Border Security: Additional Steps Needed to Ensure That Officers Are Fully Trained
Published: 2011-12-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Recent incidents involving potential terrorists attempting to enter the country highlight the need for a vigilant and well-trained workforce at the border. U.S. Customs and Border Protection (CBP), within the Department of Homeland Security, is the lead federal agency in charge of inspecting travelers and goods for admission into the United States. About 20,000 CBP officers play a central role in ensuring that CBP accomplishes its mission of securing the border while also facilitating the movement of millions of legitimate travelers and billions of dollars in international trade. GAO was asked to assess the extent to which CBP has (1) revised its training program for newly hired CBP officers in accordance with training standards and (2) identified and addressed the training needs of incumbent CBP officers. GAO analyzed data and documentation related to the agencys training efforts, such as its covert test program and its training records. GAO also interviewed CBP officials and CBP officers. This is a public version of a sensitive report that GAO issued in October 2011. Information CBP deemed sensitive has been redacted.
section_title: What GAO Found
paragraphs: CBP revised its training program for newly hired CBP officers in accordance with its own training development standards. Consistent with these standards, CBP convened a team of subject-matter experts to identify and rank the tasks that new CBP officers are expected to perform. As a result, the new curriculum was designed to produce a professional law enforcement officer capable of protecting the homeland from terrorist, criminal, biological and agricultural threats. In addition, the curriculum stated that the CBP officer is to draw conclusions and take appropriate action to identify behavioral indicators displayed by criminals, effectively interview travelers to identify potential threats, identify fraudulent documents, and use technology in support of the inspection process.
CBP has taken some steps to identify and address the training needs of its incumbent CBP officers, but could do more to ensure that these officers are fully trained. GAO examined CBPs results of covert tests conducted over more than 2 years and found significant weaknesses in the CBP inspection process at the ports of entry that were tested. In response to these tests, CBP developed a Back to Basics course in March 2010 for incumbent officers but has no plans to evaluate the effectiveness of the training. Moreover, CBP has not conducted an analysis of all the possible causes or systemic issues that may be contributing to the test results. Further evaluation of the training and causes underlying covert test results could help inform CBP about whether the training is sufficient to address the weaknesses identified by the covert tests or if adjustments are needed. In addition, CBP offices are responsible for recording their employees training records; however, CBP does not have a policy that assigns responsibility to port management to ensure that their staff enter data into its training records system completely and accurately. A policy outlining the roles and responsibilities of offices and positions for training could help clarify which offices and positions are responsible for identifying and addressing training needs and for holding these offices accountable for their responsibilities. Moreover, CBP currently does not have reliable training completion records to ensure CBP officers received required training or other training relevant to their assigned duties. Based on GAOs analysis of training records, more than 4,000 customs officers have not completed the immigration fundamentals, immigration law, and agricultural fundamentals courses, although they were required to complete them during a cross-training program. According to CBP, the training completion records are incomplete, and it is unlikely that the officers did not complete the required cross-training. Nevertheless, without reliable training records; CBP cannot provide reasonable assurance that all customs officers completed the required cross-training. Further, CBP has not conducted a needs assessment that would identify any gaps between identified critical skills and incumbent officers current skills and competencies. A needs assessment could enhance CBPs ability to ensure its workforce is training to meet its mission.
section_title: What GAO Recommends
paragraphs: To improve CBP training efforts, GAO recommends that the CBP Commissioner evaluate the Back to Basics training course; analyze covert test results; establish a policy for training responsibilities, including oversight of training records; and, conduct a training needs assessment. CBP concurred with the recommendations and is taking steps to address them.

section_title: Letter
paragraphs: The September 11, 2001, terrorist attacks, as well as recent incidents  involving potential terrorists attempting to enter the country, highlight the  need for a vigilant and well-trained workforce at the border. Since the  creation of the Department of Homeland Security (DHS) in 2003, U.S.  Customs and Border Protection (CBP)—a component within DHS— serves as the lead federal agency in charge of inspecting travelers and  goods entering the United States at air, land, and sea ports of entry.  CBP officers, who number about 20,000, play a central role in carrying  out this responsibility. A highly trained CBP officer corps is critical to  ensure that CBP accomplishes its dual mission of securing the border by  refusing attempted illegal entry to the United States and facilitating the  cross-border movement of millions of legitimate travelers and billions of  dollars in international trade. Since the creation of the CBP officer position  in 2003 and the subsequent development of the original CBP officer basic  training curriculum, the role of the CBP officer has involved increased  emphasis on countering threats posed by terrorists and others attempting  to fraudulently enter the country with altered or genuine travel  documents. As a result, CBP has revised its training to reinforce the law  enforcement mindset within the CBP officer.
In 2007, we reported on vulnerabilities and inefficiencies in traveler  inspections, including challenges ports of entry faced in delivering  required training to CBP officers.  Specifically, we reported that CBP did not know the extent to which legacy officers had received required cross- training and whether newly hired officers were fully proficient in their  required duties. Therefore, we recommended that the agency develop  data on cross-training to determine whether the officers received the  required training. We also recommended that the agency incorporate  specific tasks into the on-the-job training program for newly hired officers  and measure officer proficiency in performing those tasks. CBP generally  agreed with our recommendations and we discuss actions it has taken in  response to these recommendations later in this report.
In this context, you asked us to assess the extent to which CBP has       (1) revised its training program for newly hired CBP officers in accordance  with its training standards since the launch of the curriculum in 2004 and  (2) identified and addressed the training needs among incumbent CBP  officers.
This report is a public version of the prior sensitive report that we  provided to you. DHS deemed some of the information in the prior report  as Sensitive Security Information (SSI), which must be protected from  public disclosure. Therefore, this report omits sensitive information about  the specific results related to CBP’s covert testing. Although the  information provided in this report is more limited in scope, it addresses  the same questions as the sensitive report. Also, the overall methodology  used for both reports is the same.
