TRUSTED 

TRAVELERS 

Programs Provide 

Benefits, but 

Enrollment Processes 

Could Be 

Strengthened

Report to Congressional Requesters

May 2014

GAO-14-483

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-483, a report to 

congressional requesters.

May 2014

TRUSTED TRAVELERS

Programs Provide Benefits, but Enrollment 

Processes Could Be Strengthened

Why GAO Did This Study

Nearly 1 million people and $1.5 billion 

of trade entered the United States 

through 328 POEs on an average day 

in fiscal year 2013. CBP, within the 

Department of Homeland Security

(DHS), has four trusted traveler 

programs—Global Entry, NEXUS, 

SENTRI, and Free and Secure Trade 

(FAST)—to provide for expedited travel 

through dedicated lanes and kiosks at 

POEs. GAO was asked to review these 

programs. This report addresses (1) 

trends in enrollment and program use 

over the past 5 fiscal years, (2) the 

extent to which CBP has designed and 

implemented processes to help ensure 

consistent and efficient enrollment of 

applicants, and (3) the impacts of the 

programs on travelers and CBP. GAO 

analyzed data on enrollment and POE

operations from fiscal years 2009 

through 2013, reviewed documents,

and visited nine POEs selected based 

on traveler volume and location. While 

information from these POEs cannot 

be generalized, the visits provided 

insights on program operations. 

What GAO Recommends

GAO recommends, among other 

things, that CBP assess the feasibility 

of practices to improve application 

processing times, establish a 

mechanism to document types of 

interview questions asked, and 

document information on foreign 

countries’ procedures. DHS concurred 

with all recommendations but one to 

establish a mechanism to document 

interview questions asked because, 

among other reasons, DHS does not 

believe it should use scripted interview 

questions. As discussed in this report, 

GAO continues to believe in the need 

for such a mechanism.

What GAO Found

As of January 2014, there were about 2.5 million people enrolled in U.S. 

Customs and Border Protection’s (CBP) four trusted traveler programs—which 

provide expedited travel for preapproved, low-risk travelers and cargo—and 

enrollments more than quadrupled over the past 5 fiscal years. About 43 percent 

of trusted travelers were enrolled in Global Entry, operating at select air ports of 

entry (POE) and about 38 percent were enrolled in NEXUS, operating at northern 

border POEs. Trusted traveler entries into the United States increased from fiscal 

years 2009 through 2013. For example, entries through lanes for the Secure 

Electronic Network for Travelers Rapid Inspection (SENTRI) program, operating

at southern border POEs, increased from 5.9 million to 12.6 million vehicles.

CBP has designed and implemented trusted traveler enrollment processes, but 

could improve key areas to enhance and assess consistency and efficiency in 

those processes. U.S. citizens and foreign nationals seek to enroll in CBP’s 

trusted traveler programs through an application vetted by CBP and an in-person 

interview. CBP has taken steps to improve the efficiency of the applicationvetting process by, for example, automating background checks. However, CBP 

has not assessed the feasibility of various other practices for improving efficiency

in enrollment processes, such as conducting group briefings for applicants on the 

programs. As of August 2013, CBP had a backlog of pending applications, as 

there were about 90,000 applications pending CBP vetting, and another 33,000 

applicants who had not scheduled an interview. Assessing the feasibility of 

various practices, consistent with program management standards, could better 

position CBP to improve application-processing times. Further, CBP has 

designed some processes for the trusted traveler applicant interview process to 

help ensure consistency across enrollment centers; however, GAO identified

variations in interviews and application denial rates, indicating that interviews 

may not be conducted consistently across enrollment centers. For example, GAO 

observed interviews that did not consistently follow procedures laid out in CBP 

guidance at 2 of the 3 centers where GAO observed interviews. Establishing a 

mechanism for CBP officers to document the kinds of questions asked and the 

nature of the applicants’ responses could better position CBP to help ensure that 

interviews are conducted consistently. In addition, CBP has implemented trusted 

traveler programs that allow participating low-risk citizens from nine countries to 

use Global Entry kiosks at select air POEs. CBP has discussed information about 

other countries’ operational procedures for sharing applicant-vetting results, but 

has not documented this information for seven of the countries, consistent with 

internal control standards. Without such documentation, there is no institutional 

record that those countries’ procedures for vetting applicants help to ensure that 

only low-risk applicants are enrolled.

Trusted travelers generally experience shorter wait times than regular travelers,

and CBP spends less time inspecting trusted travelers at POEs than regular 

travelers. GAO’s analysis of CBP data showed that primary inspections took 

about twice as long or longer on average for regular travelers than for trusted 

travelers at 11 of 14 SENTRI crossings and 12 of 18 NEXUS crossings in fiscal 

year 2013. GAO’s analysis of CBP data also indicates that trusted travelers 

commit fewer border violations, such as smuggling, than regular travelers. 

View GAO-14-483. For more information, 

contact Rebecca Gambler at (202) 512-8777

or gamblerr@gao.gov.
Page i GAO-14-483 CBP Trusted Traveler Programs

Letter 1

Background 5

Enrollment in Trusted Traveler Programs Has Increased in the 

Past 5 Fiscal Years; Use Differs by Program and POE 14

CBP Has Designed and Implemented Enrollment Processes, but 

Opportunities Exist to Enhance Efficiency and Consistency 20

CBP Moves Trusted Travelers through POEs More Quickly than 

Other Travelers, Allowing CBP to Focus Its Resources on 

Travelers It Knows Less About 37

Conclusions 44

Recommendations for Executive Action 45

Agency Comments and Our Evaluation 46

Appendix I Ombudsman Reconsideration Process 52

Appendix II Ports of Entry with Dedicated Trusted Traveler Lanes and Kiosks 54

Appendix III Trusted Traveler Application Denial Rates and Revocations 57

Appendix IV Number and Percentage of Trusted Traveler Entries at Ports of Entry 

That Have Trusted Traveler Lanes, by Program, Fiscal Years 2009 

through 2013 60

Appendix V CBP Efforts to Address Wait Time Data Limitations 65

Appendix VI Comments from the Department of Homeland Security 67

Appendix VII GAO Contact and Staff Acknowledgments 70

Contents
Page ii GAO-14-483 CBP Trusted Traveler Programs

Tables

Table 1: U.S. Customs and Border Protection (CBP) Trusted 

Traveler Programs 5

Table 2: Ports of Entry (POE) and Specific Crossings for Trusted 

Traveler Programs at Land Borders 54

Table 3: U.S. Airports with Global Entry Kiosks 56

Table 4: Number and Percentage of Vehicle Entries through 

Crossings with Dedicated Secure Electronic Network for 

Travelers Rapid Inspection (SENTRI) Lanes That Were 

Trusted Travelers, Fiscal Years 2009 through 2013a 60

Table 5: Number and Percentage of Vehicle Entries through 

Crossings with Dedicated NEXUS Lanes That Were 

Trusted Travelers, Fiscal Years 2009 through 2013a 61

Table 6: Number and Percentage of Passenger Entries through 

Airports for Global Entry Kiosks, Fiscal Years 2012 

through 2013 62

Table 7: Number and Percentage of Commercial Vehicle Entries 

through Ports of Entry with Dedicated Free and Secure 

Trade (FAST) Lanes That Were Trusted Travelers, Fiscal 

Years 2009 through 2013 64

Figures

Figure 1: U.S. Customs and Border Protection (CBP) Trusted 

Traveler Enrollment Process 8

Figure 2: Trusted Traveler Ports of Entry (POEs) by Program 12

Figure 3: Trusted Traveler Enrollments, Fiscal Years 2009 through 

2013 15

Figure 4: Trusted Traveler Membership by Program, as of January 

2014 16

Figure 5: Trends in the Use of Trusted Traveler Lanes and Kiosks, 

Including the Number of Entries and Percentage of 

Entries That Were Trusted Travelers, Fiscal Years 2009-

2013 19

Figure 6: Average Trusted Traveler Initial Application Vetting 

Time, Fiscal Years 2009-2013 22

Figure 7: Range of Trusted Traveler Application Denial Rates at 

Enrollment Centers 31

Figure 8: Number of Border Crossings with Differences in Wait 

Times for Trusted and Regular Travelers by Program, 

Fiscal Year 2013 39
Page iii GAO-14-483 CBP Trusted Traveler Programs

Figure 9: Detroit Port of Entry Choke Point at Which Trusted 

Traveler Traffic May Wait with Regular Traffic 41

Figure 10: Reconsideration Cases Reviewed by the Ombudsman, 

Fiscal Years 2009-2013 52

Figure 11: Trusted Traveler Application Denial Rates for Fiscal 

Years 2009 through 2013 58

Figure 12: Trusted Traveler Revocations as of January 2014 59

Abbreviations

CBP U.S. Customs and Border Protection

CBSA Canadian Border Services Agency

C-TPAT Customs-Trade Partnership Against Terrorism

DHS Department of Homeland Security

FAST Free and Secure Trade

GES Global Enrollment System

GOES Global Online Enrollment System

OFO Office of Field Operations

POE port of entry

SENTRI Secure Electronic Network for Travelers Rapid Inspection

TSA Transportation Security Administration

WHTI Western Hemisphere Travel Initiative

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Page 1 GAO-14-483 CBP Trusted Traveler Programs

441 G St. N.W.

Washington, DC 20548

May 30, 2014

Congressional Requesters

On a typical day in fiscal year 2013, nearly 1 million passengers and 

pedestrians and over 67,000 truck, rail, and sea containers worth 

approximately $1.5 billion entered the United States through 328 U.S. 

land, sea, and air ports of entry (POE), according to U.S. Customs and 

Border Protection (CBP).1

CBP’s focus has historically been on security; however, CBP has 

undertaken specific efforts to facilitate legitimate travel and trade. A key 

part of these efforts is CBP’s development of four trusted traveler 

programs to expedite the travel of low-risk passengers and screened 

shipments across the border. More specifically, trusted traveler programs 

provide for expedited travel for preapproved, low-risk travelers—including 

U.S. citizens and foreign nationals—and cargo through dedicated lanes 

and kiosks at POEs. Individuals can apply for membership in all four of 

the trusted traveler programs online and, if conditionally approved, 

schedule an appointment with a CBP officer to undergo an enrollment 

interview, where applicants can be approved or denied membership in the 

programs. The four CBP trusted traveler programs are Secure Electronic 

Network for Travelers Rapid Inspection (SENTRI), NEXUS, Global Entry, 

and Free and Secure Trade (FAST). SENTRI offers expedited processing 

to approved low-risk travelers at southern land borders, while NEXUS 

Within the Department of Homeland Security 

(DHS), CBP is the lead federal agency charged with a dual mission of 

keeping terrorists and their weapons, criminals and their contraband, and 

inadmissible aliens out of the country while also facilitating the flow of 

legitimate travel and trade at the nation’s borders. CBP’s Office of Field 

Operations (OFO) is responsible for cargo- and passenger-processing 

activities related to security, trade, immigration, and agricultural 

inspection at POEs.

 1

Ports of entry are the facilities that provide for the controlled entry into or departure from 

the United States for persons and materials. Specifically, a port of entry is any officially 

designated location (seaport, airport, or land border location) where Department of 

Homeland Security officers or employees are assigned to clear passengers and 

merchandise, collect duties, and enforce customs laws. A single land port of entry may be 

composed of one or more crossings. For example, the Port of Laredo, Texas, headed by a 

port director, oversees operations at four separate border crossings, one rail crossing, and 

one airport.
Page 2 GAO-14-483 CBP Trusted Traveler Programs

primarily offers expedited processing to approved, low-risk travelers at the 

northern land border. Global Entry offers low-risk aviation passengers 

expedited processing at select aviation POEs. FAST allows low-risk 

commercial truckers expedited access at select commercial POEs at the 

northern (FAST North) and southern (FAST South) land borders.

You asked us to review CBP’s trusted traveler programs to determine the 

extent to which the programs have improved the facilitation of legitimate 

travel and trade, including the efficiency of the application processes and 

the potential impacts on security. This report addresses the following 

questions:

1. What are the trends in enrollment and use of the trusted traveler 

programs over the past 5 fiscal years?

2. To what extent has CBP designed and implemented processes to 

help ensure the consistent and efficient enrollment of applicants in the 

trusted traveler programs?

3. What do data collected at POEs indicate about the impacts of the 

trusted traveler programs for travelers and CBP?

To inform our analysis of all three objectives, we visited nine POEs, 

including airports and land POEs, along or near the northern and 

southern borders. We selected the POEs in these locations on the basis 

of the locations having (1) higher than average traffic and participation in 

trusted traveler programs, (2) multiple POEs in geographic proximity to 

one another that participate in two or more trusted traveler programs, (3) 

enrollment centers—where applicants undergo an interview process 

when applying to be a trusted traveler—that collectively cover all four 

trusted traveler programs (SENTRI, NEXUS, Global Entry, and FAST), 

and (4) geographic dispersion to cover the southern and northern 

borders. The POEs we visited were Los Angeles International Airport; 

San Ysidro, California; Otay Mesa, California; Seattle-Tacoma 

International Airport; Blaine, Washington; Detroit Metropolitan Airport; 

Detroit, Michigan; and San Antonio International Airport and Laredo, 

Texas. While information we obtained from these visits cannot be 

generalized to all POEs, the visits provided us with insights into the 

operation of the trusted traveler programs.

To determine the trends in the enrollment and use of the trusted traveler 

programs over the past 5 fiscal years, we analyzed enrollment data from 

fiscal years 2009 through 2013 and selected membership and enrollment 

data as of January 2014. We met with CBP officials responsible for 
Page 3 GAO-14-483 CBP Trusted Traveler Programs

managing the enrollment system data to discuss data reliability, reviewed 

system documentation, and electronically tested the data. We determined 

that the data were sufficiently reliable for the purposes of this report. We 

also met with officials responsible for overseeing or conducting the 

enrollment interviews at all 12 enrollment centers at the locations we 

visited to gain a better understanding of the applicant interview process. 

We reviewed CBP data related to the numbers of trusted and regular 

travelers crossing the northern and southern land border crossings with 

dedicated trusted traveler lanes and through airports with Global Entry 

kiosks for fiscal years 2009 through 2013. To assess the reliability of 

these data, we reviewed documentation about CBP’s data systems; 

interviewed agency officials responsible for managing, assessing, and 

using the data and the relevant systems; and electronically tested the 

data. We determined that the data were sufficiently reliable for the 

purposes of this report.

To determine the extent to which CBP has designed and implemented 

processes to help ensure the consistent and efficient enrollment of 

applicants in the trusted traveler programs, we reviewed the policies, 

procedures, and guidelines governing the trusted traveler enrollment 

process, such as the Trusted Traveler Handbook, policy memorandums, 

and bilateral arrangements with other countries.2

 2

The United States has bilateral arrangements with other countries that provide the 

framework for those countries’ participation in Global Entry. The United States also has an 

arrangement with Canada regarding management of the NEXUS and FAST programs.

To determine the extent 

to which the enrollment process resulted in consistent outcomes, we 

analyzed enrollment data from fiscal years 2009 through 2013 described 

above. When possible, we observed enrollment interviews and examined 

any locally developed guidance for conducting the enrollment interviews. 

We also reviewed and analyzed selected daily reports summarizing 

interview appointment availability from fiscal years 2013 and 2014. 

