, the new officer 

training program complies with OTD’s standards that state the training 

curriculum should be current and valid.

OTD internal training standards also state that the training should be 

aligned with the current agency mission and current threats. According to 

OFO and OTD officials, the previous CBP officer curriculum focused 

primarily on preparing the officer to serve in the primary inspection 

function at a port. The SME panel recommended that the new officer 

curriculum be revised to produce a law enforcement officer capable of 

supporting CBP’s expanding antiterror mission. As a result, the new 

curriculum is designed to produce a professional law enforcement officer 

capable of protecting the homeland from terrorist, criminal, biological, and 

agricultural threats. Specifically, the new curriculum states that the CBP 

officer is expected, among other tasks, to draw appropriate conclusions 

and take appropriate action to identify behavioral indicators displayed by 

criminals and terrorists, effectively interview and analyze travelers to 

identify potential threats, expertly identify altered and counterfeit 

documents and impostors, and use technology in support of the 
 

Page 14 GAO-12-269 Border Security

inspection process.21

OTD standards also state that is important to identify the appropriate 

delivery method and location. In accordance with these standards, CBP 

determined that the training for new CBP officers would be divided into 

three components as shown in figure 3.

Upon completion of training, the newly hired CBP 

officer is expected to be able to perform the primary inspection function, 

as well as some aspects of the secondary inspection function.

Figure 3: Overview of Revised Training Program for Newly Hired CBP Officers

Pre-academy—According to OFO officials, the pre-academy component 

helps educate incoming CBP officers of job responsibilities before the 

agency commits the funds to send them to the Field Operations Academy 

in Glynco, Georgia, for basic training. OFO officials also stated that the 

 

21Specifically, the CBP officer is to correctly apply relevant laws to travelers and 

merchandise entering and leaving the country; employ nonintrusive technology to detect 

and deter terrorist and criminal activity; conduct thorough and accurate research to 

support inspections and investigations; prepare thorough and accurate reports covering 

significant incidents and intelligence; and use intelligence information and trends to 

identify high-risk travelers and cargo, among other duties.
 

Page 15 GAO-12-269 Border Security

pre-academy curriculum is structured because it recommends that a fixed 

curriculum be completed in a specific amount of time. Also, it contains a 

mix of classroom instruction and web-based courses to familiarize 

incoming CBP officers with the specific requirements of the law 

enforcement and inspections job, thereby helping to ensure that the preacademy training is consistent throughout the nation.

Basic academy—The SME panel recommended that the curriculum 

include intensified training to enhance officer vigilance and awareness 

though interview training, behavior analysis training to discern passenger 

behavior, report writing training, and training to detect fraudulent 

documents, among others. In addition, CBP increased the amount of time 

devoted to practical exercises in response to comments made by newly 

hired officers during pilot testing. For example, exercises in the passenger 

processing module increased from 11 hours in the old curriculum to 

33 hours in the revised curriculum. The revised curriculum was designed 

to enhance an officer’s ability to

• identify behavioral indicators displayed by terrorists and criminals;

• effectively interview and analyze travelers to identify potential threats;

• expertly identify altered and counterfeit documents and impostors; 

and

• use technology (including computers and other resources) in support 

of the inspection process.

Postacademy—In 2007, we reported that although CBP had issued 

guidance for on-the-job training of new CBP officers, CBP had difficulty in 

providing the training in accordance with the guidance.22

 

22

We

recommended that CBP incorporate the following into its on-the-job 

training program: (1) specific tasks that CBP officers must experience 

during on-the-job training and (2) requirements for measuring officer 

proficiency in performing those tasks. In response to our 

recommendations, CBP revised its postacademy training program by 

identifying specific tasks and developing a plan for measuring officer 

proficiency in those tasks. The revised postacademy training program 

combines classroom and on-the-job training and incorporates ongoing 

testing and evaluation of officer proficiency. The evaluations are tied to 

the critical tasks and competencies that a new officer must perform. In 

accordance with the new postacademy training program, prior to being 

GAO-08-219. 
 

Page 16 GAO-12-269 Border Security

able to perform primary inspections independently, a training officer must 

certify that the officer is proficient to perform the task. The revised 

postacademy training began in June 2011. Consistent with OTD training 

standards that call for measuring the effectiveness of training, CBP plans 

to ask new officers to evaluate their basic academy and postacademy 

training. In addition, CBP plans to survey both new officers and their 

supervisors several months after a new officer completes on-the-job 

training to determine the effectiveness of the training. Consistent with 

OTD standards that its training meets federal law enforcement standards, 

OTD officials stated that the curriculum received its federal law 

enforcement training accreditation in November 2011.

