HOMELAND 

SECURITY

Agriculture Inspection 

Program Has Made 

Some Improvements, 

but Management 

Challenges Persist

Report to Congressional Requesters

September 2012

GAO-12-885

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-885, a report to 

congressional requesters 

September 2012

HOMELAND SECURITY 

Agriculture Inspection Program Has Made Some 

Improvements, but Management Challenges Persist

Why GAO Did This Study

According to DHS, invasive species 

cause an estimated $136 billion in lost 

agricultural revenue annually, and

since September 11, 2001, concerns 

have persisted about the vulnerability 

of agriculture to deliberate introduction 

of foreign pests and disease. DHS and 

USDA manage the AQI program, 

which places agriculture inspectors at

U.S. ports of entry to inspect imported 

agriculture products and intercept 

foreign pests. GAO reported in 2006 

on management challenges in the 

program and made seven 

recommendations to improve it. GAO 

was asked to examine the extent to 

which (1) DHS and USDA 

implemented GAO’s

recommendations; (2) data on arrivals, 

inspections, and interceptions are used 

for managing the program; and (3) the 

views of AQI agriculture specialists on 

their work environment have changed 

since 2006. GAO surveyed a 

representative sample of agriculture 

specialists and supervisors; reviewed 

key documents and inspection 

procedures; visited five selected ports 

of entry based on size and entry 

pathways, such as air or sea; 

interviewed DHS and USDA officials; 

and reviewed AQI data. The survey 

instrument and most results can be 

viewed at GAO-12-884SP. 

What GAO Recommends

GAO recommends, among other 

things, that (1) DHS and USDA 

develop a joint strategic plan for the 

AQI program, (2) DHS develop a plan 

for implementing a staffing model, and 

(3) DHS and USDA take steps to 

improve the reliability of certain data. 

DHS and USDA agreed with the 

recommendations.

What GAO Found

The Department of Homeland Security (DHS) and the U.S. Department of 

Agriculture (USDA) have taken steps to implement all seven of the 

recommendations GAO made in 2006 to improve the Agriculture Quarantine 

Inspection (AQI) program, but they face challenges in fully implementing four of 

them. Specifically, DHS and USDA have implemented GAO’s recommendations 

to improve information sharing, review DHS’s financial management system for 

the AQI program, and remove barriers to timely and accurate transfers of AQI 

user fees—collected for AQI services provided in connection with the arrival of 

international air passengers and conveyances at U.S. ports. However, DHS and 

USDA face challenges in fully implementing GAO’s recommendations to adopt 

meaningful performance measures, establish a national risk-based staffing 

model, improve the agriculture canine program, and revise user fees to cover 

program costs. For example, in 2006, GAO recommended that DHS and USDA 

adopt meaningful performance measures for assessing the AQI program’s 

effectiveness at intercepting foreign pests and disease. DHS and USDA have 

expanded the use of one type of performance measure but have not developed 

measures for all aspects of the AQI program that are important for its 

management. In addition, the AQI program does not have a strategic plan—a 

leading practice that would provide DHS and USDA with a framework for defining 

the mission of what the program seeks to accomplish, setting goals to achieve 

desired results, and identifying performance measures for gauging progress 

toward those goals. Furthermore, DHS has undertaken efforts to respond to 

GAO’s recommendation to develop a national, risk-based staffing model but does 

not yet have one, and DHS anticipates that the model will recommend significant 

staffing increases. DHS officials told GAO they do not have the resources to 

increase staff, but the agency has not developed a plan that assesses the risk of 

potential fiscal constraints on its ability to implement the staffing model. Without a 

plan or strategy to address potential resource constraints on staffing by

considering the fiscal resources that may realistically be available, DHS risks 

increasing the vulnerability of the agriculture sector to foreign pests and disease.

The AQI program uses data on arrivals, inspections, and interceptions at U.S. 

ports of entry to determine how well agriculture inspections identify prohibited 

materials and to review ports’ performance, but data quality issues may prevent 

AQI program officials from making full use of the data. For example, the data 

may not be reliable. DHS and USDA recognize that data quality is an ongoing 

issue and in 2004 created an interagency group to address this issue. However, 

from 2010 to 2011, joint DHS-USDA reviews of 22 selected ports found 

discrepancies in the data at about half of the ports reviewed (10 out of 22). Data 

reliability has the potential to affect other key efforts that are currently under way, 

such as the program’s staffing model. Without reliable data, AQI program officials 

do not have assurance that they have the information needed to manage the 

program. 

GAO also presents analysis of survey data from 2006 and 2012 on agriculture 

specialists’ and supervisors’ views about their work environment.

View GAO-12-885. To view the e-supplement 

online, click on GAO-12-884SP. For more 

information, contact Lisa Shames at (202) 

512-3841 or shamesl@gao.gov. 
Page i GAO-12-885 Agriculture Inspections

Letter 1 

Background 4

DHS and USDA Have Taken Steps to Implement GAO’s Seven 

Recommendations, but Have Not Fully Implemented Four of 

Them 8

Limitations in the Arrival, Inspection, and Interception Data May 

Hinder Their Use in Managing the Program 19

Survey Responses Show Some Changes in Agriculture Specialists’ 

Views 22

Conclusions 32

Recommendations for Executive Action 33

Agency Comments and Our Evaluation 34

Appendix I Objectives, Scope, and Methodology 37

Appendix II Summary of Responses to Open-ended Survey Questions in 

2006 and 2012 43

Appendix III Comments from the U.S. Department of Agriculture 45

Appendix IV Comments from the Department of Homeland Security 48

Appendix V GAO Contacts and Staff Acknowledgments 51

Tables

Table 1: Estimates for the Closed-ended Question “Do You Believe 

That You Are Sufficiently Trained to Perform Your 

Agriculture Inspection Duties?” (in percent) 23

Table 2: Estimates for the Closed-ended Question “Is the 

Information Delivered to You in a Timely Manner to be 

Useful?” (in percent) 26

Contents
Page ii GAO-12-885 Agriculture Inspections

Table 3: Estimates for the Closed-ended Question “Do You Have 

Enough Time to Look for Pests in Agriculture Materials 

Intercepted from Passengers?” (in percent) 28

Table 4: Estimates for the Closed-ended Question “In General, Do 

You Feel that the Work of a CBP Agriculture Specialist Is 

Respected by CBP Officers and Management?” (in 

percent) 29

Table 5: Estimates for the Closed-ended Question “In Your 

Experience, Does Your Port Currently Have Enough 

Agriculture Specialists to Carry Out Agriculture Duties?” 

(in percent) 31

Table 6: GAO Summary of Responses to the Open-ended Question 

“What Is Going Well with Respect to Your Work as an 

Agriculture Specialist?” in 2006 Compared with 2012 43

Table 7: GAO Summary of Responses to the Open-ended Question 

“What Would You Like to See Changed or Improved with 

Respect to Your Work as an Agriculture Specialist?” in 

2006 Compared with 2012 44

Figure

Figure 1: Example of Primary and Secondary Inspection 

Procedures at an Airport 6

Abbreviations

APHIS Animal and Plant Health Inspection Service

AQI Agricultural Quarantine Inspection 

CBP Customs and Border Protection

DHS Department of Homeland Security

GPRA Government Performance and Results Act

PPQ Plant Protection and Quarantine

USDA U.S. Department of Agriculture

WADS Work Accomplishment Data System

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

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Page 1 GAO-12-885 Agriculture Inspections

United States Government Accountability Office 

Washington, DC 20548

September 27, 2012

Congressional Requesters

The United States is one of the world’s largest producers, consumers, 

exporters, and importers of agricultural commodities. However, some of 

these imported products may contain exotic pests and diseases. 

According to the Department of Homeland Security (DHS), invasive 

species cause an estimated $136 billion in lost agricultural revenue 

annually. For example, the Asian Longhorned Beetle has destroyed more 

than 30,000 trees in Illinois, New Jersey, and New York since it was 

discovered in 1996 in imported cargo, and it remains a significant problem 

today. Damages for this infestation have been estimated at more than 

$269 million, and according to the U.S. Department of Agriculture 

(USDA), if the infestation were to expand nationwide, it could cause more 

than $41 billion in losses. Furthermore, the terrorist attacks of September 

11, 2001, heightened concerns about agriculture’s vulnerability to 

terrorism, including the deliberate introduction of livestock, poultry, and 

crop diseases.1

Under the Agricultural Quarantine Inspection (AQI) program, international 

passengers and cargo at U.S. ports of entry are inspected to seize 

prohibited material and intercept foreign agricultural pests. Historically, 

USDA was responsible for the AQI program, but the Homeland Security 

Act of 2002 split responsibility for the AQI program between DHS and 

USDA’s Animal and Plant Health Inspection Service (APHIS). DHS 

acquired the authority to inspect passenger declarations and cargo 

manifests; international passengers; baggage; cargo; and conveyances 

such as ships, aircraft, vehicles, buses, and rail cars; and to seize and 

quarantine suspect articles. Under this authority, DHS’s Customs and 

Border Protection’s (CBP) agriculture specialists perform these duties at 

ports of entry located at airports, seaports, and land borders throughout 

the United States. Inspection methods include the examination of 

baggage by hand, X-ray, and canine inspection, and the examination of 

documents accompanying incoming cargo to ensure compliance with 

 

1

GAO, Homeland Security: Actions Needed to Improve Response to Potential Terrorist 

Attacks and Natural Disasters Affecting Food and Agriculture, GAO-11-652 (Washington, 

D.C.: Aug. 19, 2011).

 
 

Page 2 GAO-12-885 Agriculture Inspections

plant and animal health and trade agreements. An agriculture inspection 

may result in an interception—the identification of items that may be 

confiscated or transferred to an APHIS facility for subsequent evaluation 

or treatment, depending on the product or material. APHIS remains 

responsible for setting inspection policy, overseeing CBP agriculture 

specialists’ training, and managing and collecting AQI user fees––fees 

collected in connection with the arrival of international air passengers and 

conveyances at ports in the customs territory of the United States.

For more than a decade, we have reported on challenges related to the 

AQI program.2 In particular, in 2006, we issued two reports on 

management challenges in the AQI program, including one in May 2006, 

in which we identified shortcomings in the program’s staffing, 

performance measures, inter-agency coordination, and inspection 

performance.3 In our May 2006 report, we made seven recommendations 

to DHS and USDA to improve the AQI program by (1) improving 

information-sharing, (2) undertaking a full review of DHS’s financial 

management system for the AQI program, (3) removing barriers to timely 

and accurate AQI user fee transfers from USDA to DHS, (4) adopting 

meaningful performance measures, (5) establishing a national risk-based 

staffing model, (6) improving the agriculture canine program, and (7) 

revising user fees to cover AQI program costs. DHS and USDA generally 

agreed with these recommendations and in 2007 created a joint task 

force to, among other things, identify and implement solutions. In 

November 2006, we issued a report with additional analysis of survey 

data from our May 2006 report regarding agriculture specialists’ views on 

their work environment.4

Concerns persist that the agriculture sector remains vulnerable to the 

unintentional or deliberate introduction of pests and disease. In this 

context, you asked us to examine the AQI program. Our objectives for 

this report were to examine the extent to which (1) USDA and DHS have 

 

2

GAO, Agricultural Inspection: Improvements Needed to Minimize Threat of Foreign Pests 

and Diseases, GAO/RCED-97-102 (Washington, D.C.: May 5, 1997).

3

GAO, Homeland Security: Management and Coordination Problems Increase the 

Vulnerability of U.S. Agriculture to Foreign Pests and Disease, GAO-06-644 (Washington, 

D.C.: May 19, 2006).

4

GAO, Homeland Security: Agriculture Specialists’ Views of Their Work Experiences after 

Transfer to DHS, GAO-07-209R (Washington, D.C.: Nov. 14, 2006). 
 

Page 3 GAO-12-885 Agriculture Inspections

implemented recommendations we made in 2006 to improve the AQI 

program; (2) data on arrivals, inspections, and interceptions are used for 

managing the program; and (3) the views of agriculture specialists at CBP 

regarding their work environment have changed, if at all, since our 2006 

reports.