Additionally, we met with officials at CBP’s Vetting Center and 

Ombudsman’s office who manage the processes of vetting trusted 

traveler applications and reviewing cases where a person believes that 

his or her denial or revocation for participation in a program should be 

reconsidered. Further, we met with officials from CBP to discuss the 

procedures for developing bilateral arrangements and implementing joint 

trusted traveler programs with other countries. We observed enrollment 

center operations, interviewed CBP officials, and reviewed CBP 

documentation to assess the extent to which these enrollment processes 
Page 4 GAO-14-483 CBP Trusted Traveler Programs

were consistent with CBP guidelines, Standards for Internal Control in the 

Federal Government, Office of Management and Budget guidance on 

performance measures, and program management standards.3

To determine what data collected at POEs indicate about the impacts of 

the trusted traveler programs on travelers and CBP, we reviewed CBP 

data for fiscal years 2009 through 2013 related to the use of trusted 

traveler programs at POEs. These data include (1) the numbers and 

types of violations committed by trusted and regular travelers and (2) the 

differences in wait times and inspection times for trusted and regular 

travelers at crossings with trusted traveler lanes and kiosks. We reviewed 

CBP policies and guidance, such as the Trusted Traveler Handbook, 

memos describing accepted methodologies for calculating wait times, and 

CBP self-inspection reports. We interviewed CBP field officials at the nine 

POEs we visited about the operational impacts of the program related to 

security, traveler wait times, and the time it takes CBP to inspect 

travelers, and observed these impacts, including differences in 

infrastructure across POEs. We also interviewed CBP headquarters 

officials about the reliability of trusted and regular traveler wait time data, 

steps CBP is taking to improve the reliability of these data, and the extent 

to which CBP measures the impacts of the programs. In addition, we 

reviewed documentation and electronically tested the data in order to 

assess their reliability. We determined that the data were sufficiently 

reliable for the purposes of our report. However, we limited the scope of 

our work on wait times data, as CBP is currently taking steps to improve 

the reliability of the data. Data reliability considerations are discussed 

later in this report.

We also 

interviewed representatives from three associations, which we selected 

based on their representation of members of the travel or trade industries, 

to obtain their perspectives on the trusted traveler enrollment process. 

The perspectives of these associations are not generalizable to all of the 

travel and trade industries, but provided insights on the enrollment 

process and impacts of the trusted traveler programs.

 3

See Project Management Institute, The Standard for Program Management©, Third 

Edition, (Newton Square, Pennsylvania: 2013); Office of Management and Budget, 

Performance Measurement Challenges and Strategies (Washington, D.C.: June 2003); 

and GAO, Internal Control: Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).
Page 5 GAO-14-483 CBP Trusted Traveler Programs

We conducted this performance audit from February 2013 to May 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

CBP’s four trusted traveler programs are designed to allow for expedited 

travel for preapproved, low-risk travelers and cargo through dedicated 

lanes and kiosks at select POEs throughout the nation. The four trusted 

traveler programs are predicated on the vetting of travelers who have 

voluntarily applied for membership, paid a fee, and provided personal 

data to CBP. Travelers who are granted trusted traveler status are 

considered lower risk than other travelers because of the vetting CBP 

conducts both when the travelers apply for program participation and after 

they become members. The programs, according to CBP officials, are 

part of the agency’s risk-based security approach to focus resources, 

such as CBP officers, at the POEs on passengers and cargo that have

not been identified as low risk. Table 1 provides information on each of 

CBP’s trusted traveler programs.

Table 1: U.S. Customs and Border Protection (CBP) Trusted Traveler Programs

Trusted traveler 

program Port of entry (POE) locations

Primary port of

entry environment Year begun

Eligible countries

and citizenship

Secure Electronic 

Network for Travelers 

Rapid Inspection 

(SENTRI)

10 southern border POEs Land 1995 Any

NEXUS 12 northern border POEs Land, air, and sea 2002 Citizens or legal permanent 

residents of the United States or 

Canada

Free and Secure 

Trade (FAST)

8 southern and 4 northern border 

POEs

Commercial trucking 2002 Citizens or legal permanent 

residents of the United States, 

Canada, or Mexico

Background

CBP’s Four Trusted 

Traveler Programs
Page 6 GAO-14-483 CBP Trusted Traveler Programs

Trusted traveler 

program Port of entry (POE) locations

Primary port of

entry environment Year begun

Eligible countries

and citizenship

Global Entry 31 airports in the United States 

with incoming international flights 

and 10 airports in Canada and 

Ireland that clear passengers on 

outbound flights for entry into the 

United States

Air 2012 Citizens or legal permanent 

residents of the United States, 

citizens of Germany, Mexico, the 

Netherlands, Qatar, the Republic 

of Korea, Panama, or the United 

Kingdom

a

Source: GAO analysis of CBP data.

b

a

Global Entry began as a pilot program in 2008 and became a permanent program in March 2012.

b

Citizens from these countries are eligible to participate in Global Entry. As of March 2014, CBP 

considers arrangements with four of the seven countries to be in the pilot phase (Germany, Qatar, 

Panama, and the United Kingdom). In addition, CBP has completed bilateral arrangements with Israel 

and Saudi Arabia for participation in Global Entry; however, these pilots have not begun or have 

begun on a limited basis. According to CBP officials, CBP plans to expand the pilot with Saudi Arabia 

in the future. CBP has signed bilateral arrangements with Australia and New Zealand, but according 

to CBP officials, these countries have not established programs to allow their citizens to participate in 

Global Entry.

To enroll in a trusted traveler program, applicants from the United States 

and other eligible countries must submit an initial application, pay a fee, 

have their information vetted by CBP, and undergo an in-person 

interview. Applicants apply for each of the four trusted traveler programs 

through CBP’s Global Online Enrollment System (GOES). When 

applying, individuals submit information in GOES, including their name, 

address, date of birth, country of citizenship, and other pertinent 

information, such as which trusted traveler program they are applying for 

and payment information. Applicants also must answer questions 

included in the application on such topics as travel history, place of birth, 

and employment, among others. In addition, applicants must submit a 

nonrefundable payment for the processing of their applications.4

Once a completed application is certified by the applicant and the 

nonrefundable payment is successfully processed, CBP officers are to 

review the application at CBP’s Vetting Center to determine whether to 

conditionally approve the applicant. As part of this vetting process, CBP 

officers at the Vetting Center are to determine applicants’ nationality and 

 4

SENTRI applicants must pay a $25 application fee when they apply; the total application 

fee is $122.25, which also includes fees for processing fingerprints and to support the 

system of dedicated SENTRI lanes. NEXUS and FAST applicants must pay a $50 

application fee. Global Entry applicants must pay a $100 application fee. 

Processes for Enrolling

in the Trusted Traveler 

Programs
Page 7 GAO-14-483 CBP Trusted Traveler Programs

admissibility, and assess any potential risk factors. In particular, 

applicants’ information is to be vetted against a number of criminal and 

terrorist data sets to determine the extent to which applicants may 

present a risk to the security and safety of the United States. In addition, 

applicants’ information is to be vetted against CBP’s TECS to determine 

what, if any, border violations applicants may have committed in the past 

that could make them ineligible for participation in a trusted traveler 

program.5 Depending on the results of the vetting process, CBP is to 

conditionally approve or deny applications at the Vetting Center. For 

applications that are conditionally approved, CBP officers are to update 

CBP’s Global Enrollment System (GES),6 and applicants are to be 

notified to schedule an appointment for an interview at a trusted traveler 

enrollment center.7 Applicants whose applications are denied are to be 

notified via e-mail of the denial. Denied applicants can reapply for a 

trusted traveler program or request reconsideration of the denial to the 

trusted traveler Ombudsman.8

 5

TECS is designed to be a comprehensive enforcement and communications system that 

enables CBP and other agencies to create or access lookout data when (1) processing 

persons and vehicles entering the United States; (2) communicating with other computer 

systems, such as the Federal Bureau of Investigation’s National Crime Information Center; 

and (3) storing case data and other enforcement reports.

If an applicant’s reconsideration request is 

successful, his or her application can be “conditionally approved” and 

referred to the Vetting Center or an enrollment center and include 

additional information, such as an applicant’s request for reconsideration, 

for CBP officers to review. For additional information on the Ombudsman 

reconsideration process, see appendix I. Figure 1 depicts the enrollment 

process for CBP’s trusted traveler programs.

6

GES is used by CBP to collect and maintain records on individuals who voluntarily 

provide personally identifiable information for the purpose of enrolling in a trusted traveler

program that makes them eligible for expedited processing at designated U.S. POEs.

7

Trusted traveler applicants can schedule interviews at select enrollment centers; 

however, some enrollment centers interview applicants only for specific programs. For 

example, FAST enrollment centers typically do not conduct interviews for the other trusted 

traveler programs. In addition, SENTRI enrollment centers require a vehicle to be 

inspected and registered; therefore other trusted traveler enrollment centers cannot 

finalize the interview process because they do not conduct vehicle inspections. Enrollment 

centers are generally located at POEs that offer dedicated lanes for trusted travelers. 

8

The trusted traveler Ombudsman reviews cases where an individual has requested 

reconsideration of a CBP decision after his or her application was denied or membership 

was revoked.
Page 8 GAO-14-483 CBP Trusted Traveler Programs

Figure 1: U.S. Customs and Border Protection (CBP) Trusted Traveler Enrollment Process

The applicant-vetting process is similar for all four trusted traveler

programs; however, there are some differences in the programs’

enrollment processes. For example, according to CBP officials, SENTRI 

applicants from Mexico are required to provide a U.S. address and point 

of contact, while NEXUS applicants from Canada are not required to 

provide similar information. CBP officials stated that the requirements are 

different because, in part, NEXUS applicants from Canada are vetted by 

their home country and by the United States against a Canadian criminal 

database, while SENTRI applicants from Mexico are not vetted by their 

home country. According to CBP officials, Canada sends a “pass” or “fail”

notification to CBP following adjudication of an application. If Canada 

“fails” an application, the United States is to deny the application in all 

cases. If Canada “passes” an application, the United States is to continue 

the vetting process and rely on its own determination. These, among 

other differences, result in the collection of different data for various 

programs and, according to CBP officials, can have an impact on the 

amount of time and resources needed to vet individual applicants. More 

specifically, CBP officers at the Vetting Center told us that it may take 

more time to review the additional information—U.S. address and point of 

contact—that is required for SENTRI applicants. This information is used 

to help CBP determine and assess any potential relationships that could 

result in the applicant being considered a potential security risk.

In addition, CBP has differences in the rules that govern how CBP officers 

determine the eligibility of an applicant for each of the trusted traveler 

programs. For example, CBP uses a different standard when 
Page 9 GAO-14-483 CBP Trusted Traveler Programs

adjudicating—determining eligibility for—a FAST applicant than is used 

for the other programs.9 However, CBP officials noted that the 

commercial environment is different from the passenger environment. 

More specifically, CBP officials stated that in order to use trusted traveler 

benefits at a commercial POE, the shipper and carrier have to be 

Customs-Trade Partnership Against Terrorism (C-TPAT) approved in 

addition to the driver being a FAST member, a condition that provides an 

additional layer of security by helping to ensure the shipment is legitimate 

trade.10

Once an applicant is conditionally approved, the Vetting Center is to notify 

the applicant to schedule an interview at an enrollment center. Enrollment 

centers are located at POEs that have dedicated lanes for trusted 

travelers, airports with Global Entry kiosks, and other select locations.

In addition, there are other variations in the eligibility standards 

amongst the four programs. For example, a felony conviction disqualifies 

applicants from joining any of the four trusted traveler programs; however, 

applicants with misdemeanors may be considered for inclusion in some 

cases, depending on how recent the convictions were, the overall number 

of misdemeanor convictions, and the applicant’s nationality. For instance, 

according to CBP officials, FAST applicants may be allowed to enroll in 

the program with more than one misdemeanor conviction. In addition, 

CBP honors other countries’ and U.S. states’ determinations for what 

crimes constitute a felony, a misdemeanor, or an infraction. For example, 

a “driving under the influence” charge in one state may be considered an 

infraction, while in another state it may be considered a misdemeanor.

11

 9

CBP officials noted that they encountered a higher percentage of FAST applicants with 

criminal convictions and made the decision to modify the standards for FAST applicants to 

ensure that multiple misdemeanor convictions do not automatically result in the denial of 

an application. 

The interview process requires applicants to meet with a CBP officer at 

an enrollment center to confirm the accuracy and validity of the 

10C-TPAT is a voluntary program in which CBP officials work with private companies, 

referred to as partners, to review the security of their international supply chains and 

improve the security of their shipments to the United States. In return, C-TPAT partners 

receive various incentives to facilitate the flow of legitimate cargo, such as reduced 

scrutiny of their shipments. In October 2006, the Security and Accountability for Every Port 

Act of 2006 established a statutory framework for the C-TPAT program, codified its 

existing membership processes, and added new components—such as time frames for 

certifying, validating, and revalidating members’ security practices. 6 U.S.C. §§ 961-973.

11Most trusted traveler enrollment centers are located at a POE; however, CBP also has 

an enrollment center in Washington, D.C., and has also used mobile enrollment centers.
Page 10 GAO-14-483 CBP Trusted Traveler Programs

information they submitted in their GOES application, provide proof of a 

valid travel document that is compliant with the Western Hemisphere 

Travel Initiative (WHTI), submit biometric information to CBP, answer any 

questions from a CBP officer, and receive a briefing on the trusted 

traveler programs.12

Pending the results of the interview and fingerprint scan at the enrollment 

center, applicants are approved or denied. If they are approved, CBP is to 

mail applicants their WHTI-approved trusted traveler card. If denied, 

applicants have the option to reapply or request reconsideration of the 

decision through the trusted traveler Ombudsman office. The 

Ombudsman can uphold a denial or reverse the decision based on the 

review of an applicant’s reconsideration request so that the Vetting 

Center or enrollment center may consider new or additional information 

for additional consideration. Once approved, each trusted traveler is to be 

vetted daily through a “24-hour vetting” process. Under this process, a 

trusted traveler’s information is to be vetted against various databases, 

including TECS and terrorist data sets, on a daily basis to help ensure 

that trusted travelers remain low-risk travelers. The 24-hour vetting 

process that trusted travelers undergo provides an additional layer of 

screening that regular travelers are not subject to. If a trusted traveler is 

found to match information in one of the databases CBP screens against 

during the 24-hour vetting process, the Vetting Center is to review the 

case and make a determination as to whether the traveler should be 

allowed to remain in the trusted traveler program.

In addition, some NEXUS applicants also have to 

meet with a Canadian Border Services Agency (CBSA) official. During the 

interview with CBP, applicants are to submit a 10-finger fingerprint that is 

to be vetted against Federal Bureau of Investigation criminal records, 

which provide a response within minutes. In addition, applicants’ photos 

are to be taken. As with the vetting and adjudication processes, there are 

differences in the interview processes for each program. For example, 

SENTRI applicants who plan to drive across the border must register a 

vehicle and undergo a vehicle inspection during the interview.

 12WHTI implements a statutory mandate to require all travelers to present a passport or 

other document that denotes identity and citizenship when entering the United States. See 

Intelligence Reform and Terrorism Prevention Act of 2004, Pub. L. No. 108-458, § 7209, 

118. Stat. 3638, 3823, as amended. The goal of WHTI is to facilitate entry for U.S. citizens 

and legitimate foreign visitors while strengthening U.S. border security by providing 

standardized documentation that enables CBP to quickly and reliably identify a traveler. 

WHTI-approved documents include valid U.S. passports, passport cards, trusted traveler 

program cards, and others.
Page 11 GAO-14-483 CBP Trusted Traveler Programs

When entering the United States through a POE, regular travelers and 

trusted travelers are generally inspected by a CBP officer at a primary 

inspection booth.13 Following the primary inspection, travelers are either 

permitted to enter the country or referred for additional inspection. 

