Homeland Security: Management and Coordination Problems Increase the Vulnerability of U.S. Agriculture to Foreign Pests and Disease
Published: 2006-05-19T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: U.S. agriculture generates over $1 trillion in annual economic activity, but concerns exist about the sector's vulnerability to a natural or deliberate introduction of foreign livestock, poultry, and crop pests and disease. Under the Agricultural Quarantine Inspection (AQI) program, international passengers and cargo are inspected at U.S. ports of entry to seize prohibited material and intercept foreign agricultural pests. The Homeland Security Act of 2002 transferred AQI inspections from the U.S. Department of Agriculture (USDA) to the Department of Homeland Security (DHS) and left certain other AQI responsibilities at USDA. GAO examined (1) the extent to which USDA and DHS have changed the inspection program since the transfer, (2) how the agencies have managed and coordinated their responsibilities, and (3) how funding for agricultural inspections has been managed since the transfer.
section_title: What GAO Found
paragraphs: After the terrorist attacks of September 11, 2001, federal agencies' roles and responsibilities were modified to help protect agriculture. In March 2003, more than 1,800 agriculture specialists within USDA's Animal and Plant Health Inspection Service (APHIS) became DHS Customs and Border Protection (CBP) employees, while USDA retained responsibility for AQI activities such as setting inspection policy, providing training, and collecting user fees. Since the transfer, the agencies have expanded training on agriculture issues for CBP officers and agriculture specialists. CBP and APHIS also have taken steps to enable agriculture specialists to better target shipments and passengers for inspections and established a process to assess how CBP agriculture specialists are implementing AQI policy. Finally, CBP created a new agriculture liaison position in each of its district field offices to advise regional directors on agricultural issues. While these are positive steps, the agencies face management and coordination problems that increase the vulnerability of U.S. agriculture to foreign pests and disease. CBP has not developed sufficient performance measures that take into account the agency's expanded mission or consider all pathways by which prohibited agricultural items or foreign pests may enter the country. Specifically, although CBP's measures focus on two pathways that pose a risk to U.S. agriculture, they do not consider other key pathways such as commercial aircraft, vessels, and truck cargo. Also, although CBP has hired more than 630 specialists since the transfer, it has not yet developed or used a risk-based staffing model to ensure that adequate numbers of agriculture specialists are staffed to areas of greatest vulnerability. CBP also has not used available inspection and interception data to evaluate the performance of the AQI program. CBP and APHIS also continue to experience difficulty in sharing information such as key policy changes and urgent inspection alerts, and CBP has allowed the number and proficiency of agriculture canine units to decline. Although APHIS is legally authorized (though not required) to charge AQI user fees to cover program costs, we found that the agencies have not taken the necessary steps to ensure that user fees cover AQI costs. Consequently, the agencies had to use other authorized funding sources to pay for the program. Also, because of weaknesses in the design of CBP's new financial management system, CBP was unable to provide APHIS with information on the actual costs of the AQI program by user-fee type--for example, fees paid by international air passengers. APHIS uses this information to set future user-fee rates. Finally, in fiscal years 2004 and 2005, APHIS did not transfer AQI funds to CBP as agreed to by both agencies, causing some ports of entry to reduce spending on inspection activities in fiscal year 2005.

section_title: Letter
paragraphs: Agriculture—the largest industry and employer in the United States,  generating more than $1 trillion in economic activity annually—is  threatened by the entry of foreign pests and disease that can harm the  economy, the environment, plant and animal health, and public health. The  U.S. Department of Agriculture (USDA) estimates that these biological  invaders cost the American economy tens of billions of dollars annually in  lower crop values, eradication programs, and emergency payments to  farmers. As we reported in 2005, the terrorist attacks of September 11,  2001, have heightened concerns about agriculture’s vulnerability to  terrorism, including the deliberate introduction of livestock, poultry, and  crop diseases. To safeguard U.S. agriculture from the catastrophic  economic losses that would likely result from accidental or deliberate  introduction of a foreign pest or disease such as avian influenza or foot- and-mouth disease, Department of Homeland Security (DHS) agriculture  specialists work at ports of entry to inspect passengers, baggage, cargo,  and mail entering the country in airplanes, ships, trucks, and railcars for  prohibited agricultural materials that may serve as carriers of these pests  and disease.