CBP has taken steps to identify the training needs of its incumbent 

officers, by for example, conducting covert tests to assess vulnerabilities 

and systemic weaknesses at ports of entry and identifying possible officer 

training needs, but could do more to analyze the tests’ results. In 

response to its covert tests, CBP has delivered two required training 

courses for incumbent officers, but it has not evaluated the effectiveness 

of these courses. Also, OFO officials stated that supervisors identify CBP 

officer training needs. However, CBP faces challenges in establishing 

policies and procedures to guide its component offices’ efforts to 

implement and oversee training, and ensuring that it has reliable training 

data. Moreover, CBP has not conducted an analysis of possible skill gaps 

that may exist between identified critical skills all incumbent officers 

should possess and incumbent officers’ current skills.

To identify vulnerabilities and weaknesses at U.S. ports of entry, CBP IA 

conducts covert tests in which undercover inspectors attempt to enter the 

United States with genuine documents used fraudulently. The tests are 

designed to provide a snapshot of the level of a port’s performance 

related to the testing objectives on a particular day. We examined CBP’s 

results of covert tests conducted over more than 2 years and found 

significant weaknesses in the CBP inspection process at the ports of 

entry that were tested.23

 

23Certain details regarding the test results were omitted because DHS considered them to 

be Sensitive Security Information.

Although the results are not fully generalizable to 

all ports, OFO officials stated that the tests are useful to identify possible

CBP Has Taken Steps 

to Identify and 

Address Incumbent 

Officer Training 

Needs but Could Do 

More to Improve 

Oversight 

CBP Uses Covert Tests to 

Help Identify Possible 

Training Needs, but 

Further Evaluation Could 

Enhance Their Usefulness
 

Page 17 GAO-12-269 Border Security

weaknesses and vulnerabilities. Following each covert test, IA prepared a 

written post-test summary of the tests and outcomes, debriefed with 

senior port management and headquarters officials, and provided data to 

OFO on the test outcomes. In some of the summaries, IA inspectors 

identified what they observed to be the key factors that contributed to 

successful outcomes, as well as potential vulnerabilities.

In response to initial test results, OFO developed and mandated an 

updated annual fraudulent document course in August 2009.24 Also, in 

March 2010, OFO developed and mandated a “Back to Basics” course 

that emphasized the basic inspection duties that all CBP officers are 

required to perform during a primary inspection. In July 2011, OFO began 

implementing a follow-on course which includes more specific instruction. 

CBP administers postcourse evaluations to CBP officer trainees to obtain 

their feedback on the “Back to Basics” course but does not have plans to 

fully evaluate the effectiveness of this course by checking the extent to 

which the officers have retained the information over time. OTD officials 

stated that they conduct these types of evaluations for the newly hired 

CBP officer basic training but do not do so for this one for incumbent 

officers, due to time and cost constraints. However, we have previously 

reported that agencies should assess the extent to which training and 

development efforts contribute to improved performance and results to 

help ensure that the agency is not devoting resources to training that may 

be ineffective.25

CBP has not conducted an analysis of all the possible causes or systemic 

issues that may be contributing to the test results. The protocols for 

covert tests state that IA will provide a comprehensive report at the 

conclusion of all cover tests that will summarize test results and identify 

systemic issues. As of August 2011, neither IA nor OFO have conducted 

such an analysis due to staffing and time constraints, according to IA and 

OFO officials. However, this type of analysis would help CBP identify any 

An evaluation of the impact of these training courses on 

CBP officer performance could help CBP know the extent to which such 

training is a sufficient response to the covert test results or whether 

adjustments to the training or other management actions are needed.

 

24CBP developed and mandated its first annual fraudulent document detection course for 

all CBP officers in May 2004. 

25GAO, Human Capital: A Guide for Assessing Strategic Training and Development 

Efforts in the Federal Government, GAO-04-546G (Washington, D.C.: Mar. 1, 2004).
 

Page 18 GAO-12-269 Border Security

patterns or trends that indicate the extent to which CBP officer training, 

performance, or other systemic issues may contribute to the issues 

identified in the covert tests. Without a comprehensive assessment, it is

difficult for CBP to identify the systemic issues underlying the test results.