To address all of these objectives, we selected a nonprobability sample of 

five CBP ports of entry to visit in order to observe agriculture inspection 

work activities and discuss challenges related to conducting agriculture 

inspections and interceptions. These ports of entry included Austin, 

Texas; Baltimore, Maryland; Dallas, Texas; Miami, Florida; and San 

Ysidro, California. We selected these ports of entry based on size and 

entry pathways, such as air, sea, and land. Because we used a 

nonprobability sample, the information we obtained from these visits 

cannot be generalized to other CBP ports of entry. The visits instead 

provided us with more in-depth information on the perspectives of various 

agriculture specialists in these ports of entry about the management of 

the AQI program.

To examine the implementation of recommendations from our May 2006 

report, we interviewed DHS and USDA officials and reviewed 

documentation and criteria related to CBP’s performance measures, 

information-sharing between CBP and APHIS, DHS’s financial 

management system, CBP’s agriculture staffing model, CBP’s agriculture 

canine program, AQI’s user fee transfers, and AQI user fee modifications 

to cover AQI program costs. To examine the extent to which data on 

agriculture arrivals, inspections, and interceptions are used to manage 

the program, we reviewed DHS and USDA inspection and interception 

data, related summary reports, and policies, and interviewed key program 

officials at DHS and USDA headquarters, in the field, and at ports of 

entry. To address our objective on agriculture specialists’ views, we 

developed a questionnaire to survey CBP agriculture specialists, which 

contained closed-ended and open-ended questions. Specifically, we 

surveyed a stratified random probability sample of 556 agriculture 

specialists and supervisors from the universe of 2,311 agriculture 

specialists, including supervisors and agriculture canine handlers at CBP. 

To facilitate comparison with the findings from our May 2006 and 

November 2006 reports, we developed similar questions for this survey. 

We also used the results of our survey to inform our analysis on the 

extent to which DHS and USDA have implemented some of the 

recommendations we made in 2006. We received an unweighted 

response rate of 74 percent, and the results of our analysis of closedended survey questions are generalizable to all agriculture specialists and 
 

Page 4 GAO-12-885 Agriculture Inspections

supervisors at CBP. More details on our scope and methodology appear 

in appendix I. To view the full results of our survey, please see an 

electronic supplement to this report (GAO-12-884SP). 

We conducted this performance audit from August 2011 to September 

2012 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.

From 1913 until 2002, USDA was responsible for the inspection of plants 

and animals at U.S. ports of entry. Following the September 11, 2001, 

terrorist attacks, Congress passed the Homeland Security Act of 2002,5

In 2003, CBP established an initiative called “One Face at the Border,” 

which unified its three missions—customs, immigration, and agricultural 

inspection—by cross-training CBP customs and immigration officers and 

agriculture specialists in all three areas. The inspection procedures vary 

somewhat by the transportation pathway, such as airports, seaports, or 

land border crossings, but, generally, CBP officers conduct primary 

inspections, including interviewing passengers, and may refer passengers 

to agriculture specialists who conduct more detailed secondary 

which combined the inspection activities of the Department of the 

Treasury’s Customs Service, the Department of Justice’s Immigration and 

Naturalization Service, and USDA’s APHIS into the newly created DHS. 

The Secretaries of DHS and of USDA signed a memorandum of 

agreement in February 2003, agreeing to work cooperatively to 

implement the relevant provisions of the Homeland Security Act of 2002. 

Under the memorandum of agreement, APHIS’s responsibilities include 

managing user fees, overseeing agriculture specialists’ training, and 

providing pest identification services; and CBP’s responsibilities include 

conducting inspections and related activities. Consistent with the 

Homeland Security Act of 2002 and the agreement, in 2003 

approximately 1,500 agriculture specialists who had formerly worked for 

APHIS became CBP employees.

 

5

Pub. L. No. 107-296, 116 Stat. 2135.

Background
 

Page 5 GAO-12-885 Agriculture Inspections

inspections, including subsequent interviews of passengers or 

examination of baggage. Figure 1 shows an example of primary and 

secondary inspection procedures at an airport.
 

Page 6 GAO-12-885 Agriculture Inspections

Figure 1: Example of Primary and Secondary Inspection Procedures at an Airport

a

During the interview, the CBP officer offers the passenger the opportunity to amend documents and 

declare items. 

b

After seizing the material, the agriculture specialist either sends an unknown detected pest to the 

APHIS pest identifiers or sends the material to the incinerator to be destroyed. 
 

Page 7 GAO-12-885 Agriculture Inspections

As of April 2012, approximately 2,360 CBP agriculture specialists, 

including those who formerly worked with APHIS and those hired by CBP, 

were assigned to about half, or 167 of the 329 U.S. ports of entry. Each 

U.S. port of entry can include one or more pathway, such as airports, 

seaports, or land border crossings. For example, the port of Baltimore, 

Maryland, has an airport and seaport, whereas the port of Dallas, Texas, 

has just an airport. CBP port directors are responsible for overseeing 

operations at ports of entry and assigning agriculture specialists to 

specific port facilities. The ports of entry are organized into 20 district field 

offices across the United States, and these district offices are headed by 

CBP field office directors who also serve as liaisons between CBP 

headquarters and port management. In 2005, APHIS and CBP 

established a formal assessment process at select ports—known as joint 

quality assurance reviews—to ensure that ports of entry carry out 

agricultural inspections in accordance with APHIS’s regulations, policies, 

and procedures. APHIS and CBP spent about $33,000 conducting eight 

such reviews in 2011, and, according to CBP officials, the reviews focus 

on ports that are considered to be high risk for agriculture.

The Food, Agriculture, Conservation, and Trade Act of 1990, as 

amended, authorizes the Secretary of Agriculture to set and collect user 

fees for AQI services provided in connection with the arrival, at a port in 

the customs territory of the United States, of commercial vessels, 

commercial trucks, commercial railroad cars, commercial aircraft, and 

international passengers.6

 

6

Pub. L. No. 101-624 § 2509, 104 Stat. 3359 (codified as amended at 21 U.S.C. § 136a).

These fees are credited to USDA accounts that incur the costs associated with the AQI 

services. The fees remain available until expended, without fiscal year limitation.

The Secretary subsequently delegated this 

authority to APHIS. The fees are paid either directly by shipping 

companies or indirectly by air passengers through fees on tickets. CBP 

collects user fees for commercial vessels and trucks and deposits the 

collections into APHIS’s user fees account. APHIS collects all other user 

fees and periodically transfers a pre-agreed portion of the total collections 

to CBP to support CBP’s agriculture-related operations. APHIS has 

revised the AQI user fees several times since the act was passed. For 

example, through the rulemaking process, APHIS increased the user fees 

in November 1999 and, in January 2003, extended the adjusted fees 

indefinitely. In August 2006, APHIS published a final rule affirming a 

December 2004 interim rule that increased user fees again. We have 

previously reported on how the fees are set, collected, and distributed, 
 

Page 8 GAO-12-885 Agriculture Inspections

and the benefits and challenges of this process to agencies and 

stakeholders, including the implications of consolidating these fees under 

the authority of DHS.7

DHS and USDA took steps to implement all seven recommendations we 

made in our May 2006 report, but they faced challenges fully 

implementing four of them.

DHS and USDA have implemented our recommendations to (1) improve 

information-sharing, (2) undertake a full review of DHS’s financial 

management system for the AQI program, and (3) remove barriers to 

timely and accurate AQI user fee transfers from USDA to DHS.

Improve information-sharing. In our May 2006 report,8

 

7

GAO, Federal User Fees: Substantive Reviews Needed to Align Port-Related Fees with 

the Programs They Support,

we recommended 

that DHS and USDA ensure that they more effectively share urgent alerts 

and other information essential to safeguarding U.S. agriculture and that 

they transmit such information to agriculture specialists at the ports. At 

that time, we reported that agriculture specialists were not consistently 

receiving notifications of changes to inspection procedures or policies and 

urgent alerts from APHIS—notices of emerging concerns about foreign 

pests and diseases––in a timely manner. In response to our 

recommendation, in 2007, DHS established the position of Deputy 

Executive Director for Agriculture Operational Oversight to serve as a 

GAO-08-321 (Washington, D.C.: Feb. 22, 2008); and Federal 

User Fees: Key Aspects of International Air Passenger Inspection Fees Should Be 

Addressed Regardless of Whether Fees Are Consolidated, GAO-07-1131 (Washington, 

D.C.: Sept. 24, 2007).

8

GAO-06-644. 

DHS and USDA Have 

Taken Steps to 

Implement GAO’s 

Seven 

Recommendations, 

but Have Not Fully 

Implemented Four of 

Them

DHS and USDA Have 

Implemented Three 

Recommendations to 

Enhance the Effectiveness 

of the AQI Program
 

Page 9 GAO-12-885 Agriculture Inspections

primary point of contact for coordination among CBP, APHIS, and AQI 

stakeholders, such as state departments of agriculture, who would be 

largely responsible for eradicating foreign pests. In addition, CBP 

implemented a policy to disseminate urgent agriculture alerts to its field 

offices within 24 hours of receipt, and the alerts are then disseminated to 

agriculture specialists at the ports. These alerts, as well as any changes 

in inspection procedures or policies, are also available on the AQI 

program’s intranet site. Our survey results indicate that an estimated 83 

percent of the agriculture specialists and supervisors at CBP found that 

information regarding agriculture regulatory changes was delivered in a 

timely manner either always or most of the time.9 Our survey results also 

indicate that an estimated 4 percent of agriculture specialists and 

supervisors at CBP believe that the timeliness of information provided to 

agriculture specialists is a very major challenge, while an estimated 57 

percent believe it is only a minor challenge or not a challenge.10

Review DHS’s financial management system. In 2006, we recommended 

that DHS undertake a full review of its financial management systems, 

policies, and procedures for the AQI program to ensure financial 

accountability for funds allocated for agricultural quarantine inspections.11

 

9

The 95 percent confidence interval surrounding the estimate of 83 percent of agriculture 

specialists and supervisors at CBP believing information regarding agriculture regulatory 

changes was delivered in a timely manner either always or most of the time ranges from 

78.8 to 87.3.

At that time, CBP’s financial management system did not separately track 

time spent on agriculture activities from other types of activities. For 

example, a CBP officer conducting a primary inspection of an air 

passenger could ask questions related to immigration, customs, and 

agriculture activities, but only the time spent asking questions related to 

agriculture would generate AQI user fees and need to be reported to 

APHIS. However, CBP’s financial system did not track this time 

separately. As a result, CBP provided APHIS with estimates of the time 

10The 95 percent confidence interval surrounding the estimate of 4 percent of agriculture 

specialists and supervisors at CBP believing that the timeliness of information provided to 

agriculture specialists is a very major challenge ranges from 2.1 percent to 7.3 percent, 

and the 95 percent confidence interval surrounding the estimate of 57 percent of 

agriculture specialists and supervisors at CBP believing that it is a minor challenge or not 

a challenge ranges from 51.5 percent to 62.6 percent.

11GAO-06-644. 
 

Page 10 GAO-12-885 Agriculture Inspections

spent on agriculture activities and the associated costs. Since we last 

reported, CBP added agriculture-specific activity codes to its financial 

management system, which, according to CBP officials, allows CBP to 

provide APHIS with actual costs related to user fees. In addition, CBP 

issued guidance to clarify how employees should account for activities 

that are simultaneously related to immigration, customs, and agriculture 

activities so that this information could be tracked for the purpose of 

collecting AQI user fees. According to APHIS and CBP officials, the new 

activity codes and guidance allow CBP to accurately report its costs by 

user fee type to APHIS and ensure financial accountability for funds 

allocated to AQI user fees.

Accurately transfer user fees. In 2006, we recommended that USDA take 

steps to assess and remove barriers to the timely and accurate transfer of 

AQI user fees to DHS.12

 

12

At that time, transfers of user fees from USDA’s 

APHIS to DHS’s CBP were often delayed and their amounts were 

sometimes less than CBP expected, which adversely affected agricultural 

inspection activities. For example, in 2006, we reported that during fiscal 

years 2004 and 2005, CBP frequently did not receive the transfers at the 

time specified or for the agreed upon amount, causing some ports to 

reduce spending for supplies or to delay hiring or purchasing equipment. 