Since the early 1900s, USDA was responsible under its Agricultural  Quarantine Inspection (AQI) program for inspecting agricultural products  entering the country. Following the events of September 11, 2001, the  Congress passed the Homeland Security Act of 2002, transferring USDA’s  Animal and Plant Health Inspection Service (APHIS) port inspection  activities and those of other federal inspection agencies responsible for  monitoring the entry of passengers and cargo into the United States—the  Department of the Treasury’s U.S. Customs Service and the Department of  Justice’s Immigration and Naturalization Service—to the newly created  Department of Homeland Security Customs and Border Protection (CBP).
Beginning in March 2003, more than 1,800 frontline agriculture specialists  who had formerly reported to APHIS became CBP employees, as CBP  incorporated the protection of U.S. agriculture into its primary  antiterrorism mission. Unlike the other former federal inspection  agencies, which were moved to DHS in their entirety, APHIS continues to  exist within USDA and retains responsibility for domestic animal and plant  programs and several AQI program activities, such as setting inspection  policy, providing training, and collecting AQI user fees.
Responding to concerns that the transfer of agricultural inspections from  APHIS to CBP could shift the focus away from agriculture to other DHS  priorities, the conference report accompanying the Consolidated  Appropriations Act for Fiscal Year 2005 requested that we report on  coordination between USDA and DHS to ensure that U.S. agriculture is  protected from accidentally or intentionally introduced pests and disease.  We also received a request from the Ranking Member of the Senate  Agriculture, Nutrition, and Forestry Committee to evaluate AQI inspection  issues. As agreed with your offices, we are presenting our responses to  both requests in this report.
This report assesses (1) the extent to which USDA and DHS have changed  the Agricultural Quarantine Inspection program since the transfer of  responsibilities from USDA to DHS, (2) how the departments have  managed and coordinated their responsibilities, and (3) how funding for  agricultural inspections has been managed since the transfer from USDA to  DHS.
To address these objectives, we surveyed a nationally representative  sample of agriculture specialists about their work experiences since the  transfer; analyzed APHIS’s inspection and interception data for fiscal years  2000 through 2005; visited agriculture training facilities in Florida, Georgia,  and Maryland; and reviewed interagency agreements related to the AQI  program and other documentation, such as staffing information, training  materials, budget information, and financial systems that CBP uses to track  AQI-related costs. We also interviewed key program officials at APHIS and  CBP headquarters and field offices. We performed a reliability assessment  of the data we analyzed and determined that the data were sufficiently  reliable for the purposes of this report. More details on our scope and  methodology appear in appendix I. We conducted our review from April  2005 through March 2006 in accordance with generally accepted  government auditing standards.
subsections: section_title: Background
paragraphs: Agricultural inspections at U.S. ports of entry had been the responsibility of  USDA since 1913. Following the events of September 11, 2001, the  Congress passed the Homeland Security Act of 2002, which combined the  inspection activities of the Department of the Treasury’s Customs Service,  the Department of Justice’s Immigration and Naturalization Service, and  APHIS into the newly created DHS Customs and Border Protection (CBP).  Among other things, the act (1) transferred, to the Department of  Homeland Security, APHIS’s responsibility for inspecting passenger  declarations and cargo manifests, international air passengers, baggage,  cargo, and conveyances and holding suspect articles in quarantine to  prevent the introduction of plant or animal diseases; and (2) authorized  USDA to transfer up to 3,200 agricultural quarantine inspection (AQI)  personnel to DHS.