Trusted travelers are to receive expedited processing at POEs and use 

dedicated lanes at POEs. Trusted traveler POE locations that have 

dedicated lanes for SENTRI, NEXUS, Global Entry, and FAST are shown 

in figure 2. Of the 328 United States POEs, 65 have dedicated lanes or 

kiosks for trusted travelers. For a list of POEs with dedicated lanes or 

kiosks for trusted travelers, see appendix II.

 13 Primary inspection booths are where individuals present themselves for inspection to 

CBP officers for a preliminary screening procedure used to process those individuals who 

can be readily identified as admissible. Persons whose admissibility cannot be readily 

determined and persons selected as part of a random selection process are subjected to a 

more detailed review called a secondary inspection.

Trusted Travelers

at POEs
Page 12 GAO-14-483 CBP Trusted Traveler Programs

Figure 2: Trusted Traveler Ports of Entry (POEs) by Program

Typically, trusted travelers go through the same inspection process as a 

regular traveler; however, according to CBP officials, trusted travelers 

have radio-frequency-identification-enabled trusted traveler cards that are 

WHTI compliant and automatically populate a CBP officer’s computer 

system at the primary inspection booth. In addition, according to CBP 

guidance, any trusted traveler that is referred to secondary inspection—

when crossing the border—by the CBP officer at the primary inspection 

booth is to be given “front of line” privileges during his or her secondary 

inspection. Secondary inspections at land borders generally involve an 

additional interview with a CBP officer and, if a vehicle is involved, an 

inspection of the vehicle that can include the use of various inspection 

methods, such as X-rays and canine inspections. At an airport, secondary 
Page 13 GAO-14-483 CBP Trusted Traveler Programs

inspections can entail additional questioning by a CBP officer and the 

search of luggage and other items a traveler has with him or her. At 

commercial trucking POEs, secondary inspection can include referrals to 

have the truck and its cargo X-rayed, additional questioning, and removal 

and inspection of cargo.

CBP employs a technique called active lane management to help ensure 

that trusted travelers’ wait times remain lower than those of regular 

travelers at POEs. More specifically, according to CBP officials, active 

lane management is used to switch regular traffic lanes to trusted traveler 

lanes when wait times become too long for trusted travelers, or switch 

trusted traveler lanes back to regular lanes when the number of trusted 

travelers coming through the POE requires fewer lanes. CBP officials 

define wait time as the amount of time it takes a passenger or vehicle to 

reach the primary inspection booth at the POE from the back of the line. 

CBP defines inspection time as the amount of time it takes a CBP officer 

to inspect and release a passenger at the primary inspection booth.

In addition, at Global Entry POEs, trusted travelers scan their passports 

at a kiosk that allows them to progress past the primary inspection booth 

without being interviewed by a CBP officer. The kiosk requires travelers to 

submit their passports, answer a series of questions, have their photos 

taken, and submit their fingerprints to verify their identities. The answers 

to the questions and traveler’s photo are printed on a receipt. The kiosk 

also informs the travelers that they have been cleared to enter the country 

or refers them to secondary inspection. If cleared to enter the country, the 

trusted traveler has to show a CBP officer his or her passport and the 

receipt from the kiosk to ensure that the receipt is valid and matches the 

passenger. At this point, the passenger is allowed to enter the country. If 

a passenger is referred to secondary inspection, the receipt is to be 

issued with a large X on it.
Page 14 GAO-14-483 CBP Trusted Traveler Programs

As of January 2014, there were about 2.5 million people enrolled in CBP’s 

four trusted traveler programs, and the number of people enrolling in 

trusted traveler programs has more than quadrupled over the past 5 fiscal 

years.14 As shown in figure 3, the number of individuals enrolling in 

trusted traveler programs has increased from 209,117 in fiscal year 2009 

to 857,529 in fiscal year 2013. The growth in enrollments has been 

largely due to the growth of Global Entry enrollments. CBP officials told 

us that they believe that the February 2012 announcement that Global 

Entry members could receive the benefits of the Transportation Security 

Administration’s (TSA) Pre-Check Program, which provides for expedited 

screening at select TSA checkpoints, contributed to the increase in Global 

Entry applications. They explained that enrolling in a CBP trusted traveler 

program was one of the only ways an individual could obtain the PreCheck benefit from February 2012 through December 2013, since there 

was not a public application process for Pre-Check prior to December 

2013.15

 14Trusted traveler members include both U.S. citizens and citizens from other countries. 

See fig. 4 for additional information on the citizenship of trusted travelers. 

15We are currently reviewing TSA’s Pre-Check program and plan to issue a report on the 

subject later this year.

Enrollment in Trusted 

Traveler Programs 

Has Increased in the 

Past 5 Fiscal Years; 

Use Differs by 

Program and POE

Enrollment in Trusted 

Traveler Programs Has 

Increased, Largely 

because of Growth in 

Global Entry
Page 15 GAO-14-483 CBP Trusted Traveler Programs

Figure 3: Trusted Traveler Enrollments, Fiscal Years 2009 through 2013

Note: The number of enrollments includes approved first-time applications, renewal applications, and 

“reapplications”—the applications of individuals who applied one or more times previously. CBP 

officials noted that one person may apply to more than one trusted traveler program, so the number 

of approved applications exceeds the number of trusted travelers.

As of January 2014, most trusted travelers were enrolled in either Global 

Entry (about 43 percent of all trusted travelers) or NEXUS (about 38 

percent of all trusted travelers), as shown in figure 4. The citizenship of 

trusted travelers varied by program (also shown in fig. 4), with U.S. 

citizens and lawful permanent residents accounting for the largest share 

of Global Entry and SENTRI memberships, Canadian citizens accounting 

for the largest share of FAST North and NEXUS memberships, and 

Mexican citizens accounting for the largest share of FAST South 

memberships.
Page 16 GAO-14-483 CBP Trusted Traveler Programs

Figure 4: Trusted Traveler Membership by Program, as of January 2014

Note: Membership numbers are as of January 23, 2014. Percentages may not add to 100 because of 

rounding. The “other” citizenship category for FAST South, Global Entry, and SENTRI includes 

Canadian citizens, among others. The “other” citizenship category for FAST North and NEXUS 

includes Mexican citizens, among others. For all programs, the “other” citizenship category may 

include legal residents of Canada and Mexico who are not citizens of those countries.

CBP officials provided insights on this variation, stating that they have 

observed that many Canadian citizens live near the border and enroll in 

NEXUS because they enjoy the benefits of cross-border travel and 
Page 17 GAO-14-483 CBP Trusted Traveler Programs

commerce. They also explained that many Canadians enroll in NEXUS 

because membership makes them eligible for expedited screening for 

domestic Canadian flights as well as international flights entering Canada. 

In addition, they stated that many Mexican and U.S. citizens enroll in 

SENTRI because they commute across the border for work or to attend 

school. Further, they said that more Canadian and Mexican truck drivers 

have enrolled in FAST than have U.S. truck drivers because U.S. truck 

drivers have opportunities to drive domestic routes, which do not require 

drivers to cross the border. See appendix III for additional information on 

trusted traveler application denial rates and revocations from the 

programs.

The number of trusted traveler entries increased for all four trusted 

traveler programs, but the amount of the increase varied by trusted 

traveler program for fiscal years 2009 through 2013.16 Border-crossing 

locations with dedicated SENTRI lanes had the greatest increase in the 

total number of trusted traveler vehicles entering the United States, 

increasing from 5.9 million vehicles entering in fiscal year 2009 to 12.6 

million vehicles entering in fiscal year 2013. Border-crossing locations 

with dedicated NEXUS lanes, however, had the greatest growth in terms 

of percentage increase, with nearly two and a half times as many vehicles 

entering through dedicated NEXUS lanes in fiscal year 2013 compared 

with fiscal year 2009 (1.7 million entries in fiscal year 2009 compared with 

4 million entries in fiscal year 2013). Global Entry, the newest program, 

nearly doubled in use from fiscal year 2012 through fiscal year 2013 (1.1 

million entries through Global Entry kiosks in fiscal year 2012 compared 

with 1.9 million entries in fiscal year 2013).17

The percentage of entries into the United States that were trusted 

travelers also differed by program, but was less than 30 percent for all 

trusted traveler programs. For example, during fiscal year 2013, 3 percent 

 16The number of crossings for SENTRI, NEXUS, and FAST indicates the number of 

vehicles entering through those programs, regardless of the number of passengers in 

each vehicle, and does not include pedestrian entries. The number of crossings for Global 

Entry includes the number of individual people entering the United States through the 

program. For all four programs, individual travelers and vehicles are counted each time 

they entered the country, and therefore an individual traveler or vehicle could account for 

more than one crossing.

17Prior to fiscal year 2012, Global Entry was a pilot program. 

Use of Trusted Traveler 

Programs Has Increased, 

but Differs by Program

and POE
Page 18 GAO-14-483 CBP Trusted Traveler Programs

of all travelers that entered through airports that have Global Entry kiosks 

(1.9 million out of 77 million total entries) were trusted travelers, while 29 

percent of all vehicles entering the United States through crossings with 

SENTRI lanes (12.6 million of 42.9 million total vehicles entries at those 

crossings) were trusted traveler vehicles. According to CBP officials, 

SENTRI is the most heavily used trusted traveler program because many 

SENTRI members cross the southern border frequently, for example, if 

they live in Mexico but work or attend school in the United States. Figure 

5 shows the trends in trusted traveler entries and the percentage of all 

entries that were trusted traveler entries by program for fiscal years 2009 

through 2013.
Page 19 GAO-14-483 CBP Trusted Traveler Programs

Figure 5: Trends in the Use of Trusted Traveler Lanes and Kiosks, Including the 

Number of Entries and Percentage of Entries That Were Trusted Travelers, Fiscal 

Years 2009-2013

a

SENTRI data include only vehicle entries, and do not include travelers entering through pedestrian 

lanes.

b

NEXUS data include only NEXUS vehicle entries, and do not include travelers entering through 

NEXUS air crossings or pedestrians through NEXUS land crossings.

c

FAST data include entries through dedicated lanes. Drivers who participate in FAST can use their 

benefits for expedited processing at any crossing. 
Page 20 GAO-14-483 CBP Trusted Traveler Programs

d

Global Entry data include the 31 airports in the United States that have Global Entry kiosks available 

for passengers on inbound international flights. Certain airports in Canada and Ireland have global 

entry kiosks used by passengers on outbound flights for preclearance for entry into the United States. 

According to CBP officials, the Canadian preclearance kiosks are used primarily by NEXUS 

members.

Within each of the programs, the percentage of travelers entering through 

trusted traveler lanes varied by individual crossing as well. For example, 

the percentage of travelers with trusted traveler benefits at crossings with 

both SENTRI and regular lanes ranged from 0.1 percent to 40 percent in 

fiscal year 2013.18 For crossings with both NEXUS and regular lanes, the 

percentage of travelers with trusted traveler benefits ranged from 0.1 

percent at the crossing with the fewest trusted travelers to 34 percent at 

the crossing with the most trusted travelers in fiscal year 2013.19 For 

information on the number of trusted travelers entering the country at 

each crossing and the percentage of travelers who were trusted travelers 

in each year, see appendix IV.

CBP has reported in its trusted traveler guidance the importance of 

having a reasonable applicant-processing time, and the agency has taken 

steps to help realize this objective; however, CBP could strengthen three 

key areas to enhance the efficiency of the application process. These 

three areas include (1) lack of a performance target for how long it should 

take to vet an application, (2) limited interview appointment availability at 

 18One crossing along the southern border had only SENTRI lanes.

19One crossing along the northern border had only NEXUS lanes.

CBP Has Designed 

and Implemented 

Enrollment 

Processes, but 

Opportunities Exist to 

Enhance Efficiency 

and Consistency

CBP Could Strengthen 

Key Areas to Improve the 

Efficiency of the 

Application Process
Page 21 GAO-14-483 CBP Trusted Traveler Programs

NEXUS and SENTRI enrollment centers, and (3) lack of systematic data 

collection on interview appointment availability.

Lack of an application-vetting performance target: CBP did not have 

a performance target for completing application vetting, as of January 

2014. As shown in figure 6, the amount of time between when an initial 

trusted traveler application is submitted and when the Vetting Center has 

completed its vetting has varied by program and year, with some 

programs experiencing vetting times that are longer than others. Notably, 

the average vetting times for SENTRI applications increased to over 70 

days and NEXUS applications increased to about 42 days in fiscal year 

2012. In the first 9 months of fiscal year 2013, the vetting times for 

SENTRI and NEXUS applications decreased, but averaged from 25 

through 29 days, or about twice as long as Global Entry applications and 

three times as long as FAST applications.20

 20Fiscal year 2013 data are from October 2012 through June 2013.
Page 22 GAO-14-483 CBP Trusted Traveler Programs

Figure 6: Average Trusted Traveler Initial Application Vetting Time, Fiscal Years 2009-2013

Notes: The average annual vetting times are for initial applications in which the applicant did not 

provide information on a vehicle. We reviewed the average vetting times for applications in which the 

applicant provided information on a vehicle and found they were similar to those in this figure. 

Applications with information on a vehicle accounted for about 13.8 percent of initial applications from 

fiscal year 2009 through June 2013.

a

Fiscal year 2013 data are from October 2012 through June 2013.

In July 2007, CBP established a performance target of having all 

applications vetted by the CBP Vetting Center within 14 days of receipt. 

According to a July 2007 memorandum to OFO staff, CBP established 

this target of 14 days because it recognized the agency should have a 

plan in place to efficiently process applicants and ensure a reasonable 

applicant-processing time to meet the expected growth in demand for the 

trusted traveler programs. However, CBP officials told us that the agency 

no longer uses the 14-day performance target, as it is not a reasonable 
Page 23 GAO-14-483 CBP Trusted Traveler Programs

target given the current conditions of a high volume of applications and 

the backlog in interview appointment availability at enrollment centers, 

which we discuss in more detail later in this report. CBP officials also 

stated that the agency does not plan to establish a new performance 

target because it plans to adjust vetting times as needed to take account 

of current conditions.

While CBP plans to adjust vetting times as needed, without a 

performance target or targets for how long vetting should take, CBP is not 

well positioned to assess how any adjustments in vetting time affect 

application process times overall or assess progress made in reducing

vetting time frames against a target or baseline. Office of Management 

and Budget guidance states that performance measures should 

incorporate targets and time frames to help track a program’s progress 

toward reaching its outcome goals—in this case, for example, a 

reasonable applicant-processing time.21 In addition, Standards for Internal 

Control in the Federal Government states that managers should compare 

actual performance against a planned target and analyze significant 

differences and that performance measures should be monitored and 

reviewed to validate their propriety.22

Limited interview appointment availability: CBP’s Vetting Center has 

taken steps to improve the efficiency of the application-vetting process; 

however, officials in the Vetting Center told us that the limited interview 

appointment availability for SENTRI and NEXUS applicants has caused 

the Vetting Center to delay vetting of SENTRI and NEXUS applications.

Given changes in the numbers of 

applications for the different trusted traveler programs over time, setting a 

performance target for vetting the applications could help better position

CBP to assess its processes and timeliness in vetting applications and 

help make resource allocation decisions. Given the growth of the trusted 

traveler programs, establishing an updated vetting target and a process 

for modifying the target as needed, based on factors such as changes in 

the numbers of applications being filed for the different trusted traveler 

programs and available resources, consistent with internal control 

standards, could provide an accountability mechanism to help CBP 

ensure timely application vetting.

 21Office of Management and Budget, Performance Measurement Challenges and 

Strategies (Washington, D.C.: June 2003). 