Since that time, APHIS and CBP have fully implemented a user fee 

transfer agreement that allows for a bimonthly transfer schedule that 

better accommodates the inflow of AQI user fee funds. This new user fee 

agreement also created chief budget liaisons at APHIS and CBP and 

provides for meetings at least 4 times a fiscal year to discuss AQI 

funding. Our analysis of transfer records provided by APHIS shows that, 

from fiscal year 2006 through 2011, 34 of the 36 scheduled user fee 

transfers were made in accordance with the new, bimonthly transfer 

schedule. During that time, six scheduled transfers were less than the 

scheduled amount, and, for each, APHIS made up the difference either 

by adding an unscheduled transfer or by adding the difference to the next 

scheduled transfer. APHIS and CBP officials told us that transfers have 

been more timely and accurate since the changes were implemented.

GAO-06-644. 
 

Page 11 GAO-12-885 Agriculture Inspections

DHS and USDA faced challenges in fully implementing our 

recommendations to (1) adopt meaningful performance measures, (2) 

establish a national risk-based staffing model, (3) improve the agriculture 

canine program, and (4) revise user fees to cover AQI program costs.

In 2006, we recommended that DHS and USDA adopt meaningful 

performance measures for assessing the AQI program’s effectiveness at 

intercepting foreign pests and disease on agricultural materials entering 

the country by all pathways and posing a risk to U.S. agriculture.13

Even as APHIS and CBP expanded existing performance measures, they 

did not develop measures for all aspects of the AQI program that are 

important for its management. Thus, existing performance measures are 

not sufficient to assess the program’s overall effectiveness. For example, 

APHIS officials told us that the AQI program does not have performance 

measures for gauging the timeliness of APHIS’s pest identification 

services, which form the basis for deciding how to treat inspected 

material. According to APHIS officials, they are working independently to 

develop such measures. In addition, CBP officials told us that there are 

no performance measures for gauging the extent to which the AQI 

At that 

time, CBP had not adopted performance measures that took into account 

the agency’s expanded mission or considered all pathways by which 

prohibited agriculture items or foreign pests may enter the country. In 

response to our recommendation, in 2007, APHIS and CBP created a 

joint task force that expanded existing performance measures to more 

pathways, including passengers’ baggage, pedestrians, and vehicles, as 

well as some cargo pathways. These performance measures provide 

information about the amount of prohibited agriculture items expected to 

be found in specific pathways during inspections, which can then be 

compared with data on the actual amount found. According to APHIS and 

CBP officials, this comparison can provide some information regarding 

the effectiveness of agricultural inspection activities as well as the relative 

risk that prohibited pests pose in a particular pathway. For example, in 

fiscal year 2011, APHIS estimated that 3.5 percent of international airline 

passengers were expected to be carrying prohibited agriculture items, 

and agricultural inspections actually found prohibited items in 3.2 percent 

of international airline passengers, suggesting that the agricultural 

inspections may not have found all items for that year.

 

13GAO-06-644. 

DHS and USDA Faced 

Challenges Implementing 

Four of Seven 

Recommendations

Adopt Meaningful Performance 

Measures 
 

Page 12 GAO-12-885 Agriculture Inspections

program targets inspections to commodities or pathways of higher risk. 

Furthermore, there are no performance measures for assessing progress 

related to the AQI program’s expanded mission to prevent agroterrorism, 

such as preventing the intentional introduction of pests harmful to 

agriculture by coordinating with intelligence entities. According to the 

Director of CBP’s Agriculture/Bio Terror Countermeasures division, there 

is an ongoing effort to develop a measure of CBP’s ability to prevent 

intentional introductions of harmful pathogens. CBP officials also told us 

that because the current performance measures are not designed to 

indicate what type of inspection procedure would most likely identify a 

prohibited item––for example, whether an item would be more likely to be 

found using an x-ray or a canine team—they are limited in their 

usefulness for effectively deploying their inspection resources. According 

to APHIS and CBP officials, the two agencies have not created additional 

performance measures for the AQI program because they have largely 

focused their performance management efforts on expanding their 

existing performance measures to additional pathways. In addition, they 

told us that developing additional performance measures has been a 

challenge because of the diverse missions of the two agencies. Our work 

on results-oriented organizations states that performance goals and 

measures that successfully address important and varied aspects of 

program performance are key elements of results-oriented 

organizations.14

The AQI program also does not have a strategic plan that could serve as 

the framework for defining the mission of what the program seeks to 

accomplish, setting goals to achieve the desired results, and identifying 

performance measures for gauging progress towards those goals. The 

Government Performance and Results Act of 1993, as amended,15

 

14GAO, Agency Performance Plans: Examples of Practices That Can Improve Usefulness 

to Decisionmakers,

(GPRA) requires, among other things, that federal agencies develop 

multi-year strategic plans, and we have previously reported that these 

requirements can also serve as leading practices for strategic planning at 

lower levels within federal agencies, such as planning for individual 

GAO/GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999).

15Pub. L., No. 103-62, 107 Stat. 285, amended by GPRA Modernization Act of 2010, Pub. 

L. No. 111-352, 142 Stat. 3866.
 

Page 13 GAO-12-885 Agriculture Inspections

divisions, programs, or initiatives.16

In 2006, we recommended that DHS and USDA establish a process to 

identify and assess the major risks posed by foreign pests and disease 

and develop and implement a national staffing model to ensure that 

agriculture staffing levels at each port are sufficient to meet those risks.

The memorandum of agreement that 

established APHIS and CBP roles in the AQI program also emphasized 

the need for coordination between the two agencies. In 2007, a task force 

comprising of APHIS and CBP employees identified the need to create a 

joint agency AQI strategic plan, but an official with the task force told us 

that this effort was not successful because the two agencies took 

fundamentally different approaches to strategic planning that could not be 

resolved. Instead, according to APHIS and CBP officials, the two 

agencies have incorporated elements of AQI activities into each agency’s 

separate strategic planning efforts. For example, the strategic plan for 

APHIS’s Plant Protection and Quarantine program has a program goal of 

optimizing the effectiveness of pest exclusion and prevention activities. At 

the same time, CBP’s Office of Field Operations has a separate draft 

strategic plan that contains an objective for protecting against the 

introduction of plant pests and foreign animal diseases. Each plan has 

different performance measures. These separate strategic plans do not 

reflect a coherent joint mission with program goals that can serve as the 

foundation for developing performance measures for the AQI program as 

a whole. Without a joint strategic plan defining the mission and goals of 

the AQI program, APHIS and CBP do not have a unified framework for 

developing meaningful performance measures.

17

 

16For example, see GAO, Environmental Justice: EPA Needs to Take Additional Actions 

to Help Ensure Effective Implementation, 

At that time, we found that CBP had not developed or used a risk-based

staffing model to ensure that adequate numbers of agriculture specialists 

were staffed to the areas of greatest vulnerability for introducing pests 

and disease. In response to our recommendation, CBP has made 

multiple attempts to build a staffing model since 2006, but agency officials 

told us the agency has not yet developed a risk-based staffing model that 

takes into account specialized, port-specific needs. CBP officials said that 

after several attempts to create their own staffing model, they concluded 

they did not have the needed expertise or reliable data to do so. CBP 

officials told us that, in 2009, they hired a contractor for $300,000 to 

GAO-12-77 (Washington, D.C.: Oct. 6, 2011).

17GAO-06-644. 

Establish a National Risk-Based 

Staffing Model
 

Page 14 GAO-12-885 Agriculture Inspections

develop a model, and the agency received the model in September 2010. 

However, CBP determined that the model was inadequate because it did 

not incorporate specialized staffing needs, such as ports where unique 

commodities (e.g., cut flowers) are inspected. CBP is in the process of 

soliciting for a new contract to revise the staffing model to account for 

these specialized staffing needs, and they estimate that this new contract 

will cost an additional $300,000. CBP officials told us their goal is for the 

revised staffing model to be completed and approved by September 

2014, but as of June 2012, officials said that the effort to finalize the 

contract solicitation is 4 months behind schedule. In addition, CBP 

officials were unable to provide contracting documents to substantiate 

their timeline. CBP officials told us they are having difficulty writing the 

new contract solicitation because DHS’s information requirements for 

contracting documents have changed since they wrote the previous 

contract, and they were unaware of the new requirements when they 

submitted their draft documents. In addition, a CBP official involved in the 

contracting process told us that the AQI program generally does not use 

contractors; therefore, the program’s experience in managing the 

contracting process is limited.

CBP officials told us they anticipate that the revised staffing model will 

recommend significant increases in staff at many locations because the 

staffing model they received in September 2010 recommended a 32-

percent increase in the total number of agriculture specialists for the AQI 

program. CBP officials also told us they currently do not have the 

resources to increase staff above replacement levels. However, the 

agency has not developed a plan or strategy that assesses the risk of 

potential fiscal constraints on their ability to implement the staffing model. 

Under standards for internal control in the federal government, agencies 

are to assess the risks they face from external and internal sources and 

to determine what actions should be taken to mitigate them.18 Because 

the AQI program may not have the fiscal resources to add the number of 

agriculture specialists that the model recommends, CBP faces the risk of 

being unable to keep up with the demand for agricultural inspections. In 

2006, we reported that the changing nature of international travel and 

agricultural imports creates risks for introducing pests and disease.19

 

18GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1999).

19GAO-06-644. 
 

Page 15 GAO-12-885 Agriculture Inspections

These risks include the volume of passengers and cargo, the type of 

agricultural products, countries of origin, and ports of entry where 

passengers and cargo arrive in the United States. Without a plan or 

strategy to optimize the allocation of staff to those ports of highest need 

that considers the fiscal resources that may realistically be available, CBP 

risks investing in a staffing model it cannot execute and increasing the 

vulnerability of the agriculture sector to foreign pests and disease. 

International trade could also be affected if agriculture specialists are not 

available to inspect cargo in a timely manner.

In 2006, we recommended that DHS and USDA work together to improve 

the effectiveness of the agriculture canine program by reviewing policies 

and procedures regarding training and staffing of agriculture canines and 

ensure that these policies and procedures are followed in the ports.20

• Increased staffing levels. According to CBP officials, there are 

currently 114 active agriculture canine teams compared with the 

approximately 80 teams that were in place in 2006. We could not 

determine if the staffing levels were adequate without a final staffing 

model for the AQI program. According to CBP officials, the staffing 

model being developed by CBP includes staffing recommendations 

for agriculture canine teams. However, as discussed above, CBP 

officials told us that they do not have a plan to implement the staffing 

model results for deploying canine teams effectively at the ports 

because of current resource constraints.

 At 

that time, the agriculture canine program was understaffed and 

proficiency scores of canine teams had declined. Agriculture canines are 

a key tool for targeting passengers and cargo for inspection by detecting 

the scent of specific prohibited agricultural items, such as citrus or beef. 

CBP officials told us that the use of canines can increase the number of 

agriculture interceptions. For example, at one port of entry that we visited, 

after a canine handler was assigned to work a pathway where no canine 

team had previously worked, interceptions increased by 800 percent. In 

response to our recommendation, CBP has

• Increased canine training requirements. In 2006, we reported that 60 

percent of the 43 agriculture canine teams tested failed the 2005 

proficiency test—an annual performance evaluation all canine 

 

20GAO-06-644. 

Improve the Effectiveness of 

the Agriculture Canine Program 
 

Page 16 GAO-12-885 Agriculture Inspections

enforcement teams must undergo to maintain certification of their 

detection capability. We recommended that USDA and DHS review 

canine training policies. In response, in 2007, trainers from USDA’s 

National Detector Dog Training Center—the training center for 

agriculture canine teams— evaluated the annual agriculture canine 

certification program at selected ports. As a result of these 

evaluations, officials from CBP and the training center decided to 

extend the agriculture canine field training course by 1 week to add, 

among other things, hands-on training for conducting certifications at 

the ports. According to the national agriculture canine program 

manager, all current canine teams have passed the annual proficiency 

test.