The Secretaries of the Department of Homeland Security (DHS) and the  United States Department of Agriculture (USDA) signed a memorandum of  agreement in February 2003, agreeing to work cooperatively to implement  the relevant provisions of the Homeland Security Act of 2002 and to ensure  necessary support for and coordination of the AQI program functions. The  agreement detailed how the AQI program was to be divided, with some  functions transferred to DHS and others retained by USDA. Agricultural  import and entry inspection functions transferred to DHS included (1)  reviewing passenger declarations and cargo manifests and targeting for  inspection high-risk agricultural passenger/cargo shipments; (2) inspecting  international passengers, luggage, cargo, mail, and means of conveyance;  and (3) holding suspect cargo and articles for evaluation of plant and  animal health risk in accordance with USDA regulations, policies, and  guidelines. Functions remaining in USDA included (1) providing risk- analysis guidance, including in consultation with DHS, and the setting of  inspection protocols; (2) applying remedial measures other than  destruction and re-exportation, such as fumigation, to commodities,  conveyances, and passengers; and (3) providing pest identification services  at plant inspection stations and other facilities. The parties agreed to  cooperate in the financial management functions, including development  of annual plans and budgets, AQI user fees, and funds control and financial  reporting procedures.
To carry out its new inspection responsibilities, CBP established a “One  Face at the Border” initiative, which unified the customs, immigration, and  agricultural inspection processes by cross-training CBP officers and  agriculture specialists to (1) prevent terrorists, terrorist weapons, and  contraband from entering the United States; (2) identify people seeking to  enter the United States illegally and deny them entry; and (3) protect U.S.  agricultural and economic interests from harmful pests and diseases.
Unlike the Customs Service and the Immigration and Naturalization  Service, which were moved to DHS in their entirety, APHIS continues to  exist within USDA and retains responsibility for conducting veterinary  inspections of live imported animals; establishing policy for inspections  and quarantines; providing risk analysis; developing and supervising  training on agriculture for CBP agriculture specialists; conducting  specialized inspections of plant or pest material; identifying agricultural  pests; and collecting AQI user fees. CBP and APHIS agreed to support their  respective AQI duties by sharing funds from USDA-collected AQI user fees  levied on international air passengers, commercial aircraft, ships, trucks,  and railroad cars.
CBP agriculture specialists are assigned to 161 of the 317 ports of entry that  CBP staffs. As shown in figure 1, these ports collectively handle thousands  of sea containers and aircraft and over a million passengers each day.
Each port of entry can comprise one or more facilities—airports, seaports,  or land border crossings—where CBP officers and agriculture specialists  process arriving passengers and cargo. For example, the port of Buffalo,  New York, has an airport and land border inspection facilities, whereas the  Port of Atlanta has only the Atlanta Hartsfield/Jackson International  Airport. Individual port directors are responsible for overseeing port  operations and assigning agriculture specialists to specific port facilities.  The ports are organized into 20 district field offices, each with a director of  field operations who is responsible for the operation of multiple ports in a  given geographic area and serves as a liaison between CBP headquarters  and port management.
Day-to-day operations for agriculture specialists may include inspecting  pedestrians, passengers, cargo, and vehicles for pests and contraband.  Such inspections generally follow a two-stage process—primary and  secondary inspections. Figure 2 shows the passenger inspection process at  an international airport, as an example.
A primary inspection could include questioning passengers about their  origin and destination, reviewing their written declarations, and screening  their baggage with detector dogs to determine whether to refer the  passengers for a secondary inspection. A secondary inspection involves a  more detailed questioning of the passenger and an examination of their  baggage by X-ray and, if necessary, by hand search. Procedures for  inspecting commercial shipments vary according to factors such as the  type of agricultural product, risk level associated with the product, and  country of origin. To reduce the risk of foreign pests and disease entering  the United States, agriculture specialists review cargo documents to select  shipments for more detailed physical inspection.