22GAO/AIMD-00-21.3.1.
Page 24 GAO-14-483 CBP Trusted Traveler Programs

According to CBP officials, one factor that has affected the Vetting 

Center’s ability to complete vetting of trusted travelers in a timely manner 

is the growth in trusted traveler applications. The number of applications 

has more than tripled, from 233,833 in fiscal year 2009 to 895,830 in 

fiscal year 2013, while the number of CBP officers who vet applications 

on a full-time basis has slightly increased over that same time period.23

However, despite these productivity gains, the vetting time frames for 

SENTRI and NEXUS applications have remained relatively long in 

comparison with vetting time frames for FAST and Global Entry 

applications. CBP officials stated that the Vetting Center prioritizes Global 

Entry and FAST applications because of the high volume of Global Entry 

applications and the importance of FAST membership for trade. Further, 

Vetting Center officials said that they delay vetting SENTRI and NEXUS 

applications since they know that SENTRI and NEXUS applicants will not 

be able to be interviewed in a timely manner because of limited 

appointment availability at those enrollment centers. NEXUS and SENTRI 

interviews must be conducted at 1 of the 24 NEXUS enrollment centers or 

9 SENTRI enrollment centers because specific enrollment requirements 

of these programs can be performed only at these locations (i.e., NEXUS 

In 

fiscal year 2009, there was an average of 23.6 officers vetting 

applications, and in fiscal year 2013 there was an average of 30.0 

officers. Officials stated that the Vetting Center has taken a number of 

steps over the past 2 years to make the vetting process more efficient 

and productive. For example, CBP has automated immigration, criminal 

history, and other background checks and eliminated the need to run 

manual database queries, provided additional training that reduced the 

number of supervisor reviews of applications needed, and augmented the 

Vetting Center workforce by training CBP officers at 24 POEs to vet 

applications when local traffic allows. As a result of these efforts, Vetting 

Center officials reported that they have been able to increase the average 

number of applications vetted per day from 836.9 in fiscal year 2009 to 

3,345.1 in fiscal year 2013 and increase the average number of 

applications each officer vetted per hour from 13.3 in July 2012 to 15.1 in 

July 2013.

 23The number of applications includes first-time applications, renewal applications, and 

“reapplications”—applications from applicants who have applied for the program one or 

more times previously. In addition to its responsibility to vet these types of applications, 

the Vetting Center conducts ongoing vetting of current members and may also have to 

revet members when they update their personal information. 
Page 25 GAO-14-483 CBP Trusted Traveler Programs

applicants must be interviewed by a CBSA officer, and SENTRI 

applicants must have their cars inspected in order to drive the vehicles in 

the dedicated lanes). In contrast, Global Entry applicants can schedule an 

interview at any of the NEXUS and SENTRI enrollment centers or at 1 of 

the 40 Global Entry enrollment centers. Vetting Center officials explained 

that the vetting should occur close to the time of the interview so that the 

vetting results remain current when the enrollment center makes the final 

decision to approve or deny an application.24

In August 2013, there were nearly 33,000 trusted traveler applicants who 

had not scheduled an interview and another 90,000 applications that were 

pending vetting at that time. In an effort to streamline the enrollment 

process and help address this backlog, CBP issued a memorandum in 

August 2013 instructing enrollment centers to limit the interview to 15 

minutes.

CBP officials at the Vetting 

Center told us that as of November 2013, the Vetting Center was vetting 

SENTRI applications an average of 55 days after they were submitted 

and NEXUS applications an average of 40 days after they were 

submitted. In comparison, the officials said that Global Entry applications 

were vetted 6 days after they were submitted and FAST applications were 

vetted the same day they were submitted.

25

• Officials from one POE we visited recommended that CBP eliminate 

the vehicle examination from the SENTRI enrollment interview and 

instead inspect the vehicle one of the first few times it crosses the 

Prior to this memorandum, interviews were to be no longer 

than 20 minutes. In addition to this memorandum, CBP officials told us in 

January 2014 that they eliminated the need for renewal enrollment 

interviews for current trusted travelers who do not have any derogatory 

application-vetting results. However, CBP officials at the POEs we visited 

discussed additional practices they had implemented, or would like to 

implement, to further improve the efficiency of the interview process, and 

these officials noted that such practices could be helpful in improving the 

interview process at other POEs. For example:

 24CBP officials noted that applicants who have been conditionally approved by the Vetting 

Center but have not yet completed the enrollment interview are subject to 24-hour vetting.

25CBP officials stated that they observed many interviews and came to the conclusion that 

the interview process could be completed in a 15-minute time frame. 
Page 26 GAO-14-483 CBP Trusted Traveler Programs

border.26

• One enrollment center we visited conducted group briefings on the 

trusted traveler programs instead of having the CBP officer provide 

the briefing as part of the one-on-one interview. This allowed some of 

the CBP officers to start new interviews while another officer briefed 

all of the approved applicants.

This could reduce the interview time and also allow SENTRI 

applicants to schedule an interview at any of CBP’s enrollment 

centers.

• One enrollment center we visited conducted concurrent CBP-CBSA 

interviews for NEXUS applicants. According to officials, this reduced 

the overall interview time because both CBP and CBSA officers ask 

many of the same questions during the interviews, and by conducting 

the interview concurrently, the applicant does not have to repeat 

responses to the same questions.

Standards for program management call for program managers to assess 

programs on an ongoing basis—taking into account external factors that 

affect the program, such as growth and resources—to help ensure 

continued success.27

 26In February 2014, the DHS Office of the Inspector General recommended that CBP 

pursue eliminating the vehicle inspection during the initial SENTRI enrollment interview. 

See DHS Office of Inspector General, Ensuring the Integrity of CBP’s Secure Electronic 

Network for Travelers Rapid Inspection Program, OIG-14-32 (Washington, D.C.: February 

2014). In March 2014, CBP officials told us they were considering options to revise the 

SENTRI vehicle examination requirement in response to this recommendation. 

According to standards for program management, 

feasibility studies are one tool program managers can use to determine 

whether implementing program changes could help mitigate any negative 

impacts of external factors and achieve organizational goals. Assessing 

the feasibility could include assessing potential trade-offs, associated 

costs and benefits, and other factors influencing the ability of enrollment 

centers to implement additional practices to improve the efficiency of the 

interview process. CBP officials stated that the agency has continued to 

delay the vetting of SENTRI and NEXUS applications because of agency 

priorities and limited appointment availability at enrollment centers and 

has not assessed the feasibility of implementing additional practices to 

enhance efficiency, but recognized that there may be opportunities to do 

so. Given the backlog in enrollment interviews, conducting an 

assessment of the feasibility of practices implemented or suggested by 

27Project Management Institute, The Standard for Program Management©, Third Edition. 
Page 27 GAO-14-483 CBP Trusted Traveler Programs

CBP officials at the POEs we visited, as well as other methods for 

improving appointment availability, could better position CBP to determine 

what, if any, additional practices the agency could implement to expedite 

the interview process. Implementing feasible practices could also better 

position CBP to achieve its goal of ensuring a reasonable applicantprocessing time.

Lack of data on appointment availability over time: CBP monitors 

appointment availability at each of the enrollment centers on a daily basis, 

but it does not track appointment availability over time because its 

enrollment system does not currently have this functionality. As previously 

discussed, the amount of time it takes for applicants to schedule an 

interview has an impact on the overall time it takes for applicants to be 

enrolled in a trusted traveler program. CBP has established a target of 

having sufficient appointment availability so that every applicant has the 

potential to be interviewed within 30 days of being conditionally approved 

by the Vetting Center. However, because CBP does not track data on 

appointment availability over time, it was not able to provide data on the 

extent to which it has met this performance target over the past 5 fiscal 

years.

CBP’s daily reports showed that many enrollment centers did not have 

any available interview appointments in the next 30 days, and some did 

not have any appointments within the next 90 days. For example, CBP’s 

daily report from March 19, 2013, showed that 21 of the 65 enrollment 

centers where data were available (about 32 percent) did not have any 

interview appointments available in the next 30 days, and 99 percent of 

the interview appointments in that 30-day period were already booked at 

another 9 enrollment centers (about 14 percent).28

 28The daily report from March 19, 2013, lists 68 enrollment centers, but the data indicate 

that 3 of the enrollment centers were not scheduling interviews, so we omitted these from 

the total number of enrollment centers. Additional enrollment centers opened over the time 

period we reviewed for this report—fiscal year 2009 through January 2014—so the total 

number of enrollment centers will vary by date. 

On that same date, 11 

enrollment centers (about 17 percent) did not have any appointments 

available within the next 90 days, and another 2 enrollment centers had 

99 percent of their appointments in that 90-day period booked. At 1 

enrollment center, the next available appointment was over 5 months 

away.
Page 28 GAO-14-483 CBP Trusted Traveler Programs

A daily report from January 23, 2014, showed that there may have been 

some improvement in appointment availability; however, without data on 

appointment availability over time, CBP cannot determine if this is 

indicative of a trend or a temporary change in appointment availability. On 

January 23, 2014, 9 of the 79 enrollment centers where data were 

available (about 11 percent) did not have any appointments available in 

the next 30 days, and another 19 enrollment centers (about 24 percent) 

had 99 percent of their appointments booked in that 30-day period.29

Standards for Internal Control in the Federal Government calls for agency 

management to track and compare actual performance against goals.

According to available data, trusted traveler applicants could find it 

difficult to schedule an interview for the next month at roughly 35 percent 

of the trusted traveler enrollment centers. Also, on January 23, 2014, 3 

enrollment centers (about 4 percent) did not have any appointments 

available within the next 90 days, and another 9 enrollment centers 

(about 11 percent) had 99 percent of their appointments booked in that 

90-day period. According to available data, trusted traveler applicants 

could find it difficult to schedule an interview for the next 3 months at 

roughly 15 percent of the trusted traveler enrollment centers. Depending 

on where an applicant lives, the lack of appointment availability at specific 

enrollment centers could result in delaying enrollment for months. On 

both dates, at least half of the enrollment centers with limited appointment 

availability for the next 3 months were enrollment centers that process 

NEXUS applications.

30

Developing a mechanism to track interview appointment availability data 

over time—rather than on a daily basis—could help CBP determine the 

extent to which it is meeting its performance target and help it ensure it is 

taking necessary actions to provide applicants with timely interviews. 

Further, a mechanism to track appointment availability data could help 

CBP determine if the steps it has taken to improve the efficiency of the

interview process are effective.

 29The daily report from January 23, 2014, lists 83 enrollment centers, but the data indicate 

that 4 of the enrollment centers were not scheduling interviews, so we omitted these from 

the total number of enrollment centers. Additional enrollment centers opened over the time 

period we reviewed for this report—fiscal year 2009 through January 2014—so the total 

number of enrollment centers will vary by date. 

30GAO/AIMD-00-21.3.1. 
Page 29 GAO-14-483 CBP Trusted Traveler Programs

CBP has designed some processes for the trusted traveler applicant 

interview process to help ensure consistency across enrollment centers; 

however, we found variations in enrollment center interviews and 

application denial rates, indicating that interviews may not be conducted 

consistently across enrollment centers. During the enrollment center 

interview, CBP officers are to collect biometrics, verify documents, and 

ask applicants questions to help verify the information the applicant 

provided and determine if the applicant is admissible to the United States 

and is low risk, based on factors such as criminality and financial 

solvency, among others. If the Vetting Center has identified derogatory 

information, then the interviewing CBP officer generally is to ask the 

applicant to address the issue and then document how this issue was 

resolved. These processes, as well as a list of suggested interview 

questions, are documented in CBP’s Trusted Traveler Handbook. In 

addition, CBP provides supervisory review of aspects of the interview 

process conducted at enrollment centers. For example, CBP supervisors 

are to review all denied applications at enrollment centers, and CBP 

officials stated that CBP is to conduct a headquarters-level review of all 

approved applications with derogatory criminal background information. In 

addition, CBP operates a Self Inspection Program, in which POEs with 

enrollment centers are to review a sample of interviews to determine if a 

CBP officer interviewed all applicants, regardless of citizenship or 

residency; asked the relevant questions; resolved all issues identified by 

the Vetting Center; and verified the required documents.31

While these processes are designed to help CBP provide oversight of the 

interview process at its enrollment centers, we identified potential 

inconsistencies in enrollment centers’ interview processes. In particular, 

during our visits, we observed interviews that did not follow procedures 

laid out in the Trusted Traveler Handbook. For example, we observed 

interviews at 3 of the 12 enrollment centers we visited, and identified 

Further, the 

Self Inspection Program requires CBP managers to identify and 

implement corrective actions to address any deficiencies discovered 

during the assessment. According to CBP, the Self Inspection Program 

allows CBP leadership to measure the level of compliance with critical 

operational policies and procedures and examine the issues or underlying 

causes of noncompliance.

 31CBP’s Self Inspection Program covers operational requirements other than those of the 

trusted traveler programs. 

CBP Has Processes

for Applicant Interviews, 

but Could Better Ensure 

They Are Consistently 

Implemented at 

Enrollment Centers
Page 30 GAO-14-483 CBP Trusted Traveler Programs

deficiencies with the interviews at 2 of the 3 enrollment centers.32

Specifically, at 1 NEXUS enrollment center, the CBP officer did not ask 

any of the interview questions; instead, the applicant was interviewed by 

a CBSA officer, who is not responsible for establishing admissibility to the 

United States, and did not ask one of the CBP-suggested questions that 

are intended to help establish the applicant’s admissibility to the United 

States. At another enrollment center, a CBP officer approved an 

applicant’s enrollment even though the applicant did not have a valid 

travel document compliant with WHTI, one of the requirements for joining 

a trusted traveler program. We also reviewed locally developed interview 

question lists that were used to facilitate the trusted traveler enrollment 

interviews at 3 enrollment centers that had established such lists and 

found that they varied and that none of the 3 included all of the suggested 

interview questions in the Trusted Traveler Handbook, which are 

designed to help establish the applicant’s identity, admissibility, and risk 

level.33

Moreover, our analysis of trusted traveler enrollment data from fiscal 

years 2011 through 2013 indicates that the rate at which trusted traveler 

applications were denied varied across enrollment centers, as shown in 

Specifically, all three lists did not include suggested questions 

designed to help establish applicants’ criminal history, and two of the lists 

did not include suggested questions designed to help establish 

applicants’ financial solvency. CBP officials noted that while there is not a 

set list of mandatory questions CBP officers must ask during enrollment 

interviews, they should ask questions that would allow them to verify the 

person’s identity, admission classification, and risk level. The 

observations of enrollment interviews and review of locally developed 

interview question lists from select enrollment centers are not 

generalizable to all enrollment centers; however, they provided insights 

and raise questions about the consistency of the interview process across 

enrollment centers.

 32A CBP daily report from January 23, 2014, lists a total of 83 enrollment centers, but the 

data indicate that 4 of the enrollment centers were not scheduling interviews. 

33The other 9 enrollment centers we visited did not have locally developed trusted traveler 

interview question lists. 
Page 31 GAO-14-483 CBP Trusted Traveler Programs

figure 7.34

Figure 7: Range of Trusted Traveler Application Denial Rates at Enrollment Centers

Although differences in denial rates across enrollment centers 

cannot be directly attributed to differences in how centers conduct 

applicant interviews, data on denial rates can help provide insight into and 

across the operations of various enrollment centers.

 34We analyzed the denial rates at those enrollment centers that adjudicated 100 initial 

applications or more for a particular program in that fiscal year to facilitate comparison, 

since percentages for data from relatively small populations can change greatly with minor 

changes in the data. Our analysis covers fiscal years 2011 through 2013 because CBP 

officials noted that in fiscal year 2009 and part of fiscal year 2010, applications that were 

abandoned (i.e., the applicant did not schedule an interview or did not show up for the 

scheduled interview) were counted as denials. 
Page 32 GAO-14-483 CBP Trusted Traveler Programs

Note: The range of trusted traveler denial rates includes enrollment centers that adjudicated 100 

initial applications or more for that program in the fiscal year. The overall enrollment center denial rate 

was calculated by dividing the number of initial applications denied at all enrollment centers by the 

total number of initial applications adjudicated by enrollment centers.