• Expanded management oversight. CBP hired a national agriculture 

canine program manager with canine and agriculture experience to

help ensure that staffing and training policies are followed in the ports. 

This program manager is responsible for canine handler recruitment 

activities; monitoring the training and staffing status of canine 

handlers; and coordinating the flow of information among canine 

handlers, field offices, and training centers. For example, the 

agriculture canine program manager noted that one of her primary 

responsibilities is to coordinate with the National Detector Dog 

Training Center to assist agriculture canine teams with training 

procedures and policies.

Even with these efforts, the agriculture canine program still faces 

challenges related to supervisory training and data reliability. First, 

supervisors may not have canine training or experience. Based on the 

results of our survey of agriculture specialists, we estimate that 35 

percent of agriculture canine specialists at CBP believe that their 

supervisor did not have adequate agriculture canine expertise to advise 

them on any work-related concerns in the past year.21

 

21The 95 percent confidence interval surrounding the estimate that 35 percent of 

agriculture canine specialists at CBP believe that their supervisor did not have adequate 

agriculture canine expertise to advise them on any work-related concerns in the past year 

ranges from 26.6 percent to 43.4 percent.

Our analysis of 

findings from the joint CBP-APHIS quality assurance reviews in 2010 and 

2011 shows that canine handlers at 4 of the 15 ports with canine handlers 

that were reviewed reported to a supervisor who had not taken the formal 

canine supervisory training course. According to USDA’s National 

Detector Dog Manual, the supervisory training class covers topics related 
 

Page 17 GAO-12-885 Agriculture Inspections

to using canine teams, proficiency training, veterinary requirements, and 

work expectations. The agriculture canine program manager told us that 

this formal training class is available, but not mandatory, for canine 

supervisors. Port directors at individual ports of entry are responsible for 

determining whether a canine supervisor should take the class and 

whether the port has the resources to support sending the supervisor to 

the class. Not having supervisors with experience in agriculture canines 

can, according to the canine handlers we spoke with at ports of entry, 

make it difficult for the canine handlers to get support when they 

encounter difficulty or have questions. Also, in March 2004, we reported 

that investing in and enhancing the value of employees through training 

and development is crucial for the federal government to successfully 

acquire, develop, and retain talent.22

Second, we found that some data being used to support the agriculture 

canine program may not be sufficiently reliable for assessment because 

they are incomplete and inaccurate. In addition, some data being 

collected may not be meaningful. The agriculture canine program relies 

on multiple types of data to track the work activities of canine handlers, 

such as whether the handler is active or on leave and what training 

activities the team has completed. However, we found the following:

• Some data are incomplete and inaccurate. For example, we analyzed 

data from fiscal years 2010 and 2011 on canine teams’ weekly 

training exercises. The program manager uses this information to 

ensure that canine teams are meeting their training requirement and 

maintaining a minimum required proficiency level to conduct 

agricultural inspections. However, we estimate that the percent of 

missing values in this data set ranges from 13 percent to 22 percent 

from January 2010 through July 2011. We could not accurately 

determine the precise number of missing values because, according 

to the canine program manager, the field offices do not maintain 

accurate records of the number of active canine teams. The canine 

program manager told us that canine teams periodically become 

inactive for a variety of reasons, such as medical leave or temporary 

reassignment of canine handlers, but the field offices do not change 

the team’s status to inactive in the human capital tracking system, and 

as a result, the number of active canine handling teams in each 

 

22GAO, Human Capital: A Guide for Assessing Strategic Training and Development 

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

Page 18 GAO-12-885 Agriculture Inspections

quarter may be overstated. The canine program manager also noted 

that the proficiency data—which are collected quarterly by CBP field 

offices and forwarded to the agriculture canine program manager in 

CBP headquarters—have missing values because field offices do not 

consistently review the data for errors or missing values. When there 

are missing values, too much time may have elapsed for the canine 

handler to remember what the correct data should be. According to 

the agriculture canine program manager, to compensate for these 

data problems, she maintains a separate record of the current status 

of each canine team, which is generated from personal 

communications between her, the field offices, and canine handlers. 

The agriculture canine program manager also told us she is 

developing a web-based data reporting system that is intended to 

have a supervisory review process before the data are submitted; 

however, she did not have a timeline for this project because it is 

being developed informally. Without complete and accurate 

information regarding its canine teams, the AQI program does not 

have sufficient information to assess the status of the canine teams’ 

proficiency level to ensure agriculture canine inspections are being 

conducted by qualified canine teams.

• Some data being collected may not be meaningful. Specifically, the 

agriculture canine program is gathering data on the amount of time 

canine teams actively inspect and intercept pests; however, according 

to CBP officials, these data are not useful for the AQI program. Before 

the creation of DHS, the U.S. Customs Service collected these data to 

measure the cost effectiveness of its drug-detecting canines, and 

CBP continued to collect these data for agriculture canines. The use 

of these data to determine the cost effectiveness of a canine program 

depends heavily on determining the value of the seized contraband, 

which is not easily determined for agriculture. For example, according 

to CBP officials, a pound of seized cocaine has an associated street 

value that can be compared with the cost of performing inspections. 

For agriculture products, the monetary value of the seized item may 

be minimal; instead, the value of the activity is in preventing the 

introduction of a harmful agricultural pest or disease and avoiding the 

potential economic harm, which, according to CBP, is difficult to 

project or calculate.

Without sufficiently reliable data, the AQI program cannot assess the 

effectiveness of the canine program. Furthermore, by collecting data that 

are not meaningful or useful for assessing the effectiveness of its canine 

handlers, the AQI program may be using resources to collect data it does 

not need.
 

Page 19 GAO-12-885 Agriculture Inspections

In 2006 we recommended that DHS and USDA work together to revise 

the user fees to ensure that they cover the AQI program’s costs.23 At that 

time we found that, although the Secretary of Agriculture had the 

discretion to prescribe user fees to cover the costs of the AQI program, 

program costs had exceeded user fee collections since the transfer of 

AQI inspection activities to DHS’s CBP. In 2009, APHIS attempted to 

increase the AQI user fees using an interim rulemaking process that 

increased AQI user fees by approximately 10 percent. However, later that 

year they withdrew the interim rule because, according to APHIS officials, 

stakeholders objected to the lack of a formal comment period in the 

interim rulemaking process. We have previously reported that APHIS’s 

use of interim rules to adjust user fees limits stakeholder input.24 APHIS 

officials are exploring other regulatory alternatives for adjusting the fees. 

In October 2010, APHIS hired a contractor to conduct a comprehensive 

fee review to determine the full cost of AQI services, identify potential 

changes to the fee structure, and recommend new fees. APHIS officials 

estimated that, should APHIS and DHS agree that user fees need to be 

increased, APHIS will publish a proposed rule by the summer of 2013. 

GAO is conducting a separate evaluation of the AQI user fees’ structure 

and options for setting and distributing them.

The AQI program uses data on arrivals, inspections, and interceptions to 

determine how well agricultural inspections identify prohibited materials 

and to review ports’ performance, but data quality issues may prevent 

AQI program officials from making full use of the data. More specifically, 

CBP and APHIS officials told us that they determine how well agricultural

inspections identify prohibited materials by comparing the actual counts of 

arrivals, inspections, and interceptions against the existing performance 

measure of the amount of prohibited agricultural items expected to be 

found in a specific pathway. In addition, AQI officials use the data to 

identify annual trends specific to a particular port and to determine 

whether any changes in the number of inspections or interceptions at that 

port can be explained by external factors––such as a change in trade or 

travel patterns––or indicate a performance problem at the port that needs 

to be corrected. However, we found limitations that may undermine the 

data’s overall usefulness for managing the program. Specifically:

 

23GAO-06-644. 

24GAO-07-1131.

Revise User Fees

Limitations in the 

Arrival, Inspection, 

and Interception Data 

May Hinder Their Use 

in Managing the 

Program 
 

Page 20 GAO-12-885 Agriculture Inspections

• The data may not be reliable. According to APHIS officials, data 

quality is an ongoing issue with the AQI data systems, including the 

Work Accomplishment Data System (WADS)—the primary repository 

for arrival, inspection, and interception data. As a result, in 2004, 

APHIS and CBP created an interagency stakeholder group with a goal 

of ensuring data quality and accuracy by performing quarterly visual 

checks of WADS data and providing data quality training to agriculture 

specialists at the ports upon request. Since 2006, 30 of the 167 ports 

with agriculture specialists have received this training. At some ports, 

agriculture specialists record arrivals, inspections, and interceptions 

every day on paper or spreadsheets and enter this information into 

WADS at the end of the month, which may affect the reliability of the 

data by introducing transcription errors. In addition, from 2010 through 

2011, the joint CBP-APHIS quality assurance reviews, which focused 

on 22 ports, found instances of discrepancies between data recorded 

in WADS and data recorded on daily logs at about half of the ports 

reviewed (10 out of the 22 ports). For example, at one port that was 

reviewed, the number of passengers referred to secondary inspection 

was underreported by nearly 10 percent, and reviews of other ports 

identified some data that were overreported or had not been recorded. 

APHIS and CBP officials told us that supervisors review the data 

monthly at all the ports, and that there is a quarterly review process by 

the interagency stakeholder group; however both of these reviews rely 

primarily on a visual comparison of current and historical numbers and 

thus detect only unusually large changes at a port. According to 

APHIS officials, the monthly supervisory review process does not 

require supervisors to compare the numbers in WADS with the daily 

log sheets or other databases because the policy and procedures do 

not have specific requirements on how data are to be reviewed. We 

have previously reported that agencies should ensure that data are 

free of systematic error or bias and that what is intended to be 

measured is actually measured.25 According to a senior APHIS 

official, ensuring AQI data quality and accuracy is a continuing 

challenge because of various factors, including changes in the APHIS 

and CBP personnel involved in data collection.

 

25GAO, Agencies’ Annual Performance Plans under the Results Act: An Assessment 

Guide to Facilitate Congressional Decisionmaking, GAO/GGD/AIMD-10.1.18

(Washington, D.C.: February 1998).
 

Page 21 GAO-12-885 Agriculture Inspections

• The data cannot be easily analyzed. WADS captures data on the 

number of arrivals, inspections, and interceptions independently from 

one another, and these data cannot be linked without extensive 

analysis. CBP officials told us that being able to connect a specific 

arrival to an inspection and the resulting interceptions would be useful 

information for assessing the effectiveness of targeting activities and 

inspection procedures. However, the analysis necessary to do so is 

time consuming and cumbersome, undermining the use of the data for 

managing the program. In addition, the way in which some data are 

recorded in WADS complicates analysis, according to APHIS and 

CBP officials. For example, WADS captures the number of agricultural

inspections carried out at individual ports by agriculture specialists. It 

does not count the number of agricultural inspections carried out by 

CBP officers when agriculture specialists are not present. Therefore, 

WADS is not a representation of the total number of agricultural

inspections carried out at ports and cannot be used to analyze the 

number of agricultural inspections conducted in relation to total 

number of arrivals. In another example, each inspection is counted 

once in WADS, but the number of interceptions that are recorded from 

an inspection varies depending on what is found. Specifically, if a 

passenger were inspected and found to be carrying five different 

types of fruit, the agriculture specialist would record that result as five 

interceptions for one inspection. However, if the passenger had five 

pieces of one type of fruit, it would be recorded as one interception. 

As a result, it is difficult to analyze the number of agricultural

interceptions found in relation to the total number of inspections 

conducted.

• The data have inherent limitations beyond AQI program control. The 

number of agricultural arrivals, inspections, and interceptions varies 

from year to year and by pathway. According to APHIS and CBP 

officials, the variation is caused by numerous factors, including 

weather, economics, and politics that affect travel and trade, as well 

as variances in inspection targeting procedures. For example, arrivals 

of a commodity from a particular country may drop sharply because of 

severe weather conditions, such as hurricanes or droughts, or 

because trade sanctions and embargoes have been put in place for 

political reasons. APHIS and CBP officials noted that they target 

inspections on the basis of factors such as pathways, commodities 

known to be a risk for agricultural pests, country of origin, and a 

shipper’s history of violations. Together, these factors can result in 

inspection and interception numbers that do not correlate with the 

number of arrivals for a particular pathway. For example, APHIS 

officials told us that one pathway, such as cargo trucks, may have a 
 

Page 22 GAO-12-885 Agriculture Inspections

high number of arrivals, but if the cargo these trucks are carrying is 

considered a low risk for carrying prohibited pests, then it would be 

expected that the data for this pathway would show fewer inspections 

and interceptions.