Operations Academy who are responsible for designing and  implementing the revised curriculum.
To address our second objective, we analyzed the results of CBP covert  testing of document fraud detection at ports of entry for the period      April 2009 through August 16, 2011, and interviewed officials at the Office  of Internal Affairs (IA) to understand the methodology of covert testing  operations. We assessed the reliability of the covert test data by verifying  CBP’s calculations of the covert test interdiction rate. We found these  data to be sufficiently reliable for our purpose. We also analyzed relevant  CBP training policies and procedures for incumbent officers, CBP course  offerings for incumbent officers, and CBP’s job task analysis that  identifies the differences between the former and new basic academy  training to identify possible incumbent officer training needs. We obtained  and reviewed relevant data from CBP’s Training Records and Enrollment  Network (TRAEN) for the period 2004 through 2011, as well as  supplemental data from OTD. We assessed the reliability of the TRAEN  data by (1) interviewing knowledgeable officials about how training  completion is documented, and how the completions are entered in  TRAEN; (2) reviewing relevant documentation; and, (3) comparing  TRAEN records to training completion records we obtained directly from  select field offices. We determined the TRAEN data were not sufficiently  reliable to demonstrate CBP officer training completion and training  needs, as discussed later in this report. Further, we interviewed OFO and  OTD officials on CBP efforts to address any identified training needs and  compared these efforts with OTD training standards. To assess CBP  policies for tracking, overseeing, and evaluating incumbent officer  training, we interviewed officials at the OFO Training branch, the Office of  Field Programs, the Office of Passenger Admissibility, and Passenger  Programs, including the Fraudulent Document Analysis Unit (FDAU) and  the Enforcement Policy office.
We also visited three ports of entry—John F. Kennedy International  Airport, Laredo land port, and Dallas-Fort Worth International Airport— during January and February 2011 to observe CBP officer inspections  and to interview CBP officers and port management regarding incumbent  CBP officer training and inspection policies and procedures. We selected  John F. Kennedy International Airport and Dallas-Fort Worth International  Airport because of the large volume of international passenger traffic  going through these airports. We selected Laredo land port because the  postacademy course was piloted at this port of entry. Our observations  helped us understand CBP officer passenger inspections. We also  interviewed officials with training-related responsibilities at CBP  headquarters, the New York field office, and three land ports of entry we  visited— John F. Kennedy International Airport, Laredo land port, and  Dallas-Ft. Worth International Airport. Our observations from these visits  and interviews are illustrative and provide insights but are not  generalizable to all ports of entry across the country.
The scope of our review was limited to training provided to all CBP  officers who serve in the passenger environment at ports of entry with an  emphasis on passenger admissibility. It did not include training on  customs procedures, radiation detection or training provided to those  CBP officers who serve as canine specialists, or those who may serve in  the cargo environment.
We conducted this performance audit from December 2010 to December  2011, in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: CBP is the lead federal agency charged with interdicting terrorists,  criminals, and inadmissible travelers at ports of entry while facilitating the  flow of legitimate travel and commerce at the nation’s borders. In March  2003, inspectors from the three legacy agencies—the Department of  Justice’s U.S. Immigration and Naturalization Service, the Department of  the Treasury’s U.S. Customs Service and the Department of Agriculture’s  Animal and Plant Health Inspection Service—were merged to form CBP.  As part of the merger, CBP cross-trained CBP officers to simultaneously  perform immigration and customs inspection functions as well as identify  and refer possible agricultural violations for further inspection. DHS stated  that the ability to use inspectors interchangeably for immigration and  customs inspection functions would allow the agency to more effectively  use its personnel and accelerate the processing of legitimate travelers,  thereby enabling CBP to more effectively enhance efforts to secure the  border. OFO—one of the CBP component offices—manages and deploys  CBP officers who operate within 20 field offices, and 329 ports of entry  composed of airports, seaports, and designated land ports of entry  throughout the United States plus selected locations overseas.
subsections: section_title: Staffing, Budgeting, and Training
paragraphs: As of July 2011, nearly 20,000 CBP officers operated at U.S. ports of  entry and other locations overseas. The total number of onboard CBP  officers peaked in fiscal year 2009 at 21,339 but declined in fiscal years  2010 and 2011 to 20,431. According to OFO, the decline in the onboard  number of CBP officers is due, in part, to a decline in traveler volume  resulting in a decline in collected user fees that fund CBP officers located  at airports and seaports. At the end of fiscal year 2004, there were  about 18,000 CBP officers, the majority of whom were legacy officers  from the Department of Treasury’s U.S. Customs Service, followed by  legacy officers from the Department of Justice’s U.S. Immigration and  Naturalization Service and the Department of Agriculture’s Animal and  Plant Health Inspection Service. Since fiscal year 2007, the total number  of legacy officers has declined. As of July 2011, 45 percent of the CBP  officer workforce was comprised of legacy officers. Since fiscal year 2007,  the annual attrition rate of legacy officers has declined from 6.5 percent to  2.4 percent in fiscal year 2010. Figure 1 illustrates the percentage of  legacy CBP officers compared to the total CBP officer workforce over  time.
CBP officer responsibilities for passenger inspection are primarily focused  at the primary and secondary inspection areas at ports of entry. In the  primary inspection area, CBP officers are expected to rapidly analyze  passenger admissibility by sufficiently questioning the passenger,  examining the passenger’s travel documents, and using appropriate  technology to identify those passengers that can be immediately admitted  into the United States or need to be referred to a secondary inspection  area for a more thorough inspection, if necessary. Specifically, CBP  officers in the primary inspection area are expected to first examine travel  documents by comparing the document to the passenger and then ask  questions to confirm the identity of the traveler. They also may inspect  travelers’ luggage. CBP officers who serve in the secondary inspection  area conduct closer inspection of travel documents and possessions and  can use multiple law enforcement databases to verify the traveler’s  identity, background, and purpose for entering the country. CBP officers  may also serve in specialized teams to support the inspection functions at  the ports of entry. For example, CBP established the Passenger Analysis  Unit team, which is responsible for cross-checking passenger data in  automated systems to identify high-risk passengers before they enter the  country. Appendix I provides more detail on CBP officer staffing policy  and OFO specialized teams.