In December 2008, CBP issued a directive assigning general roles and 

responsibilities for training to OTD and other CBP offices, such as 

identifying OTD as the centralized leader for all CBP training. However, 

CBP has not established policies or procedures to guide component 

offices’ efforts to implement and oversee training. Figure 4 illustrates the 

key offices and positions that OFO identified as responsible for incumbent 

CBP officer training.

CBP Faces Challenges in 

Identifying and Addressing 

Training Needs

CBP Lacks Policies and 

Procedures to Ensure 

Incumbent CBP Officers 

Complete Training
 

Page 19 GAO-12-269 Border Security

Figure 4: Key CBP Offices and Positions Involved in Incumbent CBP Officer Training

OFO does not have a policy that specifies the roles and responsibilities of 

each of these offices and positions for training implementation and 

oversight. Federal regulations require that agencies establish policies 
 

Page 20 GAO-12-269 Border Security

governing employee training, including a statement of the alignment of 

employee training and development with agency strategic plans, the 

assignment of responsibility to ensure the training goals are achieved, 

and the delegation of training approval authority to the lowest appropriate 

level.26 In addition, internal control standards state, in a good control 

environment, areas of authority and responsibility are clearly defined and 

appropriate lines of reporting are established.27 Internal control standards 

also require that responsibilities be communicated within an organization. 

According to OFO, the OFO Programs and Policy branch is responsible 

for overseeing and coordinating the development of policy to govern 

incumbent officer training, including policy that assigns roles and 

responsibilities.28

However, OFO could not provide a policy document outlining how 

supervisors would identify training needs and coordinate training. Also, 

according to the OFO officials, port management and field office directors 

are responsible for ensuring that CBP officers complete mandatory and 

other training related to their job duties. However, OFO officials in 

headquarters and at the ports stated that no policy exists that assigns 

these responsibilities to port management or field offices. In addition, 

senior CBP officials stated that Field Training Officers help ensure that 

CBP officers are receiving the training they need to perform their 

According to the OFO officials, a policy would be useful 

because it helps clearly define the responsibilities of all offices involved in 

incumbent CBP officer training. Specifically, a policy outlining the roles 

and responsibilities of offices and positions for training would help clarify 

which offices and positions are responsible for ensuring incumbent officer 

training needs are identified and addressed. However, the acting branch 

chief of the OFO Programs and Policy branch stated staffing constraints 

have limited the branch’s ability to initiate the process of developing a 

policy that clearly assigns responsibility for all offices involved in CBP 

officer training. According to OFO officials, supervisors are responsible for 

identifying officer training needs and requesting training to meet these 

needs. For example, in June 2011, CBP instructed supervisors to identify 

training needs and use the post academy modules to address those 

needs.

 

26See 5 C.F.R. § 410.201(b).

27GAO/AIMD-00-21.3.1. 

28The Programs and Policy branch is located within the OFO Office of Planning, Program 

Analysis and Evaluation and was established in 2009.
 

Page 21 GAO-12-269 Border Security

assigned duties, and that internal measures are in place to assess 

training needs and accomplishments nationwide. However, officials from 

the OFO Training branch stated that Field Training Officers are assigned 

to help deliver training to the ports but are not required to oversee the 

completion of required training by CBP officers at their respective ports. 

Further, OFO could not provide documentation confirming the roles and 

responsibilities of the Field Training Officer. A policy outlining the roles 

and responsibilities of offices and positions for training could help 

eliminate such confusion and clarify which offices and positions are 

responsible for identifying and addressing training needs and for holding 

these offices and individuals accountable for their responsibilities.

CBP currently lacks reliable training completion records to ensure CBP 

officers received required training or other training relevant to their 

assigned duties. According to OTD and OFO officials, the training 

completion records maintained in TRAEN, CBP’s official record of 

training, are incomplete or contain inaccurate information, such as the 

dates of training completion. As a result, officials from OTD’s Office of 

Operations, which plans and manages the annual National Training Plan 

(NTP) budget, stated they developed their own records of training 

completions that consist of TRAEN records supplemented with data they 

gather from e-mail archives. Also, officials from two of the three ports we 

visited stated they rely on locally developed databases or data sources 

other than TRAEN to track CBP officers’ training records.

We found, based on our analysis of TRAEN records, more than 4,000 

onboard legacy customs officers have not completed the immigration 

fundamentals, immigration law, and agricultural fundamentals courses 

although they were required to complete them during the cross-training 

program.29

 

29The cross-training program took place from 2003 to June 2011.