Our analysis of trusted traveler enrollment data shows that the denial 

rates for FAST North, for example, varied significantly in fiscal year 2013, 

with 1 enrollment center denying about 16.9 percent of the 537 applicants 

interviewed at the center, while another enrollment center denied 0.9 

percent of the 235 applicants it interviewed. In some years, the denial 

rates for FAST South, Global Entry, NEXUS, and SENTRI applications 

also varied significantly. For example,

• the FAST South application denial rate ranged from 0.4 percent of the 

489 applications adjudicated at 1 enrollment center to 12.8 percent of 

the 257 applications adjudicated at another enrollment center in fiscal 

year 2012,

• the Global Entry application denial rate ranged from 0.1 percent of the 

2,767 applications adjudicated at 1 enrollment center to 5.6 percent of 

the 2,156 applications adjudicated at another enrollment center in 

fiscal year 2013,

• the NEXUS application denial rate ranged from 0 percent of the 148 

applications adjudicated at 1 enrollment center to 6.1 percent of the 

343 applications adjudicated at another enrollment center in fiscal 

year 2011, and

• the SENTRI application denial rate ranged from 0.2 percent of the 

1,639 applications adjudicated at 1 enrollment center to 13.6 percent 

of the 6,350 applications adjudicated at another enrollment center in 

fiscal year 2012.35

Furthermore, 7 enrollment centers had the highest or lowest denial rates 

in more than 1 fiscal year. For example, from fiscal years 2011 through 

2013,1 enrollment center consistently had the highest FAST South denial 

 35A statistical analysis we conducted found that these differences were significant, that is, 

there was less than a 0.001 percent chance that each of these differences was equal to 

zero. Specifically, we estimated t-statistics for the difference between each pair of denial 

rates, assuming unequal variances, and then calculated the associated two-tailed p-value. 

We limited our statistical analysis to the largest denial rate range for each program among 

enrollment centers with at least 100 applications.
Page 33 GAO-14-483 CBP Trusted Traveler Programs

rates, and 1 enrollment center consistently had the lowest FAST South 

denial rates. In addition, 1 enrollment center had the lowest NEXUS 

denial rates from fiscal years 2011 through 2013.

We recognize that differences in denial rates across enrollment centers 

can be attributable to various factors. For example, according to CBP 

officials, differences in the applicant populations that go to certain 

enrollment centers or differences in the experience levels of the CBP 

officers conducting interviews may have contributed to differences across 

enrollment centers. However, given that denials are based at least in part 

on interviews conducted at enrollment centers, the variation in denial 

rates could indicate that the interview process may result in different 

outcomes across enrollment centers.

While CBP has processes to help provide oversight of the interview 

process at enrollment centers, including supervisory reviews and a Self 

Inspection Program, CBP’s GES, the trusted traveler system of record, 

does not document the questions CBP officers ask or the applicants’

responses, hindering the level of oversight provided through CBP’s 

existing processes. For example, according to CBP officials, the 

headquarters-level review helps to ensure that the background checks for 

a select number of approved applicants did not find potentially 

disqualifying information, but it does not take into account admissibility 

issues or all risk factors discussed during the interview, as these may not 

be documented.36

 36CBP officials noted that most applicants are U.S. citizens and thus there would not be 

any admissibility concerns for these applicants. 

Similarly, since interview questions and responses are 

not documented, the supervisory review of denied applications does not 

provide supervisors with full information on the applicant or allow 

supervisors to help ensure that CBP officers are asking all relevant 

questions. Moreover, neither of these processes provides oversight over 

the majority of applications, which are approved and do not have the type 

of derogatory background investigation findings that would trigger a 

headquarters-level review. CBP’s internal inspection process requires a 

review of a random sampling of applications, which could help CBP 

monitor the implementation of the interview process across enrollment 

centers and potentially review both approved and denied applications. 

However, because GES does not document the questions CBP officers 

ask or the applicants’ responses to these questions, it would be difficult 
Page 34 GAO-14-483 CBP Trusted Traveler Programs

for CBP, as a part of its internal self-inspection, to determine whether the 

questions asked were sufficient to determine whether the applicant was 

low risk or whether the applicant’s responses support the final 

adjudication decision.

Standards for Internal Control in Federal Government calls for agencies 

to clearly document internal control transactions so that managers can 

examine and use the information to make decisions and monitor 

programs.37 CBP officials stated that they did not want to include a set list 

of questions in GES and require CBP officers to document responses to 

these questions because they want CBP officers to be able to cater the 

interview questions to the specific applicant. We recognize that there is 

value in allowing CBP officers to vary the questions they ask based on 

the applicant and that documenting all interview questions and responses 

could require use of more resources at enrollment centers. However, 

establishing a mechanism or mechanisms in GES so that CBP officers

could efficiently document the kinds of questions they asked and the 

nature of the applicants’ responses where appropriate, for example, by 

using check boxes to indicate which of a prepopulated set of questions 

and responses apply, could help minimize any resource impacts. 

Furthermore, such a mechanism or mechanisms could better position 

CBP to monitor the interview process through its other existing 

processes, such as the Self Inspection Program, to help ensure that 

interviews are being conducted consistently and in accordance with its 

policies at enrollment centers.

CBP has implemented bilateral arrangements with 9 countries, and DHS 

has signed bilateral arrangements with 3 additional countries that 

document the countries’ intent to explore implementing joint trusted 

traveler programs.38

 37

The bilateral arrangements allow foreign citizens 

from these respective countries to enroll in the Global Entry program and 

GAO/AIMD-00-21.3.1.

38The nine countries with operational joint trusted traveler programs with the United States 

as of March 2014 are Canada, Germany, Mexico, the Netherlands, Panama, Qatar, the 

Republic of Korea, Saudi Arabia, and the United Kingdom. DHS has signed joint 

statements with Australia, Israel, and New Zealand to explore implementing joint trusted 

traveler programs in the future. The bilateral arrangements are nonbinding and may be 

discontinued by either country, according to CBP.

CBP Could Better

Ensure That Foreign 

Adjudication Procedures 

Are Documented
Page 35 GAO-14-483 CBP Trusted Traveler Programs

enter the United States through expedited lanes at aviation POEs.39

The bilateral arrangements with 8 of the remaining 10 countries that do 

not have documented operational procedures state that CBP and the 

partner country plan to work together to develop and document 

operational procedures. As an example, the bilateral arrangement with 

one country that was signed by both countries in April 2011 states that 

“additional Initiative requirements and qualifications, procedures for 

communication and vetting, and other operational details concerning the 

implementation of the Initiative are expected to be set forth in a written 

joint operational program plan.” However, according to CBP officials, 

documenting foreign countries’ operational plans or procedures would be 

burdensome and would not add value, as these plans would not be 

legally binding. Further, officials stated that the language in the bilateral 

arrangements does not necessarily indicate a standard operating 

procedure would be documented.

CBP 

has documented operating procedures for vetting or sharing information 

on applicant-vetting results for 2 of these 12 countries and CBP officials 

have stated that the agency plans to add separate appendixes on each 

country when updating its Global Entry standard operating procedures. 

However, CBP officials told us that these appendixes will provide general 

statements about operating procedures, and as CBP is in the process of 

updating the standard operating procedures, it is too early to tell what 

information will be included in the country-specific appendixes.

However, CBP has recognized the importance of understanding the 

foreign countries’ procedures. CBP officials told us that during the 

meetings that lead up to the bilateral arrangements, DHS or CBP 

communicates the trusted traveler eligibility criteria and discusses the 

kinds of information that the other country is to review as part of its vetting 

process to help ensure that partner countries apply the same standards 

that the United States does when vetting applicants. Furthermore, after 

an arrangement is signed, CBP officials stated that there are numerous 

follow-up conversations between CBP and the foreign country to 

determine which individuals will be eligible to apply, how those 

applications will be submitted, and how a foreign country will 

communicate its vetting of applicants. CBP officials noted that because 

 39Canadian citizens may enroll in NEXUS and use the Global Entry kiosks when entering 

the United States through aviation POEs.
Page 36 GAO-14-483 CBP Trusted Traveler Programs

each country has different laws, databases, and resources, there are 

some differences in how the trusted traveler programs are implemented in 

each country. For example, CBP revets trusted travelers every 24 hours 

to help ensure their continued eligibility, while, according to CBP officials, 

other countries may choose to revet their citizens on an annual basis. 

Additionally, CBP stated that it holds regular meetings with partner 

countries to help ensure the integrity of the program and that operations 

are running appropriately. However, CBP has not documented the results 

of these discussions, and thus the knowledge of the other countries’

operational procedures is maintained by those CBP and DHS officials 

who participated in the meetings.

Standards for Internal Control in the Federal Government states that 

detailed and appropriate documentation is a key component of internal 

controls and allows stakeholders to make effective decisions about 

programs or operations.40 While CBP officials have stated that conducting 

additional meetings with each partner country to jointly develop bilateral 

operational plans and procedures is overly burdensome, CBP could 

document the operational procedures it has already discussed with each 

partner country in its planned update of the Global Entry standard 

operating procedures, or elsewhere. Such operational procedures may 

include the databases or types of information the foreign country will use 

to vet applicants, how often the foreign country will revet trusted travelers 

to ensure continued eligibility, and how information on applicants’ and 

trusted travelers’ eligibility will be shared, for example. Without such 

documentation, there is no institutional record that those countries’

procedures for vetting applicants help to ensure that only low-risk 

applicants are enrolled.

 40GAO/AIMD-00-21.3.1.
Page 37 GAO-14-483 CBP Trusted Traveler Programs

Trusted travelers generally experience shorter average wait times for 

primary inspections than regular traffic at crossings for all four trusted 

traveler programs.41 Our analysis of CBP data indicates that passenger 

vehicles crossing the southern border generally experience the greatest 

benefits from the trusted traveler programs; however, concerns about the 

reliability of wait time data prevented us from directly comparing average 

wait times from crossing to crossing.42 According to CBP officials, wait 

times are generally longer along the southern border than along the 

northern border. Our analysis of CBP wait time data showed that at 11 

out of 14 crossings with SENTRI lanes, regular traveler vehicles waited at 

least 15 minutes longer on average than trusted traveler vehicles in fiscal 

year 2013.43

 41CBP weights its calculations for average wait times at land borders using vehicle 

volumes in order to account for differences in traffic flow at different times of day and on

different days, according to CBP officials.

At 5 of those 11 crossings, vehicles in regular traffic lanes 

42We have previously reported that CBP wait time data are unreliable because CBP 

officers inconsistently implemented an approved data collection methodology, and the 

methodologies used vary by crossing. GAO, U.S.-Mexico Border: CBP Action Needed to 

Improve Wait Time Data and Measure Outcomes of Trade Facilitation Efforts, 

GAO-13-603 (Washington, D.C.: July 24, 2013). For this reason, we determined that we 

could not reliably compare specific wait times across crossings. At each individual 

crossing, however, CBP uses the same methodology to estimate average wait times for 

trusted and regular travelers. We are therefore reporting estimated differences in the 

average wait times for trusted and regular travelers at individual crossings. For more 

information about the reliability of CBP’s wait time data, see appendix V.

43At one of the other 3 crossings with SENTRI lanes, regular travelers waited less than 15 

minutes longer than trusted travelers on average. Another converted its SENTRI lanes to 

regular lanes in fiscal year 2012, and the third had only SENTRI lanes in fiscal year 2013.

CBP Moves Trusted 

Travelers through 

POEs More Quickly 

than Other Travelers, 

Allowing CBP to 

Focus Its Resources 

on Travelers It Knows 

Less About

Trusted Traveler Wait 

Times Are Shorter than 

Wait Times for Regular 

Travelers and Differ by 

Program and Port of Entry
Page 38 GAO-14-483 CBP Trusted Traveler Programs

waited at least 30 minutes longer on average than vehicles in trusted 

traveler lanes. The crossing with a SENTRI lane with the greatest 

difference in wait times had an estimated difference between the average 

trusted traveler wait time and the average regular traffic wait time of over 

1 hour.44 Along the northern land border, crossings with NEXUS lanes 

generally had more similar wait times for trusted and regular travelers.45

Specifically, our analysis of CBP wait time data showed that at 15 of 18 

crossings with NEXUS lanes, regular travelers waited less than 15 

minutes longer than trusted travelers on average in fiscal year 2013.46

Among commercial traffic, our analysis of CBP data showed FAST 

participants generally experienced slightly shorter wait times than regular 

traffic on average. FAST participants spent less time waiting on average 

than regular commercial traffic at 12 of 15 crossings with FAST lanes in 

fiscal year 2013; however, this difference was less than 15 minutes on 

average at all but one of these crossings. For the other 3 crossings with 

FAST lanes, the average wait time for FAST lanes was between about 30 

seconds and 8 minutes longer than for regular lanes. Some crossings 

with FAST lanes report longer estimated average wait times for FAST 

traffic because of the high number of program members and factors 

unique to specific crossings. For example, during our visit to one FAST 

North crossing, CBP officials told us that they had a pilot project in which 

Canada was prescreening FAST trucks, which was causing delays in the 

FAST lane. In addition, according to CBP officials, infrastructure 

Trusted travelers also experienced somewhat shorter wait times in 

airports on average. Our analysis of CBP wait time data showed that 

regular travelers waited an estimated 10 to 27 minutes longer on average 

than trusted travelers at the 31 airports in the United States with Global 

Entry kiosks in fiscal year 2013.

 44Pedestrian crossers of the northern and southern land borders are eligible for NEXUS 

and SENTRI, but as the majority of users of these programs are drivers and vehicle 

passengers, we are limiting this analysis to vehicle traffic across the borders.

45The differences in wait times are based on the reported average wait times for all 

regular travelers and for trusted travelers from the point at which they are able to enter 

dedicated lanes. According to CBP officials, at some POEs, particularly along the northern 

border, infrastructure constraints such as bridges cause trusted travelers to wait with 

regular travelers until they are able to reach dedicated lanes.

46At 2 of the other northern border crossings with NEXUS lanes, regular travelers waited 

an estimated 16 minutes longer than regular travelers on average. The third had only 

NEXUS lanes.
Page 39 GAO-14-483 CBP Trusted Traveler Programs

constraints at certain POEs can lead to increased wait times for FAST 

members. For example, at some POEs, the dedicated FAST lanes are 

separated by barriers from regular lanes, and drivers must commit to 

either FAST lanes or regular lanes before they can see which set of lanes 

has a shorter queue. CBP officials told us that most of the benefits 

derived from being a FAST member are realized during the secondary 

inspection process, which provides FAST members “front of line”

privileges when referred for additional inspection.

Figure 8 shows our analysis of the number of crossings by program with 

different categories of wait time differences for trusted and regular 

travelers in fiscal year 2013.

Figure 8: Number of Border Crossings with Differences in Wait Times for Trusted 

and Regular Travelers by Program, Fiscal Year 2013

a

At 3 FAST crossings, trusted travelers waited longer on average than regular travelers.

b

One NEXUS crossing has only trusted traveler lanes, and is therefore not included in the figure.

c

One SENTRI crossing had only regular lanes in fiscal year 2013 and another had only trusted 

traveler lanes. These 2 crossings are not included in the figure.
Page 40 GAO-14-483 CBP Trusted Traveler Programs

CBP manages lanes operating as dedicated lanes at land crossings with 

trusted traveler lanes in order to keep trusted traveler wait times as low as 

possible. At airports, trusted travelers undergo primary inspection through 

kiosks rather than with a CBP officer. CBP officials told us that they can 

use wait times for Global Entry kiosks to help them prioritize decisions as 

to where they should deploy additional Global Entry kiosks.