OFO is to coordinate with OTD to ensure that component training  complies with OTD training standards. In the case of CBP officers, OFO  and OTD share responsibility for ensuring that newly hired and incumbent  CBP officers are sufficiently trained. OTD is responsible for designing,  developing, delivering, and evaluating CBP-wide training courses and  establishing training standards and policies for the program, while OFO is  responsible for identifying the training requirements of CBP officers,  providing subject-matter experts to assist in the development and  instruction of some training courses, and reviewing training that is  developed. OFO established a training branch in 2003 to serve as a  liaison between OTD and OFO. OFO also established FDAU in 2005,  which performs analyses of fraudulent documents that have been seized  to identify global patterns and trends. FDAU is to provide training and  training materials to enhance CBP officers’ abilities to detect fraudulent  documents and thereby increase the number of interceptions through the  sharing of information within CBP and DHS and with other U.S. and  foreign government agencies.
OTD is also responsible for overseeing and managing the CBP training  budget, known as the National Training Plan (NTP), and prioritizing  training development and delivery via the Training Advisory Board  (TAB). Also, OTD developed and manages the Virtual Learning Center  (VLC) where CBP officers can take self-paced courses on a variety of  topics. Further, OTD operates and manages basic and advanced  training schools for CBP officers. Specifically, OTD operates the Field  Operations Academy, which trains and prepares newly hired CBP  Officers for deployment to U.S. ports of entry. OTD is responsible for  managing and overseeing CBP’s official training records system, Training  Records and Enrollment Network (TRAEN), and the Academy Course  Management System, a training scheduling and tracking system that  OFO uses to monitor newly hired CBP officers’ successful completion of  basic training. Each year, OTD is to request that the CBP offices provide  a list of specific training courses and the approximate number of  participants they would like to send to training. OTD is to compile these  requests and present them to TAB, which is to review and prioritize the  courses to be delivered that year. In addition, TAB approves the total NTP  budget amount for each fiscal year. On the basis of the Board’s priorities,  OTD is to develop the NTP budget for the fiscal year and is also  responsible for monitoring the delivery of the training and managing the  NTP budget during the year. The NTP budget funds the delivery of  training for all CBP offices—including training for OFO—for a single fiscal  year. In fiscal year 2009, CBP training expenditures peaked due, in part,  to receipt of supplemental funding to hire and train CBP officers and  Border Patrol agents. Since fiscal year 2009, CBP’s NTP budget  expenditures have declined due to increasing budget constraints.     Figure 2 displays CBP’s actual NTP budget expenditures from fiscal  years 2008 through 2010 and its projected end-of-year expenditures for  fiscal year 2011. OFO has also funded the development and delivery of  its own training courses for CBP officers when they have not received  funding from the NTP.
IA has oversight authority for all aspects of CBP operations, personnel,  and facilities. IA is responsible for ensuring compliance with all CBP-wide  programs and policies and operates a covert test program to ensure  compliance. Following the issuance of the results of our covert tests of  border security in May 2008, CBP initiated covert tests to evaluate  CBP’s capabilities to detect document fraud. Specifically, CBP focused its  tests on evaluating CBP’s detection of impostors, or individuals who  attempt to enter the United States fraudulently by using a genuine,  unaltered travel document that belongs to another person. CBP also  continued covert tests to detect cargo containing illicit radioactive  material, among others.potential training needs.
OFO uses these ongoing test results to identify  All newly hired CBP officers are required to complete a basic training  program and demonstrate proficiency in CBP officer duties. Incumbent  CBP officers are required to take mandatory courses such as information  technology security, occupational safety, and human trafficking  awareness, among others. CBP provides most mandatory courses on a  one-time or annual basis via the VLC. OFO has mandatory course  requirements, such as fraudulent document detection, and has also  developed specialized courses for incumbent officers assigned to  specialized teams. However, CBP does not require that all CBP officers  assigned to specialized teams complete the specialized training  developed for that team. According to OFO, management must balance  the operational needs of the port with the availability of the training.  Appendix II lists examples of mandatory and specialized courses for CBP  officers for fiscal year 2011.
As we previously reported, in 2003, CBP initiated a multiyear cross- training program to equip new and legacy officers with the tools  necessary to perform primary immigration and customs inspections, and  sufficient knowledge to identify agricultural inspections in need of further  examination.courses—covering immigration fundamentals, immigration law, and  agriculture fundamentals—regardless of where they were assigned. All  legacy immigration officers were required to complete three courses— customs fundamentals, customs law, and agriculture fundamentals— regardless of where they were assigned. Further, based on their  assignment, legacy officers were required to complete additional courses  specific to their assignment and port environment. In June 2011, CBP  officially retired the cross-training courses and replaced them with revised  modules. OFO instructed managers, supervisors, and training officers to  use these new materials as refresher training for officers who transfer to a   CBP required all legacy customs officers complete three  new assignment or environment or who return to inspection duties after  an extended absence.