According to OFO officials, the training completion records 

maintained in TRAEN are incomplete, and it is unlikely that legacy officers 

did not complete required cross-training. Nevertheless, without reliable 

training records, CBP cannot provide reasonable assurance that all 

legacy customs officers completed required cross-training courses. OTD 

stated that CBP offices are responsible for recording their employees’ 

training records in TRAEN. However, CBP does not have a policy that 

assigns the responsibility for entering records to its offices or that assigns 

oversight responsibility to port management to ensure that their staff enter 

CBP Lacks Reliable Data to 

Track Training 
 

Page 22 GAO-12-269 Border Security

data into TRAEN completely and accurately. CBP is currently in the 

process of transferring the TRAEN system to the VLC and training CBP 

officials on how to properly enter training records in the new system. 

However, OFO and OTD officials stated that even trained employees 

sometimes do not enter training records completely or in a timely manner. 

Internal control standards state control activities—such as policies, 

procedures and management supervision—help to ensure that all 

transactions are completely and accurately recorded.30 Further, having 

reliable data could enable agency managers to compare actual 

performance to planned or expected results throughout the organization 

and analyze differences. Moreover, having reliable data to measure the 

degree to which CBP officers have completed required or recommended 

training for their assigned positions would put CBP in a better position to 

gauge the results of its cross-training program and other CBP officer 

training and measure its progress towards achieving CBP officer training 

goals.

CBP has taken steps to identify training needs among incumbent CBP 

officers but has not conducted a comprehensive training needs 

assessment to identify and address potential gaps in incumbent officers’ 

current skills and competencies. Under executive order and federal 

regulations, agencies are to review, not less than annually, programs to 

identify training needs, establish priorities for training, and allocate 

resources in accordance with those priorities.31

CBP has taken some steps to identify and analyze incumbent officer 

training needs. In 2008, CBP initiated the first job task analysis for the 

CBP officer position since 2003 by identifying nearly 300 job tasks and 

Further, OTD training 

development standards state that a training needs assessment is needed 

to identify knowledge or skill gaps and suggest material for new or followon training. Specifically, the analysis stage of training development 

includes conducting a training needs assessment to identify skill or 

knowledge gaps, conducting a job task analysis to identify critical 

competencies required for the target audience, and analyzing the target 

audience to develop appropriate training, among other steps.

 

30GAO/AIMD-00-21.3.1. 

31See Exec. Order No. 11,348, § 303, 32 Fed. Reg. 6335, 6335 (Apr. 20, 1967); 5 C.F.R. 

§ 410.201(c)-(d). 

CBP Has Not Fully 

Identified and Addressed 

Potential Incumbent 

Officer Training Needs
 

Page 23 GAO-12-269 Border Security

about 100 competencies that all incumbent CBP officers are expected to 

perform regardless of their currently assigned duties or port environment.

In 2011, CBP also completed a curriculum gap analysis, which compared 

the newly revised basic academy curriculum with the previous basic 

academy training to identify new skills or material that incumbent CBP 

officers may not have learned in their basic academy training. For 

example, the previous curriculum trained CBP officers to perform 75 

critical tasks while the newly revised curriculum trains newly hired officers 

to perform 138 critical tasks. According to OTD officials, the curriculum 

gap analysis identified a shift in the training philosophy and delivery 

methods and some changes in course content. For example, the revised 

training for newly hired officers aims to instill a law enforcement mindset 

by adding new courses in weapons training, evidence preservation, and 

courtroom testimony, among others, and by expanding courses that are 

designed to increase situational awareness and anti-terrorism vigilance 

among the CBP officers. It also increases physical conditioning and the 

number of hours of practical exercises related to conducting primary 

inspections and examining documents as well as course content to reflect 

new laws related to immigration processing and operating new 

equipment. The revised curriculum also adds more training in skills that 

CBP officers need to perform in secondary processing, including using 

appropriate computer systems and following procedures to verify 

passenger admittance.