Some of these data limitations have the potential to affect other key 

efforts that are currently underway, such as the program’s staffing model 

and the effort to analyze the structure and amounts of AQI user fees––

both critical to the AQI program. For example, contractor documents 

related to the staffing model stated that WADS data are not reliable for 

understanding the actual workload of agriculture specialists, and that the 

contractor had to undertake significant effort to make the data usable. 

Specifically, the contractor’s analysis estimated that about 2 percent of 

pedestrians are inspected by agriculture specialists, but that the data in 

WADS indicated that agriculture specialists inspected 33 percent of 

pedestrians.26 In addition, the contractor analyzing user fees noted 

concerns regarding potentially inconsistent or inaccurate data entry, 

which could result in decreased confidence with data reporting and 

analysis. Without reliable data on work activities, AQI program officials 

cannot be assured that they have the information they need to manage 

the program.

According to our analysis of agriculture specialists’ and supervisors’ 

responses to our 2012 survey and the results from our 2006 survey, 

some aspects of agriculture specialists’ and supervisors’ views about their 

work environment have changed since 2006. The responses to our openand closed-ended questions show that views about some areas have 

improved, some concerns expressed in 2006 have persisted, and some 

concerns have increased. (To view the full results of our survey, please 

see the electronic supplement to this report, GAO-12-884SP.)

According to our analysis of the responses to the 2006 and 2012 surveys, 

agriculture specialists and supervisors believe some aspects of the AQI 

program have improved since we last reported. Notably, in 2006, “nothing 

is going well” was the second most common response to our open-ended 

question, “What is going well with respect to your work as an agriculture 

specialist?”; in 2012, it was one of the least common responses, 

 

26For the purposes of this report, we did not assess the reliability of the numbers 

presented in the contractor’s analysis. 

Survey Responses 

Show Some Changes 

in Agriculture 

Specialists’ Views

Survey Responses Show 

Improvement in Some 

Areas
 

Page 23 GAO-12-885 Agriculture Inspections

suggesting that, in general, respondents believe aspects of the AQI 

program have improved. (See appendix II for a summary of responses to 

this open-ended question for 2006 compared to 2012.) Based on our 

analysis of survey results, agriculture specialists and supervisors 

specifically believe that training and information-sharing have improved.

Training. More agriculture specialists and supervisors at CBP now believe 

they are sufficiently trained to perform their agriculture inspection duties 

than did in 2006, according to our analysis of responses to the closedended questions in our 2012 survey. Specifically, we estimate that 76 

percent of agriculture specialists and supervisors at CBP employed 

before the merger believe they are definitely sufficiently trained to perform 

their agricultural inspection duties, and 51 percent employed after the 

merger believe they are definitely sufficiently trained.27 This represents an 

increase from 2006, when we estimated 58 and 36 percent, 

respectively.28

Table 1: Estimates for the Closed-ended Question “Do You Believe That You Are 

Sufficiently Trained to Perform Your Agriculture Inspection Duties?” (in percent)

(See table 1.)

Employed before the 

merger

Employed after the 

merger

2006 2012 2006 2012

Definitely yes 58 76 36 51

Confidence intervalsa 52.4-62.6 66.6-83.0 28.2-44.3 44.6-58.3

Probably yes 32 19 39 36

Confidence intervals 27.4-37.2 12.3-27.5 31.2-46.6 29.7-42.8

Uncertain 1 4 11 2 

Confidence intervals 0.5-2.8 1.3-10.2 7.4-15.5 0.5-4.5

Probably not 4 1 8 5 

Confidence intervals 2.7-7.0 0.0-3.6 4.7-13.3 2.4-9.2

 

27The 95 percent confidence intervals surrounding the estimates of 76 percent and 51 

percent of agriculture specialists and supervisors at CBP range from 66.6 percent to 83.0 

percent for those hired before the merger and from 44.6 percent to 58.3 percent for those 

hired after the merger.

28The 95 percent confidence intervals surrounding the estimates of 58 percent and 36 

percent of agriculture specialists and supervisors at CBP range from 52.4 percent to 62.6 

percent for those hired before the merger and from 28.2 percent to 44.3 percent for those 

hired after the merger.
 

Page 24 GAO-12-885 Agriculture Inspections

Employed before the 

merger

Employed after the 

merger

2006 2012 2006 2012

Definitely not 3 0 5 5 

Confidence intervals 1.7-6.0 0.0-3.6 2.7-9.0 2.6-9.5

No answer 1 0 2 0 

Confidence intervals 0.6-3.9 0.0-1.9 0.4-7.8 0.0-2.1

Source: GAO analysis of survey data.

Notes: Numbers may not add to 100 percent due to rounding. 

In 2006, the question was phrased as: “Do you believe you received sufficient training (on-the-job and 

at the Professional Development Center) to enable you to perform your agriculture inspection duties?” 

a

The shaded rows contain the 95 percent confidence intervals. 

Additionally, based on our analysis of the responses to our closed-ended 

questions, we estimate 28 percent of agriculture specialists and 

supervisors at CBP believe that the sufficiency of training is not a 

challenge to conducting agriculture duties at their port, and another 29 

percent believe it is only a minor challenge.29

Information-sharing. According to our analysis of 2006 and 2012 survey 

responses, information-sharing has also improved. Based on the 

responses to our closed-ended question on whether information is 

We did not ask about 

whether or not training was a challenge in our closed-ended questions in 

2006, but at that time, training was the fourth most frequent response to 

our open-ended question, “What would you like to see changed or 

improved with respect to your work as an agriculture specialist?” Our 

analysis of the responses to our 2012 survey shows that views about 

training have generally improved, but out of 406 respondents, we 

received 68 comments in response to an open-ended question listing 

certain aspects of training they would like to see changed or improved.

For example, some respondents commented that they would like to see 

more specific or refresher training on agriculture pests that they may 

encounter on the job, and one respondent commented that he would like 

the opportunity for more hands-on—rather than web-based—training.

 

29The 95 percent confidence interval surrounding the estimate for the 28 percent of 

agriculture specialists and supervisors at CBP believing that the sufficiency of training is 

not a challenge to conducting agriculture duties at their port ranges from 23.2 percent to 

33.1 percent, and the 95 percent confidence interval surrounding the estimate for the 29 

percent ranges from 23.9 percent to 34.1 percent.
 

Page 25 GAO-12-885 Agriculture Inspections

delivered in a timely manner, we estimate that 36 percent of agriculture 

specialists and supervisors at CBP believe that information on agriculture 

regulatory changes is always delivered in a timely manner, and another 

48 percent believe the information is delivered in a timely manner most of 

the time.30 These views reflect an increase from 2006, when we 

estimated 17 percent of agriculture specialists and supervisors at CBP 

believed such information was always delivered in a timely manner, and 

38 percent believed it was delivered in a timely manner most of the 

time.31 Additionally, we estimate that, compared with 2006, statistically 

more agriculture specialists and supervisors at CBP in 2012 believe they 

always receive information on urgent alerts, pest alerts, and updated 

pages for the agriculture regulatory manual in a timely manner.32 (See 

table 2.) We estimate that 57 percent of agriculture specialists and 

supervisors at CBP in 2012 believe the timeliness of information provided 

to agriculture specialists is either not a challenge or is a minor challenge 

to conducting agriculture duties at their port.33 We did not ask this 

question in 2006.

 

30The 95 percent confidence interval surrounding the estimate of 36 percent of agriculture 

specialists and supervisors at CBP believing that that information on agriculture regulatory 

changes is always delivered in a timely manner ranges from 30.2 percent to 40.8 percent, 

and the 95 percent confidence interval surrounding the estimate of 48 percent ranges from 

42.3 percent to 53.4 percent.

31The 95 percent confidence interval surrounding the estimate from 2006 of 17 percent of 

agriculture specialists and supervisors at CBP believing such information was always 

delivered in a timely manner ranged from 14.3 percent to 21.0 percent, and the 95 percent 

confidence interval surrounding the estimate of 38 percent ranged from 33.4 percent to 

41.9 percent. The way the questions were asked varied slightly from 2006 to 2012.

32The 95 percent confidence interval surrounding the estimate in 2006 of 21 percent of 

agriculture specialists and supervisors at CBP believing they always receive information 

on urgent alerts, pest alerts, and updated pages for agriculture regulatory manual in a 

timely manner ranged from 17.8 percent to 24.9 percent. In 2012, the 95 percent 

confidence interval surrounding the 34 percent estimate ranges from 28.9 percent to 39.4

percent. The 95 percent confidence interval surrounding the estimate in 2006 of 19 

percent ranged from 16.0 percent to 22.9 percent. In 2012, the 95 percent confidence 

interval surrounding the 33 percent estimate ranges from 28.1 percent to 38.6 percent. 

The 95 percent confidence interval surrounding the estimate in 2006 of 18 percent ranged 

from 14.8 percent to 21.7 percent. In 2012, the 95 percent confidence interval surrounding 

the 37 percent estimate ranges from 31.4 percent to 42.1 percent. 

33The 95 percent confidence interval surrounding the estimate of 57 percent ranges from 

51.5 percent to 62.6 percent.
 

Page 26 GAO-12-885 Agriculture Inspections

Table 2: Estimates for the Closed-ended Question “Is the Information Delivered to You in a Timely Manner to be Useful?” (in 

percent)

Response

Always Most of the time

Some of the 

time

Never or 

almost never

Did not 

receive No answer

Type of information 2006a 2012b 2006 2012 2006 2012 2006 2012 2006 2012 2006 2012

Urgent agriculture 

alerts

21 34 41 47 25 15 7 2 3 1 2 1 

Confidence intervalsc 17.8-

24.9

28.8-

39.4

37.3-

45.8

41.4-

52.5

21.4-

28.8

11.2-

19.5

5.5-

10.1

0.8-

4.1

1.8-

4.3

0.5-

3.0

1.1- 

4.5

0.1-

2.1

Pest alerts 19 33 42 47 25 16 8 2 4 2 2 1 

Confidence intervals 16.0-

22.9

28.0-

38.6

37.4-

46.0

41.1-

52.3

22.0-

29.3

11.7-

20.1

6.0-

10.9

0.7-

3.5

2.5-

5.3

0.7-

3.7

1.0- 

4.0

0.2-

2.9

Regulatory changes 17 36 38 48 26 15 12 1 5 0 2 0 

Confidence intervals 14.3-

21.0

30.2-

40.8

33.4-

41.9

42.3-

53.4

22.2-

29.7

11.2-

19.4

9.75-

15.4

0.4-

3.1

3.3-

6.2

0.0-

1.6

1.3- 

4.2

0.0-

1.4

Updated pages for 

agriculture regulatory 

manual

18 37 31 46 17 10 18 3 14 4 2 1 

Confidence intervals 14.8-

21.7

31.5-

42.2

26.6-

34.8

40.3-

51.4

13.7-

20.2

7.0-

13.9

14.9-

21.5

1.3-

5.1

11.7-

17.3

1.8-

5.6

1.5- 

4.2

0.3-

3.2

Source: GAO analysis of survey data.

Notes: Numbers may not add to 100 percent due to rounding. 

In 2006, the question was phrased as: “Is the information delivered to you in a timely manner?” 

a

In 2006, there were 626 responses. 

b

In 2012, there were 397 responses for urgent agriculture alerts, 394 for pest alerts, and 396 

responses each for regulatory changes and updated pages for agriculture manual. 

c

The shaded rows contain the 95 percent confidence intervals. 

According to our analysis of the responses to our 2012 survey, some of 

the concerns agriculture specialists and supervisors at CBP reported in 

2006 persist. In particular, concerns remain about CBP’s chain of 

command, the agriculture mission, and working relationships among coworkers. 