CBP has prepared training development standards for all CBP training  programs and courses to ensure that training delivered to CBP  employees meets established quality standards of instruction and  evaluation. OTD standards are based, in part, on federal laws and  regulations, which require agencies to establish training programs that  support their mission and meet specified standards, including identifying  training needs, prioritizing these needs, and evaluating the results of  training programs and plans. Also, CBP develops and revises its basic  training for new CBP officers to meet Federal Law Enforcement Training  Accreditation (FLETA) standards, which provide law enforcement  agencies with an opportunity to voluntarily demonstrate that they meet an  established set of professional standards and receive appropriate  recognition. Finally, Standards for Internal Control in the Federal  Government provide criteria for the management and oversight of agency  operations, including training programs.
section_title: CBP Revised Its Training for Newly Hired CBP Officers Consistent with Its Training Standards
paragraphs: In 2009, CBP revised its training program for new officers in accordance  with its training development standards. These standards are based on  legal standards that guide the development of training in the federal  government and standards that guide federal law enforcement training.  OTD standards also contain specific guidance related to the following  phases: (1) planning, (2) analysis, (3) design, (4) development, (5)  evaluation, and (6) delivery of the course curriculum, which CBP adhered  to in revising its training program. Table 1 provides an overview of the  OTD training development phases and related standards and our  assessment of how CBP efforts met these standards in revising its  training for newly hired officers.
OTD standards state that the training curriculum should be current, valid,  and updated once every 3 to 5 years. CBP began the process of revising  its training for new officers in 2009 after the initial launch of the CBP  Officer curriculum in 2004, consistent with OTD standards for updating  the training curriculum every 5 years. OTD, as well as other federal law  enforcement training standards, state that programs should first identify  the critical tasks that the individual is expected to perform in order to  determine what training is needed. Consistent with these standards, OTD  convened a team of subject matter experts (SMEs) to identify and rank  the tasks that new CBP officers are expected to perform. The team  identified a total of 138 critical tasks that newly hired CBP officers are  expected to perform within the first 2 years of employment. These  included conducting thorough and accurate research to support  inspections and investigations, and preparing thorough and accurate  reports covering significant incidents and intelligence. Once the tasks  were identified, the panel of SMEs compared the identified tasks to the  tasks addressed in the existing curriculum to identify any skill gaps. OTD  then developed specific courses with appropriate lessons and topics to  ensure that these tasks were addressed in the new curriculum. For  example, new modules on evidence preservation and secondary report  writing were incorporated in the revised curriculum to address identified  officer skill gaps in handling evidence and writing. Consistent with the  OTD standard that requires a test run of a complete and approved course  in a controlled environment by selected individuals representing the  course’s learning audience, the new CBP officer curriculum was piloted to  test its content and delivery prior to its launch in February 2011. As a  result, the new officer training program course was expanded from about  15 to 18 weeks and approximately 30 to 35 percent of the new officer  curriculum is new or updated and expanded. Thus, the new officer  training program complies with OTD’s standards that state the training  curriculum should be current and valid.
OTD internal training standards also state that the training should be  aligned with the current agency mission and current threats. According to  OFO and OTD officials, the previous CBP officer curriculum focused  primarily on preparing the officer to serve in the primary inspection  function at a port. The SME panel recommended that the new officer  curriculum be revised to produce a law enforcement officer capable of  supporting CBP’s expanding antiterror mission. As a result, the new  curriculum is designed to produce a professional law enforcement officer  capable of protecting the homeland from terrorist, criminal, biological, and  agricultural threats. Specifically, the new curriculum states that the CBP  officer is expected, among other tasks, to draw appropriate conclusions  and take appropriate action to identify behavioral indicators displayed by  criminals and terrorists, effectively interview and analyze travelers to  identify potential threats, expertly identify altered and counterfeit  documents and impostors, and use technology in support of the  inspection process.officer is expected to be able to perform the primary inspection function,  as well as some aspects of the secondary inspection function.
Upon completion of training, the newly hired CBP  OTD standards also state that is important to identify the appropriate  delivery method and location. In accordance with these standards, CBP  determined that the training for new CBP officers would be divided into  three components as shown in figure 3.
Pre-academy—According to OFO officials, the pre-academy component  helps educate incoming CBP officers of job responsibilities before the  agency commits the funds to send them to the Field Operations Academy  in Glynco, Georgia, for basic training. OFO officials also stated that the  pre-academy curriculum is structured because it recommends that a fixed  curriculum be completed in a specific amount of time. Also, it contains a  mix of classroom instruction and web-based courses to familiarize  incoming CBP officers with the specific requirements of the law  enforcement and inspections job, thereby helping to ensure that the pre- academy training is consistent throughout the nation.
Basic academy—The SME panel recommended that the curriculum  include intensified training to enhance officer vigilance and awareness  though interview training, behavior analysis training to discern passenger  behavior, report writing training, and training to detect fraudulent  documents, among others. In addition, CBP increased the amount of time  devoted to practical exercises in response to comments made by newly  hired officers during pilot testing. For example, exercises in the passenger  processing module increased from 11 hours in the old curriculum to   33 hours in the revised curriculum. The revised curriculum was designed  to enhance an officer’s ability to effectively interview and analyze travelers to identify potential threats; expertly identify altered and counterfeit documents and impostors;  identify behavioral indicators displayed by terrorists and criminals; use technology (including computers and other resources) in support  of the inspection process.