However, CBP has not conducted a training needs assessment or 

analyzed the target audience to determine what training is needed. For 

example, it has not evaluated potential gaps between the skills and 

competencies of current incumbent officers to identify appropriate training 

needs and possible gaps between (1) the nearly 300 job tasks and 100 

competencies that all incumbent officers are expected to perform and 

(2) any additional skills and knowledge that are currently taught in the 

revised basic academy curriculum. In addition, CBP has not reviewed 

incumbent CBP officers’ previous training and experience, including 

cross-training or any on-the-job training, to identify what training they may 

have completed. OTD training standards state that it is important to 

review the previous experience and training to better identify the training 

needs for particular audiences. In 2007, we recommended that CBP 

develop data on cross-training programs to determine whether officers 

received required training so the agency may measure progress toward 

achieving its training goals. As of September 2011, CBP has not 

developed these data or measured the extent to which officers completed 

required cross-training. In June 2011, CBP retired the cross-training 

courses and replaced the courses with new postacademy modules that 
 

Page 24 GAO-12-269 Border Security

contain updated content. However, CBP could review the previous 

training records of its legacy and other incumbent officers to help identify 

what training they have completed and to identify which postacademy 

modules or other training they may need to take to perform their assigned 

duties.

Conducting a comprehensive training needs assessment could help CBP 

analyze and identify potential skill gaps and training needs for incumbent 

officers—including legacy officers—and better position it to develop 

training to meet these needs, thus ensuring its officers are equipped to 

meet the operational demands at the border. OTD criteria state that CBP 

training managers may use a variety of techniques during a training 

needs assessment to gather and analyze information about the 

necessary training content for proposed training, including:

• interviews with SMEs;

• focus groups (moderated group interviews) involving SMEs and 

representatives of the learning audience;

• observation of and interviews with those performing a particular job or 

task in the field;

• review of course critiques, test results, and performance evaluations;

• instructional review, course audit, or content review of existing 

training; and

• review of field incident reports, critical factors identified, and lessons 

learned.

OFO officials stated that a training needs assessment would be useful, 

but they have been unable to conduct one due to budget constraints and 

may not be able to undertake a comprehensive training needs 

assessment until fiscal year 2013, at the earliest. However, CBP could 

begin the initial steps of planning for a training needs assessment for 

incumbent officers in fiscal year 2012. Office of Personnel Management 

(OPM) guidance states that a training needs assessment should include a 

plan that sets goals or objectives for the training needs assessment; 

evaluates the agency readiness and identifies key roles; evaluates prior 

or other relevant needs assessments; prepares a project plan; and 

clarifies success measures and program milestones. This plan could be 

similar to the preparation of a project plan. Specifically, elements of a 

project plan include (1) establishing clear and achievable training goals; 

(2) balancing the competing demands for quality, scope, time, and cost; 

(3) adapting the specifications, plans, and approach to the different 

concerns and expectations of the various stakeholders involved in the 

project; and (4) developing milestone dates to identify points throughout 
 

Page 25 GAO-12-269 Border Security

the project to reassess efforts under way to determine whether project 

changes are necessary. OFO officials stated that such a plan could be

helpful in initiating the process for conducting a training needs 

assessment. Project management standards also call for assigning 

responsibility and accountability for ensuring the results of program 

activities are carried out. Developing a project plan could also help CBP 

ensure that it is well-positioned to conduct a comprehensive training 

needs assessment in 2013 for its incumbent officers—while allowing for 

monitoring and oversight of the staff efforts through the completion of 

interim milestones to ensure progress in being made as intended.

CBP has designed its training program for newly-hired CBP officers to 

comply with its standards. Such compliance can contribute to ensuring 

that newly-hired officers are prepared to accomplish CBP’s mission of 

securing the border and simultaneously facilitating the cross-border 

movement of millions of legitimate travelers and billions of dollars in 

international trade. However, CBP faces challenges in ensuring that the 

training needs of its nearly 20,000 incumbent CBP officers are properly 

identified and addressed. The results of its covert tests are not 

generalizable to the entire CBP officer population. However, they reveal a 

consistent pattern of weaknesses among the officers tested in their ability 

to perform basic tasks and these weaknesses have not been corrected. 

CBP has no plans for assessing the effectiveness of its “Back to Basics” 

course and subsequent follow-on training developed in response to the 

covert tests. Assessing the effectiveness in improving incumbent officer 

performance could help CBP management know if the training is a 

sufficient response to the weaknesses identified by the covert tests or if 

additional adjustments are needed.

In addition, CBP has not established policies and procedures to guide 

OFO’s implementation and oversight of incumbent officer training, 

including entry of complete and accurate data into TRAEN. Having 

policies and procedures to ensure that managers are fulfilling their 

oversight responsibilities, including maintaining accurate and complete 

training records, could help improve CBP’s knowledge of whether 

incumbent CBP officers have been properly trained.