CBP’s chain of command. Our analysis indicates that respondents remain 

concerned about CBP’s chain of command—including concerns about 

poor communication related to internal policies, supervisors lacking 

agriculture experience, and the need for an agriculture chain of command 

that is separate from CBP. In 2006, CBP’s chain of command was the 

third most frequent response to our open-ended question, “What would 

you like to see changed or improved with respect to your work as an 

agriculture specialist?” Similarly, in 2012, it was the category noted most 

Survey Responses Show 

Some Concerns Persist
 

Page 27 GAO-12-885 Agriculture Inspections

often as something to be changed or improved. Furthermore, based on 

our analysis of closed-ended questions in 2012, we estimate that 30 

percent of agriculture specialists and supervisors at CBP believe the CBP 

chain of command is a very major challenge to conducting agriculture 

duties at their port, and another 23 percent believe it is a major 

challenge.34

Agriculture mission. As with the results of our 2006 survey, 2012 survey 

respondents identified the priority given to the agriculture mission among 

the top four aspects of the AQI program they would like to see changed or 

improved. Further, we estimate that 39 percent of agriculture specialists 

and supervisors at CBP believe the priority given to the agriculture 

mission is a very major challenge to conducting agriculture duties at their 

port, and another 23 percent believe it is a major challenge based on our 

analysis of responses to closed-ended questions in 2012.

(See appendix II for a summary of responses to the openended question, “What would you like to see changed or improved with 

respect to your work as an agriculture specialist?” in 2006 compared to 

2012.) We did not ask about CBP’s chain of command in our closedended questions in 2006.

35

 

34The 95 percent confidence interval surrounding the estimate of 30 percent of agriculture 

specialists and supervisors at CBP remaining concerned about CBP’s chain of command 

ranges from 24.4 percent to 34.7 percent, and the 95 percent confidence interval 

surrounding the estimate of 23 percent ranges from 17.9 percent to 27.4 percent.

Out of 406 

survey respondents, 86 respondents identified the priority given to the 

agriculture mission as something they would like to see changed or 

improved in response to our open-ended question. Respondents noted 

that competing priorities sometimes prevented them from performing their 

missions and that agriculture specialists do not have enough time to 

complete their tasks, such as looking for pests in agriculture materials 

intercepted from passengers. Not having enough time to complete 

agriculture-mission related tasks is a concern for about the same 

percentage of agriculture specialists and supervisors at CBP in 2012 as it 

was in 2006. (See table 3.)

35The 95 percent confidence interval surrounding the estimate of 39 percent of agriculture 

specialists and supervisors at CBP identifying the priority given to the agriculture mission 

is a very major challenge ranges from 34.0 percent to 44.9 percent, and the 95 percent 

confidence interval surrounding the estimate of 23 percent ranges from 18.5 percent to 

28.0 percent.
 

Page 28 GAO-12-885 Agriculture Inspections

Concern for the priority given to the agriculture mission persists, but 91 

out of 406 respondents indicated in their response to the open-ended 

question about what is going well that they believe some aspects of the 

AQI mission are going well, such as inspections and interceptions.

Table 3: Estimates for the Closed-ended Question “Do You Have Enough Time to 

Look for Pests in Agriculture Materials Intercepted from Passengers?” (in percent)

2006a 2012 b

Always 10 11

Confidence intervalsc 8.1-13.0 8.2-15.2

Most of the time 27 31

Confidence intervals 23.0-30.9 25.9-36.1

Some of the time 31 30

Confidence Intervals 27.2-35.4 25.1-35.4

Never or almost never 15 8 

Confidence Intervals 12.5-18.5 4.9-10.9

Not applicable 15 18

Confidence Intervals 11.9-17.8 13.4-22.4

No answer 2 2 

Confidence Intervals 1.1-3.6 0.9-4.8

Source: GAO analysis.

Notes: Numbers may not add to 100 percent due to rounding. 

a

In 2006, there were 626 responses. 

b

In 2012, there were 400 responses. 

c

The shaded rows contain the 95 percent confidence intervals. 

Working relationships. Working relationships among co-workers is still a 

concern for agriculture specialists and supervisors, according to our 

analysis of the 2006 and 2012 survey data. Specifically, we estimate a 

similar percentage of agriculture specialists and supervisors at CBP in 

2006 and 2012 believe their work is definitely not respected by CBP 

management—42 percent in 2006 and 43 percent in 2012—and by CBP 
 

Page 29 GAO-12-885 Agriculture Inspections

officers—35 percent in 2006 and 28 percent in 2012.36

Table 4: Estimates for the Closed-ended Question “In General, Do You Feel that the Work of a CBP Agriculture Specialist Is 

Respected by CBP Officers and Management?” (in percent)

(See table 4). 

Respondents identified working relationships in both 2006 and 2012 as 

one of the most frequent responses to the open-ended question asking 

respondents what they would like to see changed or improved. In 

particular, some respondents stated that CBP officers and management 

do not respect their work or mission, and others noted that agriculture 

specialists are not treated as part of the team. However, in both 2006 and 

2012, respondents also identified working relationships among coworkers as one of the most frequent responses to our open-ended 

question of what is going well, suggesting that while some aspects of 

working relationships continue to be a concern, other aspects of working 

relationships are going well. In particular, some respondents noted that 

their fellow agriculture specialists were dedicated, highly-qualified, or hard 

working.

Response

Definitely yes Probably yes Uncertain Probably not Definitely not No answer

2006a 2012b 2006 2012 2006 2012 2006 2012 2006 2012 2006 2012

CBP officers 7 8 18 20 14 17 26 28 35 28 0 0 

Confidence 

intervalsc 4.8-8.8

4.9-

11.2

14.9-

21.9

15.3-

24.0

10.9-

17.0

12.8-

21.5

22.4-

30.0

22.9-

33.0

31.3-

39.6

22.5-

32.6

0.2- 

0.9

0.0- 

2.1

CBP 

management

6 6 14 15 15 15 22 21 42 43 1 1 

Confidence 

intervals

4.1-

7.6

3.3- 

8.7

11.3-

17.6

11.2-

18.9

12.4-

18.6

11.6-

20.0

19.1-

26.3

16.0-

25.2

37.6-

46.2

37.7-

48.8

0.4- 

1.3

0.0- 

2.1

Source: GAO analysis.

Notes: Numbers may not add to 100 percent due to rounding. 

In 2006, the question was phrased as: “In general, do you feel that your work as a CBP Agriculture 

Specialist is respected by CBP Officers and Management?” 

 

36The 95 percent confidence interval surrounding the 2006 estimate of 42 percent of 

agriculture specialists and supervisors at CBP believing their work is definitely not 

respected by CBP management ranged from 37.5 percent to 46.2 percent; the 95 percent 

confidence interval surrounding the 2012 estimate of 43 percent ranges from 37.7 percent 

to 48.8 percent. The 95 percent confidence interval surrounding the 2006 estimate of 35 

percent of agriculture specialists and supervisors at CBP believing their work is definitely 

not respected by CBP management ranged from 31.3 percent to 39.6 percent; the 95

percent confidence interval surrounding the 2012 estimate of 28 percent ranges from 22.5 

percent to 32.6 percent.
 

Page 30 GAO-12-885 Agriculture Inspections

a

In 2006, there were 626 responses. 

b

In 2012, there were 400 responses for CBP Officers and 398 responses for CBP Management. 

c

The shaded rows contain the 95 percent confidence intervals. 

Our analysis of the responses to the closed-ended questions in our 2012 

survey indicates that agriculture specialists’ and supervisors’ concerns 

about staffing levels and salary and benefits have increased since 2006. 

Both of these issues were also mentioned more frequently in 2012 in 

response to the open-ended question about what they would like to see 

changed or improved.

Staffing levels. In 2012, respondents identified staffing levels as the 

second most frequently cited issue they would like to see changed or 

improved. In 2006, staffing was the sixth most frequently offered 

response. Furthermore, we estimate that 50 percent of agriculture 

specialists and supervisors at CBP believe that their port definitely does 

not have enough agriculture specialists to carry out agriculture duties, and 

an additional 21 percent believe that their port probably does not, based 

on our analysis of closed ended questions.37 In 2006, we estimated that 

42 percent of agriculture specialists and supervisors at CBP believed their 

port definitely did not have enough agriculture specialists to carry out 

agricultural duties, and an additional 21 percent believed that their port 

probably did not.38

 

37The 95 percent confidence interval surrounding the estimate of 50 percent of agriculture 

specialists and supervisors at CBP believing that their port definitely does not have 

enough agriculture specialists to carry out agriculture duties ranges from 44.4 percent to 

55.6 percent, and the 95 percent confidence interval surrounding the estimate of 21 

percent ranges from 16.2 percent to 25.4 percent.

(See table 5.) In addition, in 2012, we estimate that 31 

percent of agriculture specialists and supervisors at CBP believe that 

staffing levels of agriculture specialists is a very major challenge to 

38The 95 percent confidence interval surrounding the 2006 estimate of 42 percent of 

agriculture specialists and supervisors at CBP believing that their port definitely does not 

have enough agriculture specialists to carry out agriculture duties ranged from 37.5 

percent to 46.0 percent, and the 95 percent confidence interval surrounding the 2006 

estimate of 21 percent ranged from 17.6 percent to 25.1 percent.

Survey Responses Show 

Increasing Concerns in 

Some Areas
 

Page 31 GAO-12-885 Agriculture Inspections

conducting agriculture duties at their port, and another 24 percent believe 

it is a major challenge.39

Table 5: Estimates for the Closed-ended Question “In Your Experience, Does Your 

Port Currently Have Enough Agriculture Specialists to Carry Out Agriculture 

Duties?” (in percent)

We did not ask this question in 2006.

2006 2012

Definitely yes 12 7 

Confidence intervalsa 9.8-15.0 4.6-10.3

Probably yes 16 14

Confidence intervals 12.6-18.9 10.7-18.6

Uncertain 8 7 

Confidence intervals 6.2-11.3 4.7-10.9

Probably not 21 21

Confidence intervals 17.6-25.1 16.2-25.4

Definitely not 42 50

Confidence intervals 37.5-46.0 44.4-55.6

No answer 1 0 

Confidence intervals 0.5-2.8 0.0-2.1

Source: GAO analysis.

Note: Numbers may not add to 100 percent due to rounding. 

a

The shaded rows contain the 95 percent confidence intervals. 

Salary and benefits. Salary and benefits were also higher on the list of 

things respondents would like to see changed or improved in 2012 

compared with 2006. In 2012, salary and benefits was the fourth most 

mentioned category, compared with 2006, when it was the seventh most 

mentioned category. Specifically, in 2012, 77 out of 406 respondents 

identified salary and benefits as something they would like to see 

changed or improved. In their responses to our open-ended question, 

respondents mentioned wanting the same retirement system as their CBP 

officer co-workers, lacking a career ladder for agriculture specialists and 

 

39The 95 percent confidence interval surrounding the estimate of 31 percent of agriculture 

specialists and supervisors at CBP believing that staffing levels of agriculture specialists is 

a very major challenge ranges from 25.8 percent to 36.3 percent, and the 95 percent 

confidence interval surrounding the estimate of 24 percent ranges from 19.6 percent to 

29.3 percent.
 

Page 32 GAO-12-885 Agriculture Inspections

supervisors, and lacking promotion opportunities. For example, CBP 

officers are considered law enforcement officers and are generally eligible 

for full retirement benefits after 20 years of creditable service. Agriculture 

specialists are not considered law enforcement officers and, generally, 

become eligible for full retirement benefits after 30 years of creditable 

service.

The AQI program is a key component of U.S. efforts to protect agriculture 

from the unintentional or deliberate introduction of pests and disease, and 

effective management of the AQI program requires a coordinated effort 

by DHS and USDA. Since we reported in 2006, both DHS and USDA 

have made progress in implementing our recommendations and 

overcoming some of the management challenges we identified, including 

ensuring that user fees are transferred to CBP and that important 

agriculture information is shared with agriculture specialists in a timely 

manner.