Postacademy—In 2007, we reported that although CBP had issued  guidance for on-the-job training of new CBP officers, CBP had difficulty in  providing the training in accordance with the guidance. We  recommended that CBP incorporate the following into its on-the-job  training program: (1) specific tasks that CBP officers must experience  during on-the-job training and (2) requirements for measuring officer  proficiency in performing those tasks. In response to our  recommendations, CBP revised its postacademy training program by  identifying specific tasks and developing a plan for measuring officer  proficiency in those tasks. The revised postacademy training program  combines classroom and on-the-job training and incorporates ongoing  testing and evaluation of officer proficiency. The evaluations are tied to  the critical tasks and competencies that a new officer must perform. In  accordance with the new postacademy training program, prior to being  able to perform primary inspections independently, a training officer must  certify that the officer is proficient to perform the task. The revised  postacademy training began in June 2011. Consistent with OTD training  standards that call for measuring the effectiveness of training, CBP plans  to ask new officers to evaluate their basic academy and postacademy  training. In addition, CBP plans to survey both new officers and their  supervisors several months after a new officer completes on-the-job  training to determine the effectiveness of the training. Consistent with  OTD standards that its training meets federal law enforcement standards,  OTD officials stated that the curriculum received its federal law  enforcement training accreditation in November 2011.
section_title: CBP Has Taken Steps to Identify and Address Incumbent Officer Training Needs but Could Do More to Improve Oversight
paragraphs: CBP has taken steps to identify the training needs of its incumbent  officers, by for example, conducting covert tests to assess vulnerabilities  and systemic weaknesses at ports of entry and identifying possible officer  training needs, but could do more to analyze the tests’ results. In  response to its covert tests, CBP has delivered two required training  courses for incumbent officers, but it has not evaluated the effectiveness  of these courses. Also, OFO officials stated that supervisors identify CBP  officer training needs. However, CBP faces challenges in establishing  policies and procedures to guide its component offices’ efforts to  implement and oversee training, and ensuring that it has reliable training  data. Moreover, CBP has not conducted an analysis of possible skill gaps  that may exist between identified critical skills all incumbent officers  should possess and incumbent officers’ current skills.
subsections: section_title: CBP Uses Covert Tests to Help Identify Possible Training Needs, but Further Evaluation Could Enhance Their Usefulness
paragraphs: To identify vulnerabilities and weaknesses at U.S. ports of entry, CBP IA  conducts covert tests in which undercover inspectors attempt to enter the  United States with genuine documents used fraudulently. The tests are  designed to provide a snapshot of the level of a port’s performance  related to the testing objectives on a particular day. We examined CBP’s  results of covert tests conducted over more than 2 years and found  significant weaknesses in the CBP inspection process at the ports of  entry that were tested.all ports, OFO officials stated that the tests are useful to identify possible   Although the results are not fully generalizable to  weaknesses and vulnerabilities. Following each covert test, IA prepared a  written post-test summary of the tests and outcomes, debriefed with  senior port management and headquarters officials, and provided data to  OFO on the test outcomes. In some of the summaries, IA inspectors  identified what they observed to be the key factors that contributed to  successful outcomes, as well as potential vulnerabilities.
In response to initial test results, OFO developed and mandated an  updated annual fraudulent document course in August 2009. Also, in  March 2010, OFO developed and mandated a “Back to Basics” course  that emphasized the basic inspection duties that all CBP officers are  required to perform during a primary inspection. In July 2011, OFO began  implementing a follow-on course which includes more specific instruction.  CBP administers postcourse evaluations to CBP officer trainees to obtain  their feedback on the “Back to Basics” course but does not have plans to  fully evaluate the effectiveness of this course by checking the extent to  which the officers have retained the information over time. OTD officials  stated that they conduct these types of evaluations for the newly hired  CBP officer basic training but do not do so for this one for incumbent  officers, due to time and cost constraints. However, we have previously  reported that agencies should assess the extent to which training and  development efforts contribute to improved performance and results to  help ensure that the agency is not devoting resources to training that may   An evaluation of the impact of these training courses on  be ineffective.CBP officer performance could help CBP know the extent to which such  training is a sufficient response to the covert test results or whether  adjustments to the training or other management actions are needed.
CBP has not conducted an analysis of all the possible causes or systemic  issues that may be contributing to the test results. The protocols for  covert tests state that IA will provide a comprehensive report at the  conclusion of all cover tests that will summarize test results and identify  systemic issues. As of August 2011, neither IA nor OFO have conducted  such an analysis due to staffing and time constraints, according to IA and  OFO officials. However, this type of analysis would help CBP identify any  patterns or trends that indicate the extent to which CBP officer training,  performance, or other systemic issues may contribute to the issues  identified in the covert tests. Without a comprehensive assessment, it is  difficult for CBP to identify the systemic issues underlying the test results.
section_title: CBP Faces Challenges in Identifying and Addressing Training Needs
subsections: section_title: CBP Lacks Policies and Procedures to Ensure Incumbent CBP Officers Complete Training
paragraphs: In December 2008, CBP issued a directive assigning general roles and  responsibilities for training to OTD and other CBP offices, such as  identifying OTD as the centralized leader for all CBP training. However,  CBP has not established policies or procedures to guide component  offices’ efforts to implement and oversee training. Figure 4 illustrates the  key offices and positions that OFO identified as responsible for incumbent  CBP officer training.
OFO does not have a policy that specifies the roles and responsibilities of  each of these offices and positions for training implementation and  oversight. Federal regulations require that agencies establish policies  governing employee training, including a statement of the alignment of  employee training and development with agency strategic plans, the  assignment of responsibility to ensure the training goals are achieved,  and the delegation of training approval authority to the lowest appropriate  level. In addition, internal control standards state, in a good control  environment, areas of authority and responsibility are clearly defined and  appropriate lines of reporting are established. Internal control standards  also require that responsibilities be communicated within an organization.  According to OFO, the OFO Programs and Policy branch is responsible  for overseeing and coordinating the development of policy to govern  incumbent officer training, including policy that assigns roles and  responsibilities. According to the OFO officials, a policy would be useful  because it helps clearly define the responsibilities of all offices involved in  incumbent CBP officer training. Specifically, a policy outlining the roles  and responsibilities of offices and positions for training would help clarify  which offices and positions are responsible for ensuring incumbent officer  training needs are identified and addressed. However, the acting branch  chief of the OFO Programs and Policy branch stated staffing constraints  have limited the branch’s ability to initiate the process of developing a  policy that clearly assigns responsibility for all offices involved in CBP  officer training. According to OFO officials, supervisors are responsible for  identifying officer training needs and requesting training to meet these  needs. For example, in June 2011, CBP instructed supervisors to identify  training needs and use the post academy modules to address those  needs.