According to CBP officials, CBP has a goal of keeping trusted traveler 

wait times to less than 15 minutes at crossings with SENTRI or NEXUS 

lanes, and uses active lane management to switch regular traffic lanes to 

trusted traveler lanes when wait times become too long for trusted 

travelers. Infrastructure variations at some POEs, however, limit CBP’s 

ability to reduce wait times for trusted travelers because passenger and 

commercial trusted traveler vehicles may have to wait in regular traffic 

lanes before they are able to access dedicated lanes. For example, 

according to CBP officials, at one northern border vehicle crossing, 

NEXUS members are not able to enter NEXUS lanes until after a choke 

point, and if the regular traffic line is backed up past that choke point, 

NEXUS members have to wait with the regular traffic until they are able to 

access the NEXUS lanes. Commercial traffic faces the same types of 

infrastructure variations. At one northern vehicle crossing, FAST 

members have to wait with regular passenger traffic until they are able to

access the FAST lanes. CBP has undertaken efforts to expand 

infrastructure at specific POEs in an effort to mitigate these concerns. For 

example, CBP began expanding the San Ysidro, California, POE, which 

is the busiest passenger POE in the nation.

Figure 9 shows the choke point at the Detroit POE, where trusted traveler 

traffic, including NEXUS and FAST traffic, may have to wait with regular 

traffic before being allowed to access the NEXUS and FAST lanes.
Page 41 GAO-14-483 CBP Trusted Traveler Programs

Figure 9: Detroit Port of Entry Choke Point at Which Trusted Traveler Traffic May Wait with Regular Traffic
Page 42 GAO-14-483 CBP Trusted Traveler Programs

Inspections of trusted travelers at the primary inspection booths are 

generally shorter than inspections of regular travelers, and according to 

the Trusted Traveler Handbook, the average primary inspection per 

passenger vehicle in dedicated lanes should not exceed 30 seconds per 

vehicle. Our analysis of CBP data showed that CBP met this goal at 12 of 

14 crossings with SENTRI lanes and 12 of 18 crossings with NEXUS 

lanes in fiscal year 2013.47 In regular traffic lanes, the average inspection 

time was longer. Our analysis of CBP data showed that primary 

inspections took about twice as long or longer on average for regular 

travelers than for trusted travelers at 11 of 14 crossings with SENTRI 

lanes and 11 of 18 crossings with NEXUS lanes in fiscal year 2013.48

 47One of the other crossings with a SENTRI lane converted its SENTRI lane to a regular 

lane in fiscal year 2012 and therefore did not have SENTRI inspections in fiscal year 

2013. For the other, which first opened its trusted traveler lanes in 2013, the average 

inspection time was 47 seconds. Inspection times at the other 6 crossings with NEXUS 

lanes ranged from 31 seconds to 66 seconds on average in fiscal year 2013. 

On

average, CBP officers spent up to five times as long inspecting regular 

travelers at crossings with SENTRI lanes and up to three times as long 

inspecting regular travelers at crossings with NEXUS lanes. These 

inspection times ranged from 48 seconds to 97 seconds at crossings with 

SENTRI lanes and 23 seconds to 64 seconds at crossings with NEXUS 

lanes in that same year, according to CBP data. Trusted travelers are 

prescreened against multiple databases as part of their enrollment in the 

program; therefore, according to CBP officials, the agency can inspect 

them more efficiently at crossings, which allows CBP officers to focus 

more resources on travelers they know less about. For example, at the 

busiest crossing with SENTRI lanes, the average inspection time was 25 

seconds for trusted travelers and 68 seconds for regular travelers in fiscal 

year 2013. At that crossing, a single CBP officer could inspect up to 53 

regular vehicles in 1 hour; however, that same CBP officer could inspect 

up to 144 SENTRI vehicles in the same amount of time. According to 

CBP officials, prioritizing resources is one of the goals of the trusted 

traveler program. According to CBP data, the four trusted traveler 

48CBP defines inspection time as the time a traveler spends with a CBP officer. Because 

Global Entry primary screening is conducted through kiosks, CBP does not calculate an 

average inspection time for Global Entry primary screenings. At the 3 other crossings with 

SENTRI lanes, 2 had either only trusted or only regular traveler lanes, and at the other, 

the average inspection time was nearly the same for trusted and regular travelers. At the 

other 7 crossings with NEXUS lanes, 5 had slightly longer average inspection times for 

regular travelers, which ranged from 9 to 16 seconds longer than the average inspection 

times for trusted travelers, 1 had a longer inspection time for trusted travelers, and the last 

had only NEXUS lanes and therefore did not report inspection times for regular traffic. 

Trusted Travelers Are 

Inspected More Quickly 

and Commit Fewer 

Violations than Regular 

Travelers, Allowing CBP to 

Focus Its Resources on 

Other Travelers
Page 43 GAO-14-483 CBP Trusted Traveler Programs

programs saved over 270,000 CBP officer hours at primary inspection 

booths at POEs in fiscal year 2013. According to CBP data, this savings 

in CBP officer time equates to approximately $15.5 million in avoided 

costs.

In addition to determining that trusted travelers take less time to inspect 

than regular travelers, our analysis of CBP data indicates that trusted 

travelers commit fewer border violations, such as smuggling, than regular 

travelers. Our analysis of CBP data shows that the majority of violations 

result from CBP seizing illegal goods such as drugs, excess currency, or 

undeclared merchandise; however, some violations result from 

nonseizure arrests such as if a person with a warrant for a non-borderrelated crime attempts to enter the country. CBP identifies violations after 

sending travelers from primary inspection to secondary inspection, either 

randomly or based on the suspicion of the CBP officer at the primary 

inspection booth. CBP uses algorithms to determine which travelers are 

randomly sent for secondary inspection, as well as changing criteria that 

are used to randomly select travelers for secondary inspections. For 

example, CBP can target vehicles or travelers based on specific 

categories or criteria, such as age, that are then relayed to CBP officers 

at the primary inspection booths with little to no notice. CBP officers can 

also use their professional discretion to refer any travelers to secondary 

inspection that they may deem to be potential risks. Both trusted and 

regular travelers are subject to secondary inspection based on suspicion 

and random referral, and CBP calculated the rate at which travelers 

commit violations by calculating the percentage of people who are sent to 

secondary inspection that are found to have committed violations. Our 

analysis of CBP data indicates that trusted travelers commit violations at 

a lower rate than general travelers, and while these rates are not directly 

comparable because of differences in the secondary referral processes 

for trusted and regular travelers, the variation in the rates is notable. 

Specifically, our analysis of CBP data showed that of those travelers sent 

for secondary inspection, approximately 1 out of every 140 regular 

travelers was found to have committed a violation; whereas less than 1 

out of every 3,000 trusted travelers was found to have committed a 

violation in fiscal year 2013.

Trusted travelers at land POEs had been randomly referred to secondary 

inspection at a higher rate than regular travelers, according to CBP 

officials; however, CBP took steps in 2013 to reduce the likelihood of 

trusted travelers at land POEs being referred to secondary inspection 

more often than regular travelers. The random referral rate of trusted 

travelers is based on a set of rules specific to trusted travelers that targets 
Page 44 GAO-14-483 CBP Trusted Traveler Programs

both individuals and vehicles. For regular travelers, CBP uses a program 

called Compliance Examination (COMPEX), which randomly selects 

regular travelers entering the country for more detailed inspections. CBP 

officers at land POEs we visited told us that their POEs used both the 

trusted traveler random referral system and COMPEX in lanes dedicated 

for SENTRI or NEXUS. CBP officials told us that they have adjusted this 

and now use COMPEX only in the regular traveler lanes. The removal of 

COMPEX in trusted traveler lanes at land POEs should reduce the rate at 

which trusted travelers entering the country through a dedicated trusted 

traveler lane are referred to secondary inspection. However, CBP officers 

at two POEs we visited along the southern border (San Ysidro and Otay 

Mesa) told us that most trusted travelers who are sent to secondary 

inspection spend less time getting through the port than a regular traveler 

using a regular lane who is not referred to secondary inspection.

When travelers, including trusted travelers, are caught committing 

violations, CBP has a goal to prosecute offenders to the full extent of the 

law. For all instances of participants caught smuggling in dedicated lanes, 

CBP disseminates a press release, unless doing so would compromise 

an ongoing investigation. For example, on January 22, 2014, CBP issued 

a press release regarding a trusted traveler who had failed to truthfully 

declare approximately $6,000 worth of merchandise, and was assessed a 

$6,000 penalty. According to the Trusted Traveler Handbook, CBP is to 

inform applicants of the consequences of a border violation by a trusted 

traveler during his or her enrollment. CBP officials noted that the potential 

loss of the benefit is one of the most effective deterrents to such activity. 

CBP identifies trusted traveler border violations during the daily vetting 

process and uses this information to determine whether a trusted traveler 

should be allowed to remain in the program or whether the traveler should 

have the benefit revoked.

Trusted traveler programs are a key component of CBP’s risk-based 

approach to facilitate travel and trade coming through U.S. POEs while 

keeping out terrorists and their weapons and enforcing U.S. laws and 

regulations, including those that prevent the illegal entry of persons and 

contraband. According to CBP, its trusted traveler programs help it 

achieve this dual mission by allowing it to focus resources at the POEs on 

passengers and cargo that have not been identified as low risk. CBP has 

recognized the importance of processing trusted traveler applications in a 

reasonable time frame and has taken some steps to help improve the 

efficiency of the enrollment process. CBP could better ensure the 

timeliness of its enrollment process by establishing an updated 

Conclusions
Page 45 GAO-14-483 CBP Trusted Traveler Programs

performance target for vetting applications and a process to modify the 

target as needed based on factors such as application volume and 

resources, assessing the feasibility of practices to expedite the interview 

process and implementing feasible practices, and developing a 

mechanism to track interview appointment availability data over time. 

Further, the success of the trusted traveler programs is predicated on 

enrolling low-risk travelers, allowing CBP to focus its resources on 

travelers it knows less about. CBP has established processes to interview 

applicants; however, establishing mechanisms for CBP officers to 

efficiently document the types of questions they asked and the nature of 

applicants’ responses, when appropriate, in GES could allow CBP to 

better monitor the interview process through its other existing processes, 

such as the Self Inspection Program. This could help ensure that the 

interview process is being conducted consistently and in accordance with 

CBP policies across enrollment centers. Furthermore, without 

documentation on all partner countries’ vetting procedures—such as the 

databases or types of information the foreign country will use to vet 

applicants, how often the foreign country will revet trusted travelers, and 

how information on applicants’ and trusted travelers’ eligibility will be 

shared—there is no institutional record that those countries’ procedures 

for vetting applicants help to ensure that only low-risk applicants are 

enrolled.

To help assess and improve the timeliness of the trusted traveler 

application adjudication process, we recommend that the Commissioner 

of CBP take the following three actions:

• establish an updated performance target for completing application 

vetting and a process to modify that target, as needed, based on 

factors such as changes in the number of trusted traveler program 

applications and available resources;

• assess the feasibility of practices to expedite the interview process, 

which could include assessing the potential trade-offs, costs, and 

benefits associated with any proposed practices, such as those 

currently proposed or implemented at specific enrollment centers, and 

implement those practices CBP determines to be feasible; and

• develop a mechanism to track enrollment interview appointment 

availability data over time.

To better ensure that the trusted traveler eligibility criteria and applicant 

adjudication processes are consistently implemented in accordance with 

Recommendations for 

Executive Action
Page 46 GAO-14-483 CBP Trusted Traveler Programs

CBP policy at all enrollment centers and by partner countries, we 

recommend that the Commissioner of CBP take the following two actions:

• establish a mechanism or mechanisms in GES to allow CBP officers 

to efficiently document the types of interview questions asked and the 

nature of applicant responses, when appropriate, and then use this 

information to monitor the implementation of the interview process, 

and

• document information CBP has obtained on the operational 

procedures, such as those used to vet and share information on 

applicants, of foreign countries that have signed bilateral 

arrangements with the United States to participate in trusted traveler 

programs.

We provided a draft of this report to DHS for review and comment. DHS 

provided written comments, which are summarized below and reproduced 

in full in appendix VI, and technical comments, which we incorporated as 

appropriate. DHS concurred with four of the five recommendations in the 

report and described actions underway or planned to address them. DHS 

did not concur with one recommendation in the report.

With regard to the first recommendation, that CBP establish an updated 

performance target for completing application vetting, DHS concurred and 

stated that CBP OFO will work with the trusted traveler Vetting Center to 

establish an updated performance target, identify factors that may impact 

the target, and identify the process to modify the target based on these 

factors. DHS stated that its initial assessment is to be completed by 

August 2014 and provided a final completion date of October 2014. 

These planned actions, if fully implemented, should address the intent of 

the recommendation.

With regard to the second recommendation, that CBP assess the 

feasibility of practices to expedite the interview process and implement 

those practices CBP determines to be feasible, DHS concurred and 

stated that CBP OFO plans to conduct site visits at 5 to 10 enrollment 

centers to identify best practices, test and evaluate those practices in 

other enrollment centers, and then implement relevant practices at other 

enrollment centers, as appropriate. DHS provided an estimated 

completion date of November 2014. These planned actions, if fully 

implemented, should address the intent of the recommendation.

Agency Comments 

and Our Evaluation
Page 47 GAO-14-483 CBP Trusted Traveler Programs

With regard to the third recommendation, that CBP develop a mechanism 

to track enrollment interview appointment data availability over time, DHS 

concurred and stated that by August 2014, CBP OFO will determine the 

modifications that would need to be made to GOES to implement this 

recommendation. DHS stated that subsequent milestones for

implementation and completion dates will be finalized, as appropriate, 

with a final estimated completion date of December 2014. If fully 

implemented, these actions should address the intent of the 

recommendation.

With regard to the fourth recommendation, that CBP establish a

mechanism in GES to allow CBP officers to efficiently document the types 

of interview questions asked and the nature of applicant responses, when 

appropriate, and use this information to monitor the implementation of the 

interview process, DHS did not concur. DHS stated that the interview 

process for trusted traveler programs is equivalent to a border crossing 

inspection. During the interview, as well as an inspection, DHS stated that 

CBP officers must make a determination of an applicant’s identity, 

nationality, and admissibility. DHS stated that the burden of proof is on 

the applicant to establish that he or she is not inadmissible to the United 

States, and the criterion at the end of the interaction is that the applicant 

has overcome the burden of proof and the CBP officer is satisfied that the 

applicant is admissible. Further, DHS stated that there are no scripted 

questions that must be asked and that when a CBP officer approves an 

applicant, it is implicit that the officer was satisfied as to the identity, 

nationality, and admissibility of the applicant. DHS also stated that 

creating a measure for this process would force a line of questioning and 

additional steps that may not be relevant for most applicants and the 

additional step to “capture” this information would add to the time required 

to complete the interview. DHS noted that questions and answers relating 

to the risk and eligibility of a trusted traveler, beyond those in the 

inspection process, can already be documented in the comments section 

of GES.

We continue to believe that CBP should establish a mechanism in GES to 

allow CBP officers to efficiently document the types of interview questions 

asked and the nature of applicant responses, when appropriate, and use 

this information to monitor the implementation of the interview process. 

The intent of the trusted traveler programs is to provide expedited travel 

for preapproved, low risk travelers through dedicated lanes and kiosks. 