However, the AQI program continues to wrestle with fundamental 

problems that undermine the management of the program and risks 

wasting resources in a fiscally constrained environment. Specifically, in 

the absence of a strategic plan that lays out the program’s joint mission 

and goals, APHIS and CBP do not have a framework for defining the 

program’s mission, setting goals to achieve the desired results, and 

identifying performance measures for gauging progress towards those 

goals.

Furthermore, the agencies may not have sufficient information on which 

to base key decisions to support the AQI program because the data the 

two agencies are collecting and using for managing the program may not 

be reliable. Without ensuring that the data on arrivals, inspections, and 

interceptions across ports are entered accurately, the AQI program may 

not have sufficiently reliable data for supporting critical efforts for 

managing the program. When discrepancies exist between data in WADS 

and data recorded on daily logs at about half of the ports reviewed by the 

2010 to 2011 joint CBP-APHIS quality assurance reviews, it could be an 

indicator of more widespread data quality issues related to failures with 

the supervisory review policy and procedures in ensuring that data are 

entered accurately. In addition, the data supporting the agriculture canine 

program are hindered by the absence of a timely and consistent data 

review process at CBP field offices, resulting in incomplete and 

inaccurate data. Moreover, the agriculture canine program continues to 

collect some data that may not be meaningful or relevant to the program, 

Conclusions
 

Page 33 GAO-12-885 Agriculture Inspections

further straining the program’s resources. Without sufficiently reliable 

data, the AQI program cannot assess the effectiveness of the canine 

program. Furthermore, by collecting data that are not meaningful or useful 

for assessing the effectiveness of its canine handlers, the AQI program 

may be using resources to collect data it does not need.

Finally, the agencies may not be using their resources effectively. Having 

devoted 6 years and hundreds of thousands of dollars in contracts to 

develop a staffing model, CBP still does not have a risk-based staffing 

model that provides assurance that those ports of highest vulnerability for 

the entry of pests and disease are adequately staffed. Furthermore, DHS 

has not assessed the risk that insufficient resources may pose to 

implementing the staffing model once it is completed. Without a plan or 

strategy for how it will implement this staffing model that considers the 

fiscal resources that may realistically be available, the agency risks 

investing in a staffing model that it cannot execute. CBP also risks 

increasing the vulnerability of the agriculture sector to foreign pests and 

disease or disrupting international trade if agriculture specialists cannot 

keep up with demand for agriculture inspections. In addition, well-trained 

supervisory staff are a crucial resource for supporting the agriculture 

canine teams, but the results of our survey and the joint CBP-APHIS 

quality assurance reviews indicate that some supervisory staff may not 

have canine training or experience because of barriers such as a lack of 

resources at ports and the voluntary nature of supervisory canine training. 

As a result, supervisors in the AQI program may not have the skills 

necessary to manage issues unique to the canine program, such as the 

health and training of the canine. By overcoming these challenges, the 

United States would be in a better position to protect agriculture from the 

economic harm posed by foreign pests and disease.

We are making the following six recommendations.

To help ensure the CBP and APHIS agricultural quarantine inspection 

program protects U.S. agriculture from accidental or deliberate 

introduction of foreign pests and disease, we recommend that the 

Secretaries of Agriculture and of Homeland Security work together to take 

the following three actions:

• Develop a strategic plan for the AQI program that lays out its joint 

mission and program goals.

Recommendations for 

Executive Action
 

Page 34 GAO-12-885 Agriculture Inspections

• Once the strategic plan is completed, as part of a coordinated 

strategic planning effort, identify corresponding meaningful 

performance measures for monitoring progress towards those goals.

• Continue taking steps to improve the reliability of AQI data on arrivals, 

inspections, and interceptions across ports, including reviewing the 

supervisory review policy and procedures to ensure the data are 

entered accurately.

In addition, we recommend the Secretary of the Department of Homeland 

Security, in consultation with USDA where appropriate, take the following 

three actions:

• Take steps to ensure the agriculture canine program has reliable and 

meaningful data, including instituting a timely and consistent review 

process at CBP field offices, and evaluate the relevance of data 

collected for the agriculture canine program.

• Develop a plan or strategy for implementing the forthcoming AQI 

staffing model that assesses the risk of potential fiscal constraints and 

determines what actions should be taken to mitigate that risk by 

considering the fiscal resources that may realistically be available to 

ensure that agriculture staffing levels at each port are sufficient.

• Identify any agriculture canine supervisors who do not have canine 

training or experience and work with port directors to overcome any 

barriers to providing formal training.

We provided USDA and DHS with a draft of this report for their review 

and comment. In their written comments, both agencies agreed with our 

recommendations, and DHS provided technical comments, which we 

incorporated as appropriate. USDA’s comments appear in appendix III. 

DHS’s comments appear in appendix IV.

Agency Comments 

and Our Evaluation
 

Page 35 GAO-12-885 Agriculture Inspections

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

Secretaries of Agriculture and Homeland Security, the appropriate 

congressional committees, and other interested parties. In addition, the 

report is available at no charge on GAO’s website at http://www.gao.gov. 

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

me at (202) 512-3841 or shamesl@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix V.

Lisa Shames

Director, Natural Resources and Environment
 

Page 36 GAO-12-885 Agriculture Inspections

List of Congressional Requesters

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate 

The Honorable Daniel K. Akaka

Chairman

Subcommittee on Oversight of Government Management, 

the Federal Workforce, and the District of Columbia

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Kirsten E. Gillibrand

Chairman

Subcommittee on Livestock, Dairy, Poultry, Marketing, and Agriculture 

Security

Committee on Agriculture, Nutrition, and Forestry

United States Senate

The Honorable Dianne Feinstein

United States Senate
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-12-885 Agriculture Inspections

Our objectives were to examine the extent to which (1) U.S. Department 

of Agriculture (USDA) and the Department of Homeland Security (DHS) 

have implemented recommendations we made in 2006 to improve the 

Agricultural Quarantine Inspection (AQI) program; (2) data on arrivals, 

inspections, and interceptions are used for managing the program; and 

(3) the views of agriculture specialists at Customs and Border Protection 

(CBP) regarding their work environment have changed, if at all, since our 

2006 reports.

To address all of these objectives, we visited or spoke with officials at a 

nonprobability sample of five CBP ports of entry to observe agriculture 

work activities and discuss challenges related to conducting agriculture 

inspections and interceptions. These ports of entry were Austin, Texas; 

Baltimore, Maryland; Dallas, Texas; Miami, Florida; and San Ysidro, 

California. We selected these ports of entry based on size; the presence 

of agriculture specialists, supervisors, and canine handlers; and entry 

pathways, such as air, sea, and land. Because we used a nonprobability 

sample, the information we obtained from these visits cannot be 

generalized to other CBP ports of entry. The visits instead provided us 

with more in-depth information on the perspectives of various agriculture 

specialists in these ports of entry about the management of the AQI 

program.

To examine the extent to which GAO’s May 2006 recommendations have 

been implemented,1

• To determine the extent to which USDA’s Animal and Plant Health 

Inspection Service (APHIS) and DHS’s CBP improved informationsharing, we obtained and reviewed CBP’s agriculture information 

sharing policies and protocols regarding agriculture alerts and policy 

we interviewed DHS and USDA officials and 

reviewed documentation related to (1) improving information-sharing, (2) 

undertaking a full review of DHS’s financial management system for the 

AQI program, (3) removing barriers to timely and accurate AQI user fee 

transfers from USDA to DHS, (4) adopting meaningful performance 

measures, (5) establishing a national risk-based staffing model, (6) 

improving the agriculture canine program, and (7) revising user fees to 

cover AQI program costs. Specifically:

 

1

GAO, Homeland Security: Management and Coordination Problems Increase the 

Vulnerability of U.S. Agriculture to Foreign Pests and Disease, GAO-06-644 (Washington, 

D.C.: May 19, 2006).

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-12-885 Agriculture Inspections

updates, among other things, to evaluate changes since our 2006 

report. We discussed these policies with agriculture specialists and 

supervisors during our site visits. We also interviewed the Deputy 

Executive Director for Agriculture Operational Oversight to discuss 

changes in information-sharing policies and protocols since 2006. We 

conducted a nationally representative survey of agriculture specialists 

and supervisors at CBP, details of which are discussed below, and 

analyzed the results to determine the extent to which agriculture 

specialists and supervisors believe that information-sharing is a 

challenge.

• To determine the extent to which DHS reviewed its financial 

management system, we reviewed guidance on procedures for 

accounting for CBP work activities related to agriculture and 

interviewed officials with CBP’s Budget Group and APHIS’s Financial 

Management Division to discuss how the changes have affected the 

financial accountability for funds allocated for agriculture quarantine 

inspections.

• To review how USDA and DHS have removed barriers to user fee 

transfers, we obtained the updated Memorandum of Agreement 

signed by the Secretaries of Agriculture and Homeland Security that 

modified the user fee fund transfer schedule. We also received AQI 

user fee fund transfer records from APHIS to compare the timing and 

amount of transfers to the agreed upon amount. We interviewed 

officials from CBP’s Budget Group and APHIS’s Financial 

Management Division regarding the transfers to evaluate whether the 

steps taken by USDA have resulted in timely and accurate transfers to 

DHS.

• To evaluate APHIS’s and CBP’s progress in developing meaningful 

performance measures for the AQI program, we reviewed strategic 

planning documents, such as the Plant Protection and Quarantine 

(PPQ) strategic plan and selected sections of the Office of Field 

Operations’ draft strategic plan, for how AQI activities are 

incorporated into these plans. We interviewed AQI officials, including 

PPQ officials with strategic planning responsibilities, CBP officials with 

the Office of Field Operations Strategic Planning Division, and an 

official with the APHIS-CBP joint agency task force to discuss the 

existing AQI performance measures, including how they are used to 

assess performance, their limitations for measuring key AQI activities, 

and the extent to which APHIS and CBP are developing additional 

performance measures for managing the AQI program. We also 

discussed the extent to which the AQI program has developed a 

strategic plan with a joint mission and program goals, and we 

compared this to leading practices we have previously reported on for 
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-12-885 Agriculture Inspections

federal strategic planning at lower levels within federal agencies, such 

as planning for individual divisions, programs, or initiatives.2

• To evaluate the extent to which CBP has established a national riskbased staffing model, we reviewed CBP contracting documents 

related to CBP’s efforts to develop a model and interviewed officials 

from CBP’s Office of Field Operations and the Deputy Executive 

Director for Agriculture Operational Oversight regarding their progress 

towards, and their implementation plan and strategy for, a model. As 

part of evaluating the potential impact of the AQI program not having 

a risk-based staffing model, we reviewed standards for internal control 

in the federal government.3

• To assess the effectiveness of the canine program, we analyzed and 

reviewed agriculture canine units’ quarterly proficiency scores from 

fiscal years 2006 through 2011, the agriculture canine training 

manual, agriculture canine units’ leash time data from fiscal years 

2006 through 2011, and CBP’s agriculture canine daily statistics 

template. We discussed these with the CBP agriculture canine 

program manager to determine the extent to which the data can be 

used for assessing the agriculture canine program. To determine the 

extent to which the proficiency data have missing values, we 

compared the number of active agriculture canine teams for each 

quarter provided by the agriculture canine program manager to the 

number of canine teams that reported a proficiency score for that 

quarter and discussed the limitations of this approach with the 

agriculture canine program manager. We also reviewed the results of 

APHIS-CBP joint quality assurance reviews from 2010 through 2011, 

the most recent years for which complete data are available, for those 

ports that had canine handlers to determine the number of reviews 

that found canine handlers did not have supervisors with canine 

training. We also analyzed the results of our survey, discussed below, 

to determine the extent to which canine handlers believe their 

supervisor has adequate experience. We interviewed the agriculture 

canine program manager on training policy and procedures for canine 

handlers and supervisors, steps CBP has taken to address staffing 

issues raised in our 2006 report, and data quality issues with the 

agriculture canine program.