However, OFO could not provide a policy document outlining how  supervisors would identify training needs and coordinate training. Also,  according to the OFO officials, port management and field office directors  are responsible for ensuring that CBP officers complete mandatory and  other training related to their job duties. However, OFO officials in  headquarters and at the ports stated that no policy exists that assigns  these responsibilities to port management or field offices. In addition,  senior CBP officials stated that Field Training Officers help ensure that  CBP officers are receiving the training they need to perform their  assigned duties, and that internal measures are in place to assess  training needs and accomplishments nationwide. However, officials from  the OFO Training branch stated that Field Training Officers are assigned  to help deliver training to the ports but are not required to oversee the  completion of required training by CBP officers at their respective ports.  Further, OFO could not provide documentation confirming the roles and  responsibilities of the Field Training Officer. A policy outlining the roles  and responsibilities of offices and positions for training could help  eliminate such confusion and clarify which offices and positions are  responsible for identifying and addressing training needs and for holding  these offices and individuals accountable for their responsibilities.
CBP currently lacks reliable training completion records to ensure CBP  officers received required training or other training relevant to their  assigned duties. According to OTD and OFO officials, the training  completion records maintained in TRAEN, CBP’s official record of  training, are incomplete or contain inaccurate information, such as the  dates of training completion. As a result, officials from OTD’s Office of  Operations, which plans and manages the annual National Training Plan  (NTP) budget, stated they developed their own records of training  completions that consist of TRAEN records supplemented with data they  gather from e-mail archives. Also, officials from two of the three ports we  visited stated they rely on locally developed databases or data sources  other than TRAEN to track CBP officers’ training records.
We found, based on our analysis of TRAEN records, more than 4,000  onboard legacy customs officers have not completed the immigration  fundamentals, immigration law, and agricultural fundamentals courses  although they were required to complete them during the cross-training  program. According to OFO officials, the training completion records  maintained in TRAEN are incomplete, and it is unlikely that legacy officers  did not complete required cross-training. Nevertheless, without reliable  training records, CBP cannot provide reasonable assurance that all  legacy customs officers completed required cross-training courses. OTD  stated that CBP offices are responsible for recording their employees’  training records in TRAEN. However, CBP does not have a policy that  assigns the responsibility for entering records to its offices or that assigns  oversight responsibility to port management to ensure that their staff enter  data into TRAEN completely and accurately. CBP is currently in the  process of transferring the TRAEN system to the VLC and training CBP  officials on how to properly enter training records in the new system.  However, OFO and OTD officials stated that even trained employees  sometimes do not enter training records completely or in a timely manner.  Internal control standards state control activities—such as policies,  procedures and management supervision—help to ensure that all  transactions are completely and accurately recorded. Further, having  reliable data could enable agency managers to compare actual  performance to planned or expected results throughout the organization  and analyze differences. Moreover, having reliable data to measure the  degree to which CBP officers have completed required or recommended  training for their assigned positions would put CBP in a better position to  gauge the results of its cross-training program and other CBP officer  training and measure its progress towards achieving CBP officer training  goals.
section_title: CBP Has Not Fully Identified and Addressed Potential Incumbent Officer Training Needs
paragraphs: CBP has taken steps to identify training needs among incumbent CBP  officers but has not conducted a comprehensive training needs  assessment to identify and address potential gaps in incumbent officers’  current skills and competencies. Under executive order and federal  regulations, agencies are to review, not less than annually, programs to  identify training needs, establish priorities for training, and allocate  resources in accordance with those priorities.development standards state that a training needs assessment is needed  to identify knowledge or skill gaps and suggest material for new or follow- on training. Specifically, the analysis stage of training development  includes conducting a training needs assessment to identify skill or  knowledge gaps, conducting a job task analysis to identify critical  competencies required for the target audience, and analyzing the target  audience to develop appropriate training, among other steps.
CBP has taken some steps to identify and analyze incumbent officer  training needs. In 2008, CBP initiated the first job task analysis for the  CBP officer position since 2003 by identifying nearly 300 job tasks and  about 100 competencies that all incumbent CBP officers are expected to  perform regardless of their currently assigned duties or port environment.  In 2011, CBP also completed a curriculum gap analysis, which compared  the newly revised basic academy curriculum with the previous basic  academy training to identify new skills or material that incumbent CBP  officers may not have learned in their basic academy training. For  example, the previous curriculum trained CBP officers to perform 75  critical tasks while the newly revised curriculum trains newly hired officers  to perform 138 critical tasks. According to OTD officials, the curriculum  gap analysis identified a shift in the training philosophy and delivery  methods and some changes in course content. For example, the revised  training for newly hired officers aims to instill a law enforcement mindset  by adding new courses in weapons training, evidence preservation, and  courtroom testimony, among others, and by expanding courses that are  designed to increase situational awareness and anti-terrorism vigilance  among the CBP officers. It also increases physical conditioning and the  number of hours of practical exercises related to conducting primary  inspections and examining documents as well as course content to reflect  new laws related to immigration processing and operating new  equipment. The revised curriculum also adds more training in skills that  CBP officers need to perform in secondary processing, including using  appropriate computer systems and following procedures to verify  passenger admittance.