Given CBP’s commitment to reinforcing the law enforcement mindset 

among all CBP officers, evaluating the training needs of the current CBP 

officers so that they can be addressed in a timely and cost-efficient 

manner is important. In addition, given budget constraints on training 

resources throughout the government, planning accordingly to ensure 

Conclusions 
 

Page 26 GAO-12-269 Border Security

that skill needs of the incumbent CBP officers are assessed could help 

ensure that a road map is in place for conducting such an assessment 

thereby ensuring that CBP’s officer workforce is equipped to meet the 

operational demands at the border.

To improve CBP training efforts, we recommend that the CBP 

Commissioner take the following four actions:

(1) Conduct an evaluation of the effectiveness of the “Back to Basics” and 

subsequent follow-on training,

(2) Conduct a comprehensive assessment of its covert test results to 

identify the causes of and systemic issues underlying the results,

(3) Establish a policy that specifies roles and responsibilities for CBP 

officer training implementation and related oversight, including oversight 

responsibilities to ensure that training records are entered in TRAEN 

completely and accurately and

(4) Develop a plan for conducting a training needs assessment to address 

any skill gaps for incumbent CBP officers and then implement that plan.

We provided a draft of the sensitive version of this report to DHS for 

comment. DHS provided written comments which are reprinted in 

appendix III. In commenting on the sensitive version of this report, DHS, 

including CBP, agreed with the recommendations. Specifically, DHS 

stated that CBP is taking action or has taken action to address each 

recommendation.

DHS agreed with the first recommendation that CBP conduct an 

evaluation of the effectiveness of the training course and subsequent

follow-on training, and stated that the Office of Field Operations and the 

Office of Training and Development will work in partnership to determine 

if the Back to Basics and follow-on training had an effect on overall CBP 

officer performance by conducting a study and obtaining the results of 

any further covert tests by March 30, 2012. Regarding the second 

recommendation that CBP conduct a comprehensive assessment of its 

covert test results, DHS agreed and stated that the Office of Internal 

Affairs plans to conduct a comprehensive assessment of its covert test 

results for fiscal year 2011 by December 30, 2011. DHS agreed with the 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 27 GAO-12-269 Border Security

third recommendation that CBP establish a policy that specifies roles and 

responsibilities for CBP officer training implementation and related 

oversight, and stated that a policy will be developed by March 30, 2012, 

to clarify the training roles and responsibilities at all national and local 

levels to include the responsibility for maintaining accurate training 

records. Regarding the fourth recommendation that CBP develop a plan 

for conducting a training needs assessment to address any skill gaps for 

incumbent CBP officers and then implement that plan, DHS stated that 

OFO is coordinating with OTD to evaluate current training to identify any 

existing training gaps, and plan to address any identified needs through 

formal training by December 31, 2012. If effectively implemented, these 

actions should address the intent of the recommendations.

DHS raised an issue regarding the report’s characterization of the DHS 

covert test results. Specifically, DHS stated that the covert tests were 

deliberately designed to test only a specific aspect of the overall primary 

inspection process within the wide range of inspectional duties that CBP 

officers perform and are not a valid measure of overall officers’ 

performance and capabilities or reliability of the entire admissibility 

process. The report noted that the test results are not generalizable to all 

ports of entry. However, OFO officials emphasized that the tests are 

informative in that they can help management identify possible 

weaknesses and vulnerabilities in the inspection process and in the CBP 

officer ability to perform basic tasks. Specifically, the tests are designed to 

provide a snapshot of the level of a port’s performance related to the 

testing objectives. Further, according to the protocols, the tests are 

designed to test and challenge CBP officers on their abilities, adherence 

to policies and procedures, and use of technologies to detect and prevent 

individuals attempting to enter the United States through the use of 

document fraud. OFO also developed and mandated an annual 

fraudulent document course based on the initial response to the covert 

test results. Nevertheless, we incorporated language throughout the 

report to clarify the objectives and the scope of the covert tests. We 

believe that this report presents a valid characterization of the covert test 

results and their potential uses.

DHS also provided technical comments, which we incorporated into the 

report as appropriate.

We will send copies of this report to the Department of Homeland 

Security, the Commissioner of U.S. Customs and Border Protection, the 

appropriate congressional committees and other interested parties. In 
 

Page 28 GAO-12-269 Border Security

addition, the report will be available at no charge at GAO’s website 

https://www.gao.gov. 

If you or your staff members have any questions about this report, please 

contact me at (202) 512-8816 or stanar@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Other GAO contacts and staff 

acknowledgments are listed in appendix IV.