Through the application vetting and interview process, CBP officers are to 

ensure that the applicants are low-risk, in addition to making a 

determination about an applicant’s identity, nationality, and admissibility. 
Page 48 GAO-14-483 CBP Trusted Traveler Programs

As noted in the report, we identified potential inconsistencies in 

enrollment centers’ interview processes, including instances where CBP 

officers did not follow procedures laid out in the Trusted Traveler 

Handbook. For example, we observed interviews at 3 of the 12 enrollment 

centers we visited, and identified deficiencies with the interviews at 2 of 

the 3 enrollment centers. Specifically, we observed one interview where a 

CBP officer did not ask any of the interview questions suggested in the 

Trusted Traveler Handbook; rather, the applicant was interviewed 

separately by a CBSA officer who was not responsible for establishing an 

applicant’s admissibility to the United States. We also found that 3

enrollment centers had established lists of questions that were used by 

CBP officers at those centers during the interview process and that the 

three interview question lists were different and that none of the three 

included all of the suggested interview questions in the Trusted Traveler 

Handbook, which are designed to help establish the applicant’s identity, 

admissibility, and risk level. In addition, we found significant variation in 

denial rates across enrollment centers. As noted in our report, while 

differences in denial rates across enrollment centers can be attributable 

to various factors, given that denials are based at least in part on 

interviews conducted at enrollment centers, the variation in denial rates 

could indicate that the interview process may result in different outcomes 

across enrollment centers.

Further, this recommendation is not intended to imply that CBP should 

develop a set of scripted questions for trusted traveler program interviews 

or add more time to the interview process. Rather, as stated in the report, 

we recognize that there is value in allowing CBP officers to vary the 

questions they ask based on the applicant and that documenting all 

interview questions and responses could require use of more resources 

at enrollment centers. However, as we stated in the report, we believe 

that establishing a mechanism or mechanisms in GES so that CBP 

officers could efficiently document the kinds of questions they asked and 

the nature of the applicants’ responses where appropriate, could help 

minimize any resource impacts. CBP officers are not required to use the 

comments sections in GES to consistently record the types of questions 

asked and the nature of applicant responses in those comments. Further, 

allowing comments to be entered into GES does not place a control over 

the interview process to ensure that CBP officers are asking questions 

pertaining to an applicant’s identity, nationality, and admissibility, and to 

ensure the applicant’s low-risk status. CBP could accomplish this by, for 

example, using check boxes to indicate which of a prepopulated set of 

questions and responses apply, as we noted in the report. Moreover, a 

mechanism or mechanisms to efficiently document the kinds of questions 
Page 49 GAO-14-483 CBP Trusted Traveler Programs

asked and the nature of responses could better position CBP to monitor 

the interview process through its other existing processes, such as the 

Self Inspection Program, to help ensure that interviews are being 

conducted consistently and in accordance with its policies at enrollment 

centers. For example, CBP’s Self Inspection Program requires POEs with 

enrollment centers to report whether a CBP officer “asked the mandatory 

questions” during the interview process. However, as noted in the report, 

because GES does not document the questions CBP officers ask or the 

applicants’ responses to these questions, it would be difficult for CBP, as 

a part of its internal self-inspection, to determine whether the questions 

asked were sufficient to determine whether the applicant was low risk or 

whether the applicant’s responses support the final adjudication decision. 

When appropriate, documenting the types of questions—for example, 

pertaining to the applicant’s identity, nationality, admissibility, and risk 

factors—that were asked during the interview and the nature of applicant 

responses—for example, confirmation that the identity, nationality, 

admissibility, and low-risk status were verified by the CBP officer—could 

help provide CBP with assurances that CBP officers are following the 

procedures and guidelines laid out in the Trusted Traveler Handbook. 

Thus, we continue to believe that this recommendation is valid and CBP 

should take action to fully implement it.

With regard to the fifth recommendation, that CBP document information 

CBP has obtained on the operational procedures, such as those used to 

vet and share information on applicants, of foreign countries that have 

signed bilateral agreements with the United States to participate in trusted 

traveler programs, DHS concurred. DHS stated that CBP OFO has 

drafted an update to the Global Entry Standard Operating Procedure that 

is currently under review and is expected to address the operational 

procedures of foreign countries that have signed bilateral arrangements 

with the United States. DHS stated that the estimated completion date is 

August 2014. This planned action should address the intent of the 

recommendation.

We are sending copies of this report to the Secretary of Homeland 

Security and interested congressional committees and members. The 

report also is available at no charge on the GAO website at 

http://www.gao.gov. 

If you or your staff have any questions, please contact me at (202) 512-

8777 or gamblerr@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 
Page 50 GAO-14-483 CBP Trusted Traveler Programs

of this report. GAO staff who made significant contributions to this report 

are listed in appendix VII.

Rebecca Gambler

Director, Homeland Security and Justice
Page 51 GAO-14-483 CBP Trusted Traveler Programs

List of Requesters

The Honorable Tom Coburn

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Michael McCaul

Chairman

Committee on Homeland Security

House of Representatives

The Honorable Candice Miller

Chairman

Subcommittee on Border and Maritime Security

Committee on Homeland Security

House of Representatives

The Honorable Jeff Duncan

Chairman

Subcommittee on Oversight and Management Efficiency

Committee on Homeland Security

House of Representatives

The Honorable Sheila Jackson Lee

Ranking Member

Subcommittee on Border and Maritime Security

Committee on Homeland Security

House of Representatives

The Honorable Bill Keating

House of Representatives

The Honorable Henry Cuellar

House of Representatives
Appendix I: Ombudsman Reconsideration 

Process

Page 52 GAO-14-483 CBP Trusted Traveler Programs

Individuals that are denied enrollment in a trusted traveler program or 

revoked from a program have the option to request reconsideration of the 

decision through the trusted traveler Ombudsman office. The 

Ombudsman may consider additional information and can uphold a denial 

or revocation or reverse the decision. From fiscal year 2009 through 

2013, the Ombudsman reviewed 24,363 cases and overturned denials or 

revocations in approximately 43 percent of the cases. As shown in figure 

10, the number of cases the Ombudsman reviewed nearly tripled from 

2,596 in fiscal year 2009 to 7,449 in fiscal year 2013.

Figure 10: Reconsideration Cases Reviewed by the Ombudsman, Fiscal Years 2009-

2013

The Ombudsman told us that the significant increase in the number of 

reconsideration requests and cumbersome manual processes contribute 

to delays in completing reconsideration cases. At the time of our visit to 

the Ombudsman in November 2013, applicants that requested 

reconsideration of a denial or revocation from a trusted traveler program 

had to wait about 5 months to learn the outcome of the Ombudsman 

review. The Ombudsman’s office has limited staff who must review every 

case using manual processes that, according to the Ombudsman, add an 

additional 1 to 5 days to the review time for each case. For example, at 

the time of our visit in November 2013, when reviewing a case, the 

Appendix I: Ombudsman Reconsideration 

Process
Appendix I: Ombudsman Reconsideration 

Process

Page 53 GAO-14-483 CBP Trusted Traveler Programs

Ombudsman could not document decisions to overturn a denial or 

revocation directly in the Global Enrollment System (GES)—the trusted 

travel program’s system of record. Instead the Ombudsman sent daily 

lists of overturned revocations and denials to two different U.S. Customs 

and Border Protection (CBP) headquarters units for them to unlock these 

applicants’ GES records so that the Ombudsman could later document 

the outcome of the review and conditionally approve or reinstate the 

person in GES.

The Department of Homeland Security’s (DHS) Office of Inspector 

General recognized the inefficiencies with the Ombudsman review 

process and in February 2014 recommended that CBP automate the 

process and provide adequate staffing to enhance efficiency and 

effectiveness.1

 1

DHS Office of Inspector General, Ensuring the Integrity of CBP’s Secure Electronic 

Network for Travelers Rapid Inspection Program, OIG-14-32 (Washington, D.C.: February 

2014).

CBP concurred with the Inspector General’s 

recommendations and stated that the agency plans to determine the 

scope and timeline for automating the Ombudsman review process by 

July 2014. CBP officials told us that they have modified GES to allow the 

Ombudsman to directly reinstate those who have been revoked within the 

past year and are considering different options to allow the Ombudsman 

to document reviews of denials directly in the system. In addition, in 

March 2014, CBP officials stated they plan to add more staff to address 

the increase in the requests for reconsideration.
Appendix II: Ports of Entry with Dedicated 

Trusted Traveler Lanes and Kiosks

Page 54 GAO-14-483 CBP Trusted Traveler Programs

CBP has dedicated trusted traveler lanes for passenger and commercial 

traffic at ports of entry along the northern and southern land borders and 

kiosks for trusted travelers at select international airports in the United 

States. Table 2 lists ports of entry and specific crossings for the three 

trusted traveler programs with dedicated lanes at land borders—Secure 

Electronic Network for Travelers Rapid Inspection (SENTRI), NEXUS, 

and Free and Secure Trade (FAST).

Table 2: Ports of Entry (POE) and Specific Crossings for Trusted Traveler Programs at Land Borders

Port of entry Crossings

Secure Electronic Network for Travelers Rapid Inspection (SENTRI)–passenger vehicles and pedestrians along the southern 

land border

Brownsville, Texas • Veterans International

Calexico, California • Calexico East

• Calexico West

Douglas, Arizona • Douglas

El Paso, Texas • Stanton Street

• Ysleta

Hidalgo, Texas • Anzalduas

• Hidalgo

• Pharr

Laredo, Texas • Lincoln-Juarez

Nogales, Arizona • Deconcini

Otay Mesa, California • Otay Mesa

San Luis, Arizona • San Luis

San Ysidro, California • San Ysidro

NEXUS–passenger vehicles along the northern land border, and at some Canadian air and seaports for pre-clearance into 

the United States

Alexandria Bay, New York • Thousand Island Bridge

Blaine, Washington • Pacific Highway

• Peace Arch

• Point Roberts

Buffalo-Niagara Falls, New York • Lewiston Bridge

• Peace Bridge

• Rainbow Bridge

• Whirlpool Bridge

Calais, Maine • International Avenue

Champlain-Rouses Point, New York • Champlain

Detroit, Michigan • Ambassador Bridge

• Windsor Tunnel

Appendix II: Ports of Entry with Dedicated 

Trusted Traveler Lanes and Kiosks
Appendix II: Ports of Entry with Dedicated 

Trusted Traveler Lanes and Kiosks

Page 55 GAO-14-483 CBP Trusted Traveler Programs

Port of entry Crossings

Highgate Springs, Vermont • Highgate Springs

Houlton, Maine • Houlton

Pembina, North Dakota • Pembina

Port Huron, Michigan • Blue Water Bridge

Sault Saint Marie, Michigan • International Bridge

Sumas, Washington • Sumas

Free and Secure Trade (FAST) South–commercial vehicles along the southern border

Brownsville, Texas • Los Tomates

• Los Indios

Calexico East, California • Calexico East

El Paso, Texas • Bota

• Ysleta

Hidalgo, Texas • Pharr

Laredo, Texas • Laredo Bridge #4

• Columbia

Nogales, Arizona • Nogales

Otay Mesa, California • Otay Mesa

Santa Teresa, New Mexico • Santa Teresa

FAST North–commercial vehicles along the northern land border

Blaine, Washington • Blaine

Champlain-Rouses Point, New York • Champlain

Detroit, Michigan • Ambassador Bridge

Port Huron, Michigan • Blue Water Bridge

Source: GAO analysis of U.S. Customs and Border Protection data.

Table 3 lists airports within the United States with Global Entry kiosks.
Appendix II: Ports of Entry with Dedicated 

Trusted Traveler Lanes and Kiosks

Page 56 GAO-14-483 CBP Trusted Traveler Programs

Table 3: U.S. Airports with Global Entry Kiosks

Airport

1. Baltimore/Washington International Thurgood Marshall Airport

2. Boston-Logan International Airport

3. Charlotte-Douglas International Airport

4. Chicago O’Hare International Airport

5. Dallas/Ft. Worth International Airport

6. Denver International Airport

7. Detroit Metropolitan Airport

8. Ft. Lauderdale/Hollywood International Airport

9. George Bush Intercontinental Airport, Houston

10. Hartsfield-Jackson Atlanta International Airport

11. Honolulu International Airport

12. John F. Kennedy International Airport, New York

13. John Wayne Airport, Santa Ana

14. Los Angeles International Airport

15. McCarran International Airport, Las Vegas

16. Miami International Airport

17. Minneapolis/St. Paul International Airport

18. Newark Liberty International Airport

19. Orlando International Airport

20. Orlando-Sanford International Airport

21. Philadelphia International Airport

22. Phoenix Sky Harbor International Airport

23. Portland International Airport, 

24. Raleigh-Durham International Airport

25. Salt Lake City International Airport

26. San Antonio International Airport

27. San Diego International Airport

28. San Francisco International Airport

29. Seattle-Tacoma International Airport-SeaTac

30. Tampa International Airport

31. Washington-Dulles International Airport

Source: U.S. Customs and Border Protection data.
Appendix III: Trusted Traveler Application 

Denial Rates and Revocations

Page 57 GAO-14-483 CBP Trusted Traveler Programs

The rates at which applicants were denied membership varied by the 

trusted traveler program and the type of application—whether it was an 

initial application, a renewal application, or a reapplication.1

 1

A reapplication is the application of someone who has applied for a trusted traveler 

program one or more times previously and has been denied.

As shown in 

figure 11, Global Entry and NEXUS had the lowest denial rates for initial 

applications (4.4 percent and 4.6 percent, respectively) and renewal 

applications (0.4 percent and 1.0 percent, respectively) from fiscal years 

2009 through 2013. For all programs, the denial rates for renewal 

applications were lowest and the denial rates for reapplications were 

highest, with the initial application rate being somewhere in between. 

CBP officials noted that renewal application denial rates are generally low 

because these applicants have already been approved to participate in a 

trusted traveler program and have also been subject to ongoing 24-hour 

vetting. In contrast, CBP officials said that the denial rates for 

reapplications are higher because these applicants have previously 

applied for and been denied enrollment in a trusted traveler program and 

the reason their previous applications were denied may still disqualify 

them.

Appendix III: Trusted Traveler Application 

Denial Rates and Revocations
Appendix III: Trusted Traveler Application 

Denial Rates and Revocations

Page 58 GAO-14-483 CBP Trusted Traveler Programs

Figure 11: Trusted Traveler Application Denial Rates for Fiscal Years 2009 through 

2013

Note: Denial rates were calculated by dividing the number of denied applications by the total number 

of applications adjudicated from fiscal years 2009 through 2013. CBP officials noted that in fiscal year 

2009 and part of fiscal year 2010, applications that were abandoned (i.e., the applicant did not 

schedule an interview or did not show up for his or her scheduled interview) were counted as denials. 

In fiscal years 2011 through 2013, abandoned applications were not included in the number of denied 

applications as a result of changes to the Global Enrollment System that allowed CBP to better track 

abandoned applications.

There have been 52,489 trusted traveler revocations as of January 23, 

2014, and the number of revocations varied by program, as shown in 

figure 12. In particular, there have been more members revoked from 

SENTRI than from any other program, because, CBP officials explained, 

the southern border is a higher-risk environment than the northern border. 

Moreover, CBP officials noted that the number of revocations is relative to 

the total number of memberships over the lifetime of each program. For 

example, there are more SENTRI and NEXUS revocations than there are 

FAST North or FAST South revocations, as SENTRI and NEXUS account 

for a larger proportion of trusted traveler memberships and have been 

operating for just as long as or longer than either FAST North or FAST 

South. Further, while Global Entry accounted for the largest proportion of 
Appendix III: Trusted Traveler Application 

Denial Rates and Revocations

Page 59 GAO-14-483 CBP Trusted Traveler Programs

trusted traveler memberships in January 2014, the number of revocations 

is relatively low; CBP officials noted it was the most recently implemented 

trusted traveler program and that the number of revocations has 

increased as membership has grown.