However, CBP has not conducted a training needs assessment or  analyzed the target audience to determine what training is needed. For  example, it has not evaluated potential gaps between the skills and  competencies of current incumbent officers to identify appropriate training  needs and possible gaps between (1) the nearly 300 job tasks and 100  competencies that all incumbent officers are expected to perform and     (2) any additional skills and knowledge that are currently taught in the  revised basic academy curriculum. In addition, CBP has not reviewed  incumbent CBP officers’ previous training and experience, including  cross-training or any on-the-job training, to identify what training they may  have completed. OTD training standards state that it is important to  review the previous experience and training to better identify the training  needs for particular audiences. In 2007, we recommended that CBP  develop data on cross-training programs to determine whether officers  received required training so the agency may measure progress toward  achieving its training goals. As of September 2011, CBP has not  developed these data or measured the extent to which officers completed  required cross-training. In June 2011, CBP retired the cross-training  courses and replaced the courses with new postacademy modules that  contain updated content. However, CBP could review the previous  training records of its legacy and other incumbent officers to help identify  what training they have completed and to identify which postacademy  modules or other training they may need to take to perform their assigned  duties.
Conducting a comprehensive training needs assessment could help CBP  analyze and identify potential skill gaps and training needs for incumbent  officers—including legacy officers—and better position it to develop  training to meet these needs, thus ensuring its officers are equipped to  meet the operational demands at the border. OTD criteria state that CBP  training managers may use a variety of techniques during a training  needs assessment to gather and analyze information about the  necessary training content for proposed training, including:  interviews with SMEs;  focus groups (moderated group interviews) involving SMEs and  representatives of the learning audience; observation of and interviews with those performing a particular job or  task in the field;  review of course critiques, test results, and performance evaluations;  instructional review, course audit, or content review of existing  training; and  review of field incident reports, critical factors identified, and lessons  learned.
OFO officials stated that a training needs assessment would be useful,  but they have been unable to conduct one due to budget constraints and  may not be able to undertake a comprehensive training needs  assessment until fiscal year 2013, at the earliest. However, CBP could  begin the initial steps of planning for a training needs assessment for  incumbent officers in fiscal year 2012. Office of Personnel Management  (OPM) guidance states that a training needs assessment should include a  plan that sets goals or objectives for the training needs assessment;  evaluates the agency readiness and identifies key roles; evaluates prior  or other relevant needs assessments; prepares a project plan; and  clarifies success measures and program milestones. This plan could be  similar to the preparation of a project plan. Specifically, elements of a  project plan include (1) establishing clear and achievable training goals;  (2) balancing the competing demands for quality, scope, time, and cost;  (3) adapting the specifications, plans, and approach to the different  concerns and expectations of the various stakeholders involved in the  project; and (4) developing milestone dates to identify points throughout  the project to reassess efforts under way to determine whether project  changes are necessary. OFO officials stated that such a plan could be  helpful in initiating the process for conducting a training needs  assessment. Project management standards also call for assigning  responsibility and accountability for ensuring the results of program  activities are carried out. Developing a project plan could also help CBP  ensure that it is well-positioned to conduct a comprehensive training  needs assessment in 2013 for its incumbent officers—while allowing for  monitoring and oversight of the staff efforts through the completion of  interim milestones to ensure progress in being made as intended.
section_title: Conclusions
paragraphs: CBP has designed its training program for newly-hired CBP officers to  comply with its standards. Such compliance can contribute to ensuring  that newly-hired officers are prepared to accomplish CBP’s mission of  securing the border and simultaneously facilitating the cross-border  movement of millions of legitimate travelers and billions of dollars in  international trade. However, CBP faces challenges in ensuring that the  training needs of its nearly 20,000 incumbent CBP officers are properly  identified and addressed. The results of its covert tests are not  generalizable to the entire CBP officer population. However, they reveal a  consistent pattern of weaknesses among the officers tested in their ability  to perform basic tasks and these weaknesses have not been corrected.  CBP has no plans for assessing the effectiveness of its “Back to Basics”  course and subsequent follow-on training developed in response to the  covert tests. Assessing the effectiveness in improving incumbent officer  performance could help CBP management know if the training is a  sufficient response to the weaknesses identified by the covert tests or if  additional adjustments are needed.
In addition, CBP has not established policies and procedures to guide  OFO’s implementation and oversight of incumbent officer training,  including entry of complete and accurate data into TRAEN. Having  policies and procedures to ensure that managers are fulfilling their  oversight responsibilities, including maintaining accurate and complete  training records, could help improve CBP’s knowledge of whether  incumbent CBP officers have been properly trained.
Given CBP’s commitment to reinforcing the law enforcement mindset  among all CBP officers, evaluating the training needs of the current CBP  officers so that they can be addressed in a timely and cost-efficient  manner is important. In addition, given budget constraints on training  resources throughout the government, planning accordingly to ensure  that skill needs of the incumbent CBP officers are assessed could help  ensure that a road map is in place for conducting such an assessment  thereby ensuring that CBP’s officer workforce is equipped to meet the  operational demands at the border.
section_title: Recommendations for Executive Action
paragraphs: To improve CBP training efforts, we recommend that the CBP  Commissioner take the following four actions:  (1) Conduct an evaluation of the effectiveness of the “Back to Basics” and  subsequent follow-on training,  (2) Conduct a comprehensive assessment of its covert test results to  identify the causes of and systemic issues underlying the results,  (3) Establish a policy that specifies roles and responsibilities for CBP  officer training implementation and related oversight, including oversight  responsibilities to ensure that training records are entered in TRAEN  completely and accurately and  (4) Develop a plan for conducting a training needs assessment to address  any skill gaps for incumbent CBP officers and then implement that plan.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of the sensitive version of this report to DHS for  comment. DHS provided written comments which are reprinted in  appendix III. In commenting on the sensitive version of this report, DHS,  including CBP, agreed with the recommendations. Specifically, DHS  stated that CBP is taking action or has taken action to address each  recommendation.