Richard M. Stana

Director, Homeland Security and Justice Issues
 

Page 29 GAO-12-269 Border Security

List of Requesters

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Peter King

Chairman

The Honorable Bennie Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

The Honorable Gus Bilikaris

House of Representatives

The Honorable Paul Broun

House of Representatives

The Honorable Charlie Dent

House of Representatives

The Honorable Mike McCaul

House of Representatives

The Honorable Candice Miller

House of Representatives

The Honorable Mike Rogers

House of Representatives

The Honorable Lamar Smith

House of Representatives
Appendix I: Customs and Border Protection 

Officer Staffing Policy and Specialized Teams

Page 30 GAO-12-269 Border Security

In February 2009, Customs and Border Protection (CBP) management 

and the union that represents CBP officers reached an agreement to 

allow CBP officers the opportunity to bid and rotate to a new work unit, 

specialized team, or port location every 1 or 2 years.1

The following list includes specialized teams that operate at all U.S. air, 

land, and sea ports of entry. Ports may have additional CBP officer 

specialized teams depending on their size, environment, and mission 

demands.

This bid-androtation system for CBP officers is based on seniority and is designed to 

increase officer morale and retain CBP officers. The system also provides 

port management the ability to assign CBP officers to units based on 

immediate, changing workload demands.

These are the passenger work units charged with the interdiction of highrisk passengers attempting to facilitate surreptitious entry of contraband 

or who may be associated with terrorist activities.

These are the work units charged with the use of automated systems to 

target high-risk passengers, conduct threat analysis, or using after-action 

reports to identify threats.

This work unit is charged with processing violations to the Immigration 

and Nationality Act (INA) which may result in adverse actions, such as 

determination of inadmissibility to the United States.

This work unit is charged with targeting and examining outbound 

commercial cargo for violations of law, rules or regulations.

 

1

CBP officers who bid and rotate to most work units or specialized teams must only 

commit to working in that unit for one bid cycle, or for 1 fiscal year. As of 2010, CBP 

officers who bid and rotate to the Passenger Enforcement Roving Team or CounterTerrorist Response Team, the Passenger Analysis Unit or Tactical Analysis Group, and 

the Training team are required to serve in that unit for two bid cycles, or fiscal years, due 

to the specialized training officers in these units may receive.

Appendix I: Customs and Border Protection 

Officer Staffing Policy and Specialized Teams

Passenger Enforcement 

Roving Team/CounterTerrorist Response

Passenger Analysis

Unit/Tactical Analysis 

Group 

Passenger Control 

Secondary 

Outbound 
Appendix I: Customs and Border Protection 

Officer Staffing Policy and Specialized Teams

Page 31 GAO-12-269 Border Security

This work unit is charged with the use of automated systems to target 

high-risk commercial shipments, conduct analysis, or use after-action 

reports to identify threats.

This work unit is charged with the inbound and/or outbound interdiction of 

narcotics and other contraband, including currency, arms and 

ammunition, as well as terrorist related materials in the cargo and/or 

passenger environments.

This work unit is charged with providing nationally mandated and locally 

designed training including, but not limited to pre-academy, postacademy, 

virtual learning center, and unification training.

This work unit is charged with the scheduling of all regular day and 

overtime assignments, as well as the administration of the Customs 

Officers Pay Reform Act, including, but not limited to, overtime cap 

compliance and annuity integrity.

This work unit is charged with developing and conducting local firearms 

programs, including but not limited to, conducting required firearms 

qualifications and use of force training, maintaining quantities of firearmsrelated supplies and equipment, and conducting annual firearms

inventory.

Advance Targeting Unit

Anti-Terrorism Contraband 

Enforcement Team

Training

Scheduling 

Firearms
Appendix II: Mandatory and Specialized 

Courses for CBP Officers

Page 32 GAO-12-269 Border Security

The following mandatory courses are required either on a one-time basis 

or annually for all nonsupervisory Customs and Border Protection (CBP) 

officers. The specialized courses were developed to enhance incumbent 

nonsupervisory CBP officer skills in specific areas and are not mandatory.