 

2

For example, see GAO, Environmental Justice: EPA Needs to Take Additional Actions to 

Help Ensure Effective Implementation, GAO-12-77 (Washington, D.C.: Oct. 6, 2011).

3

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-12-885 Agriculture Inspections

• To evaluate how DHS and USDA have revised user fees since 2006, 

we reviewed Federal Register documents relating to APHIS’s 

attempts to revise AQI user fees. We interviewed APHIS officials on 

their plans for future revisions to the user fee structure. GAO is 

conducting a separate evaluation of the AQI user fee structure and 

options of setting and distributing them.

To examine the extent to which data on agriculture arrivals, inspections, 

and interceptions are used for managing the AQI program, we reviewed 

DHS and USDA inspection and interception data, related summary 

reports, and policies. Specifically, we obtained and analyzed data from 

USDA APHIS’s Work Accomplishment Data System for fiscal years 2001 

through 2011 and reviewed data collection and entry procedures and 

definitions of required data elements that may impact the use of the data 

for managing the program. We reviewed DHS and USDA joint Quality 

Assurance Reviews— joint agency reports on port compliance with 

agricultural inspection policy— from 2010 through 2011, the most recent 

years for which data were available. We reviewed documents related to 

contractor-led efforts for key aspects of the AQI program to determine 

how those efforts were impacted by data quality issues. Additionally, we 

interviewed key program officials at USDA and DHS to discuss the 

reliability of the data and whether there were limitations in the data that 

may affect the extent to which these data on agricultural quarantine 

inspections and interceptions are used to make AQI program decisions. 

To assess the reliability of arrival, inspection and interception data, we 

observed data collection and data entry procedures at selected ports of 

entry; reviewed the finding of CBP-APHIS joint quality assurance reviews 

from 2010 and 2011; and interviewed agriculture inspectors, supervisors 

and program managers. We concluded that inspection and interception 

data in APHIS’s Work Accomplishment Data System (WADS) may hinder 

managers’ ability to definitively determine whether patterns observed in 

inspection and interception data are attributable to real changes in the 

number of inspections and interceptions, or to errors in the data collection 

and entry processes. We found that potential weaknesses exist at several 

places in the data collection process. The process for recording 

inspections and interceptions varies significantly from port to port. At 

some ports, inspectors record inspection information on a paper clipboard 

and then proceed to enter that information into an electronic system 

following the inspection. However, at other locations, paper records of 

inspections and interceptions are compiled and entered into electronic 

form as much as one month after the inspection took place. The multiple 

steps involved in data entry increase the likelihood of errors; and at some 

ports, the amount of time that elapses between inspection and 
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-12-885 Agriculture Inspections

interception activities and data entry reduces the usefulness of inspector 

recall to correct any ambiguities or errors found in paper records.

To determine the extent to which the views of agriculture specialists 

regarding their work environment have changed, if at all, since GAO last 

reported, we conducted a nationally representative survey of agriculture 

specialists and supervisors at CBP regarding their work environment. The 

survey consisted of closed-ended and open-ended questions. 

Specifically, we drew a stratified random probability sample of 556 

agriculture specialists and supervisors from the universe of 2,311 

specialists in the DHS’s CBP who were engaged in agricultural inspection 

duty as of October 2011 and still engaged in this duty as of February 

2012. We excluded 10 respondents from our sample of 556 as out-ofscope because these individuals performed management duties outside 

of CBP ports. All agriculture canine handlers were placed in one stratum; 

other strata were defined by the number of specialists at the respective 

ports. Each sample was subsequently weighted in the analysis to account 

statistically for all specialists in the population. We received an 

unweighted response rate of 74 percent. The survey results for the 

closed-ended questions are generalizable to all agriculture specialists and 

supervisors at CBP.

Because we followed a probability procedure based on random 

selections, our sample is only one of a large number of samples we might 

have drawn. Since each sample could have provided different estimates, 

we express our confidence in the precision of our particular sample’s 

results as 95 percent confidence intervals. This is the interval that would 

contain the actual population values for 95 percent of the samples we 

could have drawn. In developing the survey, we met with CBP and APHIS 

officials to gain a thorough understanding of the AQI program. We also 

shared a draft copy of the questionnaire with CBP officials who provided 

us with comments, including technical corrections, to ensure that the 

questions were clear and unambiguous, terminology was used correctly, 

the questionnaire did not place an undue burden on agency officials, the 

information could feasibly be obtained, and the survey was 

comprehensive and unbiased. On the basis of the feedback we received, 

we made changes to the content of the survey. We posted the 

questionnaire on GAO’s survey website. When the survey was activated, 

the agriculture specialists who had been selected to participate were 

informed of its availability by an e-mail message that contained a unique 

user name and password. This allowed respondents to log on and fill out 

a questionnaire but did not allow respondents access to the 

questionnaires of others. We sent reminder and follow-up e-mails to 
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-12-885 Agriculture Inspections

agriculture specialists who had not completed their surveys in a specific 

time period to increase our response rate. Since this was a Web-based 

survey, respondents entered their answers directly into the electronic 

questionnaire, eliminating the need to key data into a database, thus 

minimizing error. The survey was available from February 6, 2012, until 

March 9, 2012. Results of the survey are summarized in GAO-12-884SP. 

To facilitate comparison with the findings from our prior report, we used a 

questionnaire for this survey similar to the one we used in 2006. The 

2006 questionnaire focused on the transition from agriculture specialists 

and supervisors in USDA to CBP, and we recognize that there may be 

demographic shifts in these agriculture specialists and supervisors that 

we did not calculate. However, we do not believe this affected the results 

of our analysis. The 2012 survey contained 25 closed-ended questions 

that asked for opinions and assessments of (1) agricultural inspection 

training, (2) agricultural inspection duties, (3) agricultural inspection 

supplies and equipment, (4) communication and information-sharing 

within CBP and between other agencies, and (5) challenges related to 

conducting agricultural work activities. Some of those questions were 

specifically for agriculture canine handlers. In addition, the survey 

contained two open-ended questions asking for opinions and 

assessments of what is going well and what could be improved in regards 

to the work of agriculture specialists. We conducted a content analysis on 

the responses to the open-ended questions using all of the same 

categories that were used in 2006, adding new categories as appropriate. 

We categorized the responses based on the descriptions of the 

categories from 2006. The responses were placed into as many 

categories as appropriate; however, each response was placed no more 

than once in any category. We conducted an independent review of the 

results and resolved any disagreement.

We conducted this performance audit from August 2011 to September 

2012 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.
Appendix II: Summary of Responses to Openended Survey Questions in 2006 and 2012 

Page 43 GAO-12-885 Agriculture Inspections

Table 6: GAO Summary of Responses to the Open-ended Question “What Is Going Well with Respect to Your Work as an 

Agriculture Specialist?” in 2006 Compared with 2012

2006 2012

Category Description

Number of 

comments out of 

626 total 

respondents 

reflecting this 

categorya

Number of 

comments out of 

406 total 

respondents 

reflecting this 

categorya

Agriculture mission See improvement in inspections or interceptions; 

positive mentions of the mission

34 91

Relationships with co-workers 

(Working relationships)

Relationships with CBP officers are good; receive 

respect from coworkers

113 66

Salary and benefits Like salary, overtime, benefits, retirement system, or 

work schedule

54 35

Equipment, supplies, uniforms Have tools and supplies needed; likes uniform 18 33

Training Training is going well, have enough knowledge to do 

job

50 31

Information-sharing Receive information from within CBP; good 

communication with other agencies

25 30

Dedicated agriculture specialists Fellow agriculture specialists are highly-qualified or 

dedicated

Not countedb 30

Access to databases Have access to databases; increased ability to 

target because of access

27 21

“One Face at the Border” initiative Integration of DHS and USDA good thing; common 

goals

34 20

Flexibility to do job Given enough flexibility or time to perform job as see 

fit; flexible job duties 

28 19

I like my job Like my job; feel performing an important mission 34 16

Nothing is going well Nothing or not much is going well 93 14

Overall going well Overall things are going well (no specifics) 10 8 

Have a job Have a job, get paid 28 6 

Staffing Staffing levels are good/adequate 26 4 

Other Statements not frequent enough to be own category 33 37

Source: GAO analysis of survey responses to this question.

a

Responses to this question may have been placed in more than one category. 

b

In 2006, this category was not mentioned frequently enough to be counted separately. 

Appendix II: Summary of Responses to Openended Survey Questions in 2006 and 2012
Appendix II: Summary of Responses to Openended Survey Questions in 2006 and 2012

Page 44 GAO-12-885 Agriculture Inspections

Table 7: GAO Summary of Responses to the Open-ended Question “What Would You Like to See Changed or Improved with 

Respect to Your Work as an Agriculture Specialist?” in 2006 Compared with 2012

2006 2012

Category Description

Number of 

comments out of 

626 total 

respondents 

reflecting this 

categorya

Number of 

comments out 

of 406 total 

respondents 

reflecting this 

categorya

Problems with CBP chain of 

command 

Want separate chain of command for agriculture; want 

to be separated from rest of CBP (similar to Border 

Patrol); want agriculture supervisors; supervisors do not 

understand mission

167 125

Staffing levels Not enough staff; heavy workload 113 112

Respect or relationships 

(Working relationships)

Disrespect or lack of comprehension from management 

or CBP officers regarding mission

190 109

Priority given to the agriculture 

mission 

Weakening of agriculture mission; competing priorities 

prevent agriculture inspector from performing mission

179 86

Salary and benefits Salary not enough; lack of promotion opportunities for 

agriculture specialists; lack of career ladder; issues with 

retirement policy

97 77

Training Training opportunities missing or unsatisfactory; training 

for non-agriculture specialists inadequate

123 68

Overtime policy Not enough access to overtime; overtime schedule is 

inflexible

75 50

Policies related to self defense Concern for personal safety; want to be armed; want 

self-defense training

59 41

Equipment/supplies Not enough supplies or funding for supplies; difficulty 

obtaining supplies; inadequate office space

113 39

Information-sharing Not receiving information from USDA; difficulty 

communicating with specialists at other ports; lack of 

information sharing from other agencies

93 38

Opportunities for temporary 

assignments

Want opportunities for temporary assignments 37 30

Uniforms Want different uniform for any reason, including to look 

different than armed co-workers or for additional 

durability

Not countedb 22

Data/paperwork Entering required data or completing paperwork is time 

consuming or inefficient

Not countedb 20

Return to USDA Agriculture mission should be placed back under USDA 61 8 

Other Statements not frequent enough to be own category 117 79

Source: GAO analysis of survey responses to this question.

a

Responses to this question may have been placed in more than one category. 

b

In 2006, this category was not mentioned frequently enough to be counted separately. 
Appendix III: Comments from the U.S. 

Department of Agriculture

Page 45 GAO-12-885 Agriculture Inspections

Appendix III: Comments from the U.S. 

Department of Agriculture
Appendix III: Comments from the U.S. 

Department of Agriculture

Page 46 GAO-12-885 Agriculture Inspections
Appendix III: Comments from the U.S. 

Department of Agriculture

Page 47 GAO-12-885 Agriculture Inspections
Appendix IV: Comments from the Department 

of Homeland Security

Page 48 GAO-12-885 Agriculture Inspections

Appendix IV: Comments from the 

Department of Homeland Security
Appendix IV: Comments from the Department 

of Homeland Security

Page 49 GAO-12-885 Agriculture Inspections
Appendix IV: Comments from the Department 

of Homeland Security

Page 50 GAO-12-885 Agriculture Inspections
Appendix V: GAO Contacts and Staff 

Acknowledgments

Page 51 GAO-12-885 Agriculture Inspections

Lisa Shames (202) 512-3841 or shamesl@gao.gov

In addition to the individual named above, Mary Denigan-Macauley 

(Assistant Director), Adam Anguiano, Carl Barden, Michelle Cooper, 

N’Kenge Gibson, Amanda Harris, Stuart Kaufman, Kirsten Lauber, Alison 

O’Neill, and Kiki Theodoropoulos made key contributions to this report. 

Important contributions were also made by Kevin Bray, Joyce Evans, and 

Jena Sinkfield.

Appendix V: GAO Contacts and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(361330)
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