DHS agreed with the first recommendation that CBP conduct an  evaluation of the effectiveness of the training course and subsequent  follow-on training, and stated that the Office of Field Operations and the  Office of Training and Development will work in partnership to determine  if the Back to Basics and follow-on training had an effect on overall CBP  officer performance by conducting a study and obtaining the results of  any further covert tests by March 30, 2012. Regarding the second  recommendation that CBP conduct a comprehensive assessment of its  covert test results, DHS agreed and stated that the Office of Internal  Affairs plans to conduct a comprehensive assessment of its covert test  results for fiscal year 2011 by December 30, 2011. DHS agreed with the  third recommendation that CBP establish a policy that specifies roles and  responsibilities for CBP officer training implementation and related  oversight, and stated that a policy will be developed by March 30, 2012,  to clarify the training roles and responsibilities at all national and local  levels to include the responsibility for maintaining accurate training  records. Regarding the fourth recommendation that CBP develop a plan  for conducting a training needs assessment to address any skill gaps for  incumbent CBP officers and then implement that plan, DHS stated that  OFO is coordinating with OTD to evaluate current training to identify any  existing training gaps, and plan to address any identified needs through  formal training by December 31, 2012. If effectively implemented, these  actions should address the intent of the recommendations.
DHS raised an issue regarding the report’s characterization of the DHS  covert test results. Specifically, DHS stated that the covert tests were  deliberately designed to test only a specific aspect of the overall primary  inspection process within the wide range of inspectional duties that CBP  officers perform and are not a valid measure of overall officers’  performance and capabilities or reliability of the entire admissibility  process. The report noted that the test results are not generalizable to all  ports of entry. However, OFO officials emphasized that the tests are  informative in that they can help management identify possible  weaknesses and vulnerabilities in the inspection process and in the CBP  officer ability to perform basic tasks. Specifically, the tests are designed to  provide a snapshot of the level of a port’s performance related to the  testing objectives. Further, according to the protocols, the tests are  designed to test and challenge CBP officers on their abilities, adherence  to policies and procedures, and use of technologies to detect and prevent  individuals attempting to enter the United States through the use of  document fraud. OFO also developed and mandated an annual  fraudulent document course based on the initial response to the covert  test results. Nevertheless, we incorporated language throughout the  report to clarify the objectives and the scope of the covert tests. We  believe that this report presents a valid characterization of the covert test  results and their potential uses.
DHS also provided technical comments, which we incorporated into the  report as appropriate.
We will send copies of this report to the Department of Homeland  Security, the Commissioner of U.S. Customs and Border Protection, the  appropriate congressional committees and other interested parties. In  addition, the report will be available at no charge at GAO’s website  https://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-8816 or stanar@gao.gov.  Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report.  Other GAO contacts and staff  acknowledgments are listed in appendix IV.
section_title: Appendix I: Customs and Border Protection Officer Staffing Policy and Specialized Teams
paragraphs: In February 2009, Customs and Border Protection (CBP) management  and the union that represents CBP officers reached an agreement to  allow CBP officers the opportunity to bid and rotate to a new work unit,  specialized team, or port location every 1 or 2 years. This bid-and- rotation system for CBP officers is based on seniority and is designed to  increase officer morale and retain CBP officers. The system also provides  port management the ability to assign CBP officers to units based on  immediate, changing workload demands.
The following list includes specialized teams that operate at all U.S. air,  land, and sea ports of entry. Ports may have additional CBP officer  specialized teams depending on their size, environment, and mission  demands.
subsections: section_title: Passenger Enforcement Roving Team/Counter- Terrorist Response
paragraphs: These are the passenger work units charged with the interdiction of high- risk passengers attempting to facilitate surreptitious entry of contraband  or who may be associated with terrorist activities.
section_title: Passenger Analysis Unit/Tactical Analysis Group
paragraphs: These are the work units charged with the use of automated systems to  target high-risk passengers, conduct threat analysis, or using after-action  reports to identify threats.
section_title: Passenger Control Secondary
paragraphs: This work unit is charged with processing violations to the Immigration  and Nationality Act (INA) which may result in adverse actions, such as  determination of inadmissibility to the United States.
section_title: Outbound
paragraphs: This work unit is charged with targeting and examining outbound  commercial cargo for violations of law, rules or regulations.
section_title: Advance Targeting Unit
paragraphs: This work unit is charged with the use of automated systems to target  high-risk commercial shipments, conduct analysis, or use after-action  reports to identify threats.
section_title: Anti-Terrorism Contraband Enforcement Team
paragraphs: This work unit is charged with the inbound and/or outbound interdiction of  narcotics and other contraband, including currency, arms and  ammunition, as well as terrorist related materials in the cargo and/or  passenger environments.
section_title: Training
paragraphs: This work unit is charged with providing nationally mandated and locally  designed training including, but not limited to pre-academy, postacademy,  virtual learning center, and unification training.
section_title: Scheduling
paragraphs: This work unit is charged with the scheduling of all regular day and  overtime assignments, as well as the administration of the Customs  Officers Pay Reform Act, including, but not limited to, overtime cap  compliance and annuity integrity.
section_title: Firearms
paragraphs: This work unit is charged with developing and conducting local firearms  programs, including but not limited to, conducting required firearms  qualifications and use of force training, maintaining quantities of firearms- related supplies and equipment, and conducting annual firearms  inventory.
section_title: Appendix II: Mandatory and Specialized Courses for CBP Officers
paragraphs: The following mandatory courses are required either on a one-time basis  or annually for all nonsupervisory Customs and Border Protection (CBP)  officers. The specialized courses were developed to enhance incumbent  nonsupervisory CBP officer skills in specific areas and are not mandatory.
section_title: Appendix III: Comments from the Department of Homeland Security
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Michael Dino, Assistant Director,  Kathryn Bernet, Assistant Director, and Nanette J. Barton, Analyst-in- Charge, managed this assignment. Jennifer Bryant and Edith Sohna  made significant contributions to the work. Stanley Kostyla assisted with  design and methodology. Frances Cook provided legal support. Katherine  Davis provided assistance in report preparation.