The Food, Agriculture, Conservation, and Trade Act of 1990, as amended  (FACT Act), authorizes APHIS to set and collect user fees for AQI services  provided in connection with the arrival of international air passengers and  conveyances (e.g., commercial aircraft and trucks) at a port in the customs  territory of the United States. The six AQI user fees are assessed on  international air passengers, commercial aircraft, commercial vessels,  commercial trucks, commercial truck decals, and commercial railroad  cars. These user fees are paid directly by shipping companies or indirectly  by air passengers through taxes on tickets. The international passenger and  commercial aircraft fees are calculated and remitted quarterly by the  individual airline companies to USDA, while rail car fees are remitted  monthly. CBP collects the commercial vessel, truck, and truck decal fees at  the time of inspection. International air passengers and commercial  conveyances entering the United States from Canada are exempt from the  user fees. The FACT Act authorizes user fees for (1) providing AQI services  for the conveyances, cargo, and passengers listed above; (2) providing  preclearance or preinspection at a site outside the customs territory of the  United States to international airline passengers, commercial vessels,  commercial trucks, commercial railroad cars, and commercial aircraft; and  (3) administering the AQI user-fee programs.
AQI user fees have been revised several times since the FACT Act was  passed in 1990. In November, 1999, APHIS published a final rule in the  Federal Register that amended the user-fee regulations by adjusting the  fees charged for certain AQI services for part of fiscal year 2000 and for  fiscal years 2001 and 2002. The user-fee adjustments were intended to  ensure that APHIS covered the anticipated actual cost of providing AQI  services. Subsequent rule making, culminating in a final rule published in  the Federal Register on January 24, 2003, extended the adjusted fees indefinitely, beyond fiscal year 2002, until the fees are revised again. On  December 9, 2004, APHIS published an interim rule to raise user fees,  effective January 1, 2005.
section_title: CBP and APHIS Have Taken Steps to Strengthen the Agricultural Quarantine Inspection Program
paragraphs: Since the transfer of agricultural quarantine inspections to CBP, the agency  has increased training in agricultural issues for CBP officers and developed  a national standard for in-port training. In addition, CBP and APHIS have  enhanced the ability of agriculture specialists to better target inspections at  the ports. The two agencies also established a joint program to review the  agricultural inspections program on a port-by-port basis, and CBP created  new agricultural liaison positions at the field office level to advise regional  port directors on agricultural issues.
subsections: section_title: CBP and APHIS Have Expanded Training on Agriculture Issues
paragraphs: CBP has undertaken several training initiatives for CBP officers, whose  primary duty is customs and immigration inspection. Under CBP, newly  hired CBP officers receive 16 hours of training on agricultural issues at the  Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia.  Under APHIS, agriculture courses for Customs and Immigrations officers  had been limited to 4 hours and 2 hours, respectively, of classroom  overviews on agriculture issues. The revamped training provides the newly  hired CBP officers with basic agriculture information so they know when  to either prohibit entry or refer potential agricultural threats to CBP  agriculture specialists. In addition to a more comprehensive course, the  curriculum provides for additional testing on AQI knowledge. For example,  classroom simulations include agricultural items, and CBP officers’ written  proficiency tests now include questions on agricultural inspections.
In addition, CBP and APHIS have undertaken an initiative to expand  agriculture training for all CBP officers at their respective ports of entry.  The purpose of these modules—designed for Customs and Immigration  officers—was to provide officers with the ability to make informed  decisions on agricultural items at high-volume border traffic areas or to  facilitate the clearance of travelers and cargo at ports without agriculture  specialists, such as some ports of entry along the Canadian border.
According to agency officials, the agencies have now expanded training to  16 hours of lecture and 8 hours of on-the-job training, including  environment-specific modules for six inspection environments: northern  border, southern border, international mail/expedited courier, maritime,  airport processing, and preclearance (i.e., inspections of passengers and  cargo prior to arrival in the United States).
Additionally, CBP and APHIS have formalized the in-port training program  and have developed a national standard for agriculture specialists. Under  APHIS, depending on the port to which they were assigned, newly hired  agriculture specialists spent anywhere from 1 week to 1 year shadowing  senior agriculture specialists. After the transfer, CBP formalized this  process to ensure all agriculture specialists were receiving the necessary  on-the-job training. This formalized process includes a checklist of  activities for agriculture specialists to master and is structured in two  modules: an 8-week module on passenger inspection procedures and a 10- week module on cargo inspection procedures.