Figure 12: Trusted Traveler Revocations as of January 2014
Appendix IV: Number and Percentage of 

Trusted Traveler Entries at Ports of Entry That 

Have Trusted Traveler Lanes, by Program, 

Fiscal Years 2009 through 2013

Page 60 GAO-14-483 CBP Trusted Traveler Programs

Tables 4 through 7 show the number of trusted traveler entries at all 

crossings with dedicated lanes or kiosks, and the percentage of all entries 

at those crossings that were trusted travelers, by program, for fiscal years 

2009 through 2013. The Global Entry table includes only fiscal years 

2012 and 2013 because Global Entry was a pilot program until 2012.

Table 4: Number and Percentage of Vehicle Entries through Crossings with Dedicated Secure Electronic Network for 

Travelers Rapid Inspection (SENTRI) Lanes That Were Trusted Travelers, Fiscal Years 2009 through 2013

Crossing

a

2009 2010 2011 2012 2013

Number Percent Number Percent Number Percent Number Percent Number Percent

Brownsville, TX–

Los Tomates

(Veterans 

International)

326,963 27 474,050 33 457,017 35 405,357 31 389,959 32

Calexico, CA–

Calexico West 

Port of Entry

641,121 18 1,139,149 27 1,171,867 29 1,350,604 33 1,467,916 36

Calexico, CA–

Calexico East Port 

of Entry 

N/A N//A b N/A N/A 236,988 9 434,413 15 496,054 16

Douglas, AZ–

Douglas

N/A N/A N/A N/A N/A N/A N/A N/A 1,995 <1

El Paso, TX–

Ysleta

388,937 18 675,955 26 650,589 27 668,660 26 717,120 25

El Paso, TX–

Stanton Street

835,536 88 1,196,014 98 1,070,032 95 1,095,821 98 1,098,444 98

Hidalgo, TX–

Anzalduas 

N/A N/A 20,315 N/A 40,189 4 N/A N/A N/A N/A

Hidalgo, TX–

International 

Bridge

196,504 6 320,132 10 322,671 12 365,589 15 407,996 18

Hidalgo, TX–Pharr N/A N/A 5,302 <1 47,936 4 45,216 4 38,593 3

Laredo, TX–

Lincoln Juarez 

Bridge

587,052 20 1,089,813 31 1,084,706 33 1,076,292 32 1,096,582 31

Nogales, AZ–

Nogales

399,281 23 532,775 29 542,358 30 597,625 32 614,254 30

Otay Mesa, CA–

Otay Mesa

601,542 17 805,640 20 910,023 22 1,042,229 20 1,256,539 21

San Luis–San Luis N/A N/A N/A N/A 190,357 9 428,982 18 487,646 18

San Ysidro, CA–

San Ysidro 

1,951,525 18 3,214,311 24 3,643,708 29 4,079,803 35 4,502,544 40

Source: GAO analysis of U.S. Customs and Border Protection data.

Appendix IV: Number and Percentage of 

Trusted Traveler Entries at Ports of Entry 

That Have Trusted Traveler Lanes, by 

Program, Fiscal Years 2009 through 2013
Appendix IV: Number and Percentage of 

Trusted Traveler Entries at Ports of Entry That 

Have Trusted Traveler Lanes, by Program, 

Fiscal Years 2009 through 2013

Page 61 GAO-14-483 CBP Trusted Traveler Programs

a

Table entries represent the total number of vehicles entering the United States through dedicated 

SENTRI lanes, and do not account for SENTRI members entering through regular lanes, or multiple 

SENTRI members traveling in the same vehicle.

b

Entries listed as N/A indicate that the listed crossing did not have dedicated SENTRI lanes in that 

year.

Table 5: Number and Percentage of Vehicle Entries through Crossings with Dedicated NEXUS Lanes That Were Trusted 

Travelers, Fiscal Years 2009 through 2013

Crossing

a

2009 2010 2011 2012 2013

Number Percent Number Percent Number Percent Number Percent Number Percent

Alexandria Bay, 

NY–Thousand 

Island Bridge

N/A N/A b 1,191 <1 1,959 <1 9,849 1 8,635 1

Blaine, WA–

Pacific Highway

149,898 15 224,558 17 309,858 20 443,620 25 580,835 32

Blaine, WA–Peace 

Arch Crossing

370,095 34 380,170 22 464,820 20 861,680 31 1,002,724 34

Buffalo-Niagara 

Falls, NY–Peace 

Bridge

281,950 14 350,965 15 377,801 16 402,363 17 415,057 18

Buffalo-Niagara 

Falls, NY–

Queenstown 

Bridge

2 <1 N/A N/A N/A <1 N/A <1 6,126 <1

Buffalo- Niagara 

Falls, NY–

Rainbow Bridge

55,183 5 71,329 5 68,051 4 70,399 4 37,559 2.7

Buffalo-Niagara 

Falls, NY–

Whirlpool Bridge

128,429 97 189,396 99 224,479 93 287,670 98 367,190 98

Calais, ME–

International 

Avenue

N/A N/A N/A N/A N/A N/A 516 <1 1,625 1

ChamplainRouses Point–

Champlain

19,818 4 39,402 6 45,621 6 54,321 6 60,323 7

Detroit, MI–

Ambassador 

Bridge

275,385 15 397,550 17 387,911 17 439,326 20 444,678 20

Detroit, MI–

Windsor Tunnel

158,778 10 244,613 15 248,166 14 271,773 14 299,347 15

Highgate Springs, 

VT–Highgate 

Springs

326 <1 1,394 <1 852 <1 2,928 1 3,775 1
Appendix IV: Number and Percentage of 

Trusted Traveler Entries at Ports of Entry That 

Have Trusted Traveler Lanes, by Program, 

Fiscal Years 2009 through 2013

Page 62 GAO-14-483 CBP Trusted Traveler Programs

Crossing 2009 2010 2011 2012 2013

Number Percent Number Percent Number Percent Number Percent Number Percent

Houlton, ME–

Houlton

1,088 1 1,593 1 3,253 1 3,632 1 4,729 2

Pembina, ND–

Pembina

440 <1 488 <1 217 <1 219 <1 280 0

Point Roberts, 

WA–Point Roberts 

104,950 19 191,296 24 180,609 18 352,088 32 385,363 34

Port Huron, MI–

Blue Water Bridge

123,315 10 277,656 17 346,012 19 339,816 18 338,091 17

Sault Saint Marie, 

MI–International 

Bridge

980 <1 1,990 <1 2,419 <1 2,982 <1 2,681 <1

Sumas, WA–

Sumas

N/A N/A N/A N/A N/A N/A 15,172 1 32,069 3

Source: GAO analysis of U.S. Customs and Border Protection data.

a

Table entries represent the total number of vehicles entering the United States through dedicated 

NEXUS lanes, and do not account for NEXUS members entering through regular lanes, or multiple 

NEXUS members traveling in the same vehicle.

b Entries listed as N/A indicate that the listed crossing did not have dedicated NEXUS lanes in that 

year.

Table 6: Number and Percentage of Passenger Entries through Airports for Global Entry Kiosks, Fiscal Years 2012 through 

2013

Airport 2012 2013

Number Percent Number Percent

Baltimore/Washington International Thurgood Marshall Airport 349 <1 2,642 1

Boston-Logan International Airport 27,371 2 50,579 3

Charlotte-Douglas International Airport 5,183 <1 19,586 2

Chicago O’Hare International Airport 94,287 2 165,720 4

Dallas/Ft. Worth International Airport 66,739 3 116,250 4

Denver International Airport 5,004 1 21,851 4

Detroit Metropolitan Airport 30,527 2 46,915 3

Ft. Lauderdale/Hollywood International Airport 9,997 1 20,334 2

George Bush Intercontinental Airport, Houston 128,270 3 201,163 5

Hartsfield-Jackson Atlanta International Airport 81,494 2 127,063 3

Honolulu International Airport 2,930 <1 6,324 <1

John F. Kennedy International Airport, New York 140,908 1 235,360 2

John Wayne Airport, Santa Ana 189 1 1,224 1

Los Angeles International Airport 78,300 1 135,198 2
Appendix IV: Number and Percentage of 

Trusted Traveler Entries at Ports of Entry That 

Have Trusted Traveler Lanes, by Program, 

Fiscal Years 2009 through 2013

Page 63 GAO-14-483 CBP Trusted Traveler Programs

Airport 2012 2013

Number Percent Number Percent

McCarran International Airport, Las Vegas 4,547 1 15,432 2

Miami International Airport 116,944 1 206,542 2

Minneapolis/St. Paul International Airport 7,501 1 26,596 3

Newark Liberty International Airport (EWR) 119,448 2 198,283 4

Orlando International Airport 5,718 <1 11,867 1

Orlando-Sanford International Airport 51 <1 83 <1

Philadelphia International Airport 15,115 1 32,561 2

Phoenix Sky Harbor International Airport 4,125 1 21,805 3

Portland International Airport 988 1 3,299 2

Raleigh-Durham International Airport 612 1 2,975 5

Salt Lake City International Airport 691 1 3,650 4

San Antonio International Airport 216 <1 5,110 2

San Diego International Airport 1,073 1 6,841 2

San Francisco International Airport 51,127 1 102,521 2

Seattle-Tacoma International Airport-SeaTac 18,560 2 36,530 3

Tampa International Airport 400 <1 3,231 2

Washington-Dulles International Airport 71,216 2 117,544 4

Source: GAO analysis of U.S. Customs and Border Protection data.

Note: Prior to fiscal year 2012, Global Entry was a pilot program. The Global Entry program was 

expanded to all airports in fiscal year 2012.
Appendix IV: Number and Percentage of 

Trusted Traveler Entries at Ports of Entry That 

Have Trusted Traveler Lanes, by Program, 

Fiscal Years 2009 through 2013

Page 64 GAO-14-483 CBP Trusted Traveler Programs

Table 7: Number and Percentage of Commercial Vehicle Entries through Ports of Entry with Dedicated Free and Secure Trade 

(FAST) Lanes That Were Trusted Travelers, Fiscal Years 2009 through 2013

Port of entry 2009 2010 2011 2012 2013

Number Percent Number Percent Number Percent Number Percent Number Percent

FAST South

Brownsville 5,567 3 7,756 4 12,167 6 11,183 5 11,657 6

Calexico 20,098 7 44,170 13 52,192 17 61,507 19 75,443 23

El Paso 51,736 7 11,493 2 152,729 21 159,457 22 159,325 22

Hidalgo 17,393 4 37,895 8 41,264 9 44,142 9 46,114 9

Laredo 34,748 2 79,290 5 142,354 8 160,656 9 181,790 10

Nogales 12,927 5 23,920 7 34,249 12 41,445 14 42,207 14

Otay Mesa 67,573 9 126,138 15 135,377 18 149,094 19 164,553 21

Santa Teresa 357 1 444 1 73 <1 118 <1 290 <1

FAST North

Blaine 20,518 6 22,261 7 25,781 7 26,294 8 77,931 8

Champlain-Rouses Point 74,223 20 97,466 25 105,817 37 99,205 35 104,082 37

Detroit 230,798 16 288,632 17 280,235 19 307,406 20 307,824 20

Buffalo-Niagara Falls 118,856 12 130,876 13 130,791 14 135,711 14 146,583 16

Source: GAO analysis of U.S. Customs and Border Protection data.

Note: Table entries represent the total number of commercial vehicles entering the United States 

through dedicated FAST lanes, and do not account for FAST members entering through regular 

lanes, or multiple FAST members traveling in the same vehicle.
Appendix V: CBP Efforts to Address

Wait Time Data Limitations

Page 65 GAO-14-483 CBP Trusted Traveler Programs

CBP faces limitations using vehicle wait time data for public reporting of 

the wait times themselves and for CBP management decisions across 

border crossings. In July 2013, we reported on CBP’s processes for 

calculating wait times for commercial vehicles at southwest border land 

POEs. Specifically, in that report we found that wait times for commercial 

vehicles along the southern border were unreliable because CBP officers 

inconsistently implemented one methodology used to calculate wait 

times, another methodology—driver surveys—was inherently unreliable, 

and CBP officials used different methodologies to calculate wait times 

across land border crossings.1 We recommended that CBP assess the 

feasibility of replacing current methodologies with automated methods, as 

well as three other recommendations. CBP concurred with our 

recommendations. According to CBP officials, CBP uses these same 

methods to measure wait times for vehicle crossings at all land border 

POEs for passenger and commercial vehicles, including those with 

trusted traveler lanes. Therefore, these same limitations apply at all land 

POEs. In July 2013, we recommended that CBP officials assess the 

feasibility of replacing current manual wait time calculation methodologies 

with automated methods.2 According to CBP officials, reliable passenger 

wait time data are important at both tactical and strategic levels, and they 

are working with the private sector to develop different automated wait 

time technologies. CBP implemented an automated wait time technology 

using cellular-based technology at the Buffalo-Niagara Falls crossing 

along the northern border in 2012, and plans to expand the use of the 

technology. CBP uses the technology by providing select vehicles at the 

end of the queue with devices that send a wireless signal that are then 

read by receivers as the cars pass certain checkpoints. In February 2008, 

the U.S. Department of Transportation Federal Highway Administration 

initiated pilot projects to develop automated wait time data collection 

methods at select southwest border crossings that rely on radiofrequency identification readers to read unique signals from passing

vehicles at several points along the border-crossing route. As of March 

2013, pilot projects to automate wait times were under way or completed 

at eight locations along the southern border.3

 1

The results of these pilots 

GAO-13-603.

2

GAO-13-603.

3

The completed pilot project was at Otay Mesa (Otay Mesa, California,) and the ongoing 

projects were at Pharr (Pharr, Texas), Bridge of the Americas (El Paso, Texas), Ysleta (El 

Paso, Texas), World Trade Bridge (Laredo, Texas), Columbia Solidarity Bridge (Laredo, 

Texas), Veterans (Brownsville, Texas), and Mariposa (Nogales, Arizona). 

Appendix V: CBP Efforts to Address

Wait Time Data Limitations
Appendix V: CBP Efforts to Address

Wait Time Data Limitations

Page 66 GAO-14-483 CBP Trusted Traveler Programs

could help CBP determine what, if any, method to employ to automate the 

collection of wait time data. Wait times for Global Entry are already 

automated, as each passenger receives a time stamp when his or her 

flight lands and when clearing primary inspection.
Appendix VI: Comments from the Department 

of Homeland Security

Page 67 GAO-14-483 CBP Trusted Traveler Programs

Appendix VI: Comments from the 

Department of Homeland Security
Appendix VI: Comments from the Department 

of Homeland Security

Page 68 GAO-14-483 CBP Trusted Traveler Programs
Appendix VI: Comments from the Department 

of Homeland Security

Page 69 GAO-14-483 CBP Trusted Traveler Programs
Page 70 GAO-14-483 CBP Trusted Traveler Programs

Rebecca Gambler, (202) 512-8777 or gamblerr@gao.gov

In addition to the contact named above, Kirk Kiester (Assistant Director), 

Frances Cook, Michele Fejfar, Allyson Goldstein, Eric Hauswirth, Robert 

Herring, Christoph Hoashi-Erhardt, Mitch Karpman, Heather May, Linda 

Miller, Octavia Parks, Meghan Squires, Vanessa Taylor, and Jeff Tessin 

made significant contributions to this report.

Appendix VII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(441131)
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