Mandatory Training Courses for All CBP Officers

• Notification and Federal Employee Antidiscrimination and Retaliation 

Act of 2002 (No Fear Act) Training1

• IT Security Awareness and Rules of Behavior Training

• CBP Safeguarding Classified National Security Information

• U.S. Constitution

• DHS Suspicious Activity Report Training

• DHS Together Employee and Organizational Resilience Safety Stand 

Down Training2

• New Employee Safety Training

• Occupant Emergency Plan

• New Employee Orientation Program

• Hazard Communication

• Understanding Sensitive But Unclassified Information

• Emergency and Disaster Preparedness Training

• Federal Emergency Management Agency Independent Study 

Program: IS-546 Cooperative Program

• Personal Search Handbook Annual Certification – Officer

• Human Trafficking Awareness & Unaccompanied Alien Children

• Basic Records Management 2010

• CBP Suicide Prevention

• Confined Spaces Entry Training3

• Hearing Conservation

• Blood Borne Pathogens & Tuberculosis Prevention

• First Responder Awareness Level Training

 

1

This law requires federal agencies to train employees on their rights and remedies under 

antidiscrimination and whistleblower protection laws. (Pub. L. No. 107-174,§ 202(c), 116 

Stat. 566, 569 (2002). 

2

In September 2009, DHS created an employee resilience and wellness program called 

“DHS Together: Building a More Resilient Workforce.” The DHS Employee and 

Organizational Resilience training is part of an initiative to improve the health and 

resilience of the entire DHS workforce. The training discusses the tools and resources 

DHS employees have at their disposal to balance work and life issues.

3

This training is mandatory only for CBP officers assigned to perform searches in confined 

spaces. 

Appendix II: Mandatory and Specialized 

Courses for CBP Officers
Appendix II: Mandatory and Specialized 

Courses for CBP Officers

Page 33 GAO-12-269 Border Security

• Hazardous and Dangerous Cargo

• Fire Safety

• Fraud Prevention Program Document Training

• Border Search of Electronic Information

• Firearms Proficiency and Qualification

• Firearms Night Fire

• Intermediate Use of Force Device Re-Certification

• Control and Arrest Techniques

• Edged Weapons Defense

• Defensive Tactics

Nonmandatory Specialized Training Courses for CBP Officers

• Advanced Admissibility Secondary Processing

• Air or Sea Cargo Targeting Training

• Air or Sea Passenger Analysis Unit

• Anti-Terrorism Contraband Enforcement Team – Air, Land, or Sea

• Automated Air Cargo Manifest System

• Automated Export System Targeting

• Bonded Warehouse Training

• Counter Terrorism Response Rover Training

• Custody and Management of Seized Property Alternate

• Detecting Deception and Eliciting Responses

• Driver Training Program

• Driver Instructor Training Program

• Electronic Control Device Instructor Training Program

• Fines Penalties and Forfeitures Basic and Advanced

• Firearms Instructor Training Program

• Firearms Instructor Recertification Training Program

• Firearms Maintenance Armorer Training

• Foreign Trade Zone Class

• Hazardous Materials Training

• Incident Command System Training Program

• Instructional Presentation Skills

• Intermediate Force Instructor Training Program

• Master Exercise Practitioner Training Program4

• Outbound Currency Interdiction Training

 

4

This is a 3-week program conducted by the Federal Emergency Management Agency 

(FEMA) to train Air and Marine Interdiction Agents, CBP Officers, and Border Patrol 

Agents to be able to design, develop, and conduct tabletop exercises for their field 

locations. Upon completion of program, the participants will be certified to develop and 

conduct training exercises unique to their field locations.
Appendix II: Mandatory and Specialized 

Courses for CBP Officers

Page 34 GAO-12-269 Border Security

• Radiation Interdiction Academy

• Training Registration and Enrollment Network

• Vehicle and Cargo Imaging System – Operator

• Weapons of Mass Effect Training
Appendix III: Comments from the Department 

of Homeland Security

Page 35 GAO-12-269 Border Security

Appendix III: Comments from the 

Department of Homeland Security
Appendix III: Comments from the Department 

of Homeland Security

Page 36 GAO-12-269 Border Security
Appendix III: Comments from the Department 

of Homeland Security

Page 37 GAO-12-269 Border Security
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 38 GAO-12-269 Border Security

Richard M. Stana, (202) 512-8816 or stanar@gao.gov

In addition to the contact named above, Michael Dino, Assistant Director, 

Kathryn Bernet, Assistant Director, and Nanette J. Barton, Analyst-inCharge, managed this assignment. Jennifer Bryant and Edith Sohna 

made significant contributions to the work. Stanley Kostyla assisted with 

design and methodology. Frances Cook provided legal support. Katherine 

Davis provided assistance in report preparation.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(441028)
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