Based on our survey of agriculture specialists, we estimate that 75 percent  of specialists hired by CBP believe that they received sufficient training (on  the job and at the Professional Development Center) to enable them to  perform their agriculture inspection duties. An estimated 13 percent of  specialists believe that they probably or definitely did not receive adequate  training, and another 13 percent either were uncertain or did not answer  the question. (See app. II, survey question 12.)
section_title: CBP and APHIS Have Taken Steps to Improve Targeting of Agricultural Inspections
paragraphs: CBP and APHIS have also taken steps to better identify and target  shipments and passengers that present potentially high risk to U.S.  agriculture. Under CBP, some agriculture specialists receive training and  access to computer applications such as CBP’s Automated Targeting  System (ATS), which is a computer system that, among other things, is  meant to (1) identify high-risk inbound and outbound passengers and cargo  for terrorist links, smuggling of WMD, drugs, currency, and other  contraband; (2) focus limited inspection resources on higher-risk  passengers and cargo; (3) facilitate expedited clearance or entry for low- risk passengers and cargo; and (4) enable users to create ad-hoc queries to filter data to meet specific research needs. ATS helps agriculture  specialists select which cargo shipments to inspect based on detailed  information contained in the cargo manifests and other documents that  shipping companies are required to submit before the ship arrives in a port.  CBP and APHIS headquarters personnel also use ATS data to identify  companies that have violated U.S. quarantine laws. For example, recently  the two agencies used ATS to help identify companies that have smuggled  poultry products in seafood containers from Asia, according to a senior  APHIS official. The U.S. currently bans uncooked poultry products from  Asian countries because of concerns over avian influenza.
CBP and APHIS are working together to further refine ATS’s effectiveness  in identifying and targeting shipments of agricultural products. Specifically,  APHIS assigned a permanent liaison to the CBP National Targeting Center  in April 2005 to help develop a rule set (a computerized set of criteria) that  will automate the process of identifying companies or individuals that pose  a significant agroterrorism risk to U.S. agriculture. According to the APHIS  liaison, the rule set will eventually be applicable to nonagroterrorism  events, such as smuggling and shipments that are not compliant with U.S.  quarantine regulations. CBP officials told us that the agency has set a  September 2006 release date for the first version of the rule set. CBP  officials also told us that the agency is testing an interim rule set for high- risk commodities regulated by USDA’s Food Safety Inspection Service  (FSIS) that they expect to release in July 2006.
In addition to ATS, agriculture specialists now also have access to the  Treasury Enforcement Communications System (TECS)—a computerized  information system for identifying individuals and businesses suspected of  violating federal law. TECS serves as a communications system between  Treasury law enforcement offices and other federal, state, and local law  enforcement agencies.
ATS and TECS complement other targeting tools already used by  agriculture specialists under APHIS. Specifically, agriculture specialists  continue to use CBP’s Automated Commercial System to review the  manifests of incoming shipments. At select ports, agriculture specialists  also continue to use APHIS’s Agricultural Quarantine Inspection  Monitoring (AQIM) system to estimate the amount of quarantine items or  pests entering the country. CBP agriculture specialists submit AQIM data to  APHIS, where it is used to estimate the extent to which agricultural pests  and diseases approach the United States through various pathways (e.g.,  international air passengers).
section_title: CBP and APHIS Have Established a Review Process for Assessing Port Compliance with Agricultural Inspection Policy
paragraphs: In fiscal year 2005, CBP and APHIS established a formal assessment  process to ensure that ports of entry continue to carry out agricultural  inspections in accordance with APHIS’s regulations, policies, and  procedures. According to an APHIS official, the new formal assessment  process is a means for APHIS to gather some of the information necessary  to formulate agricultural inspection policy. The assessments, called Joint  Agency Quality Assurance Reviews, entail a visit to ports by APHIS and  CBP officials, who complete a questionnaire based on interviews with the  port director and other CBP personnel and through direct observation of  port operations by the review team. The reviews cover topics such as (1)  coordination with other federal agencies, (2) training for agriculture  specialists, (3) access of agriculture specialists to regulatory manuals, and  (4) processes for handling violations at the port, inspecting passenger  baggage and vehicles, and intercepting, seizing, and disposing of  confiscated materials.
The review teams report on best practices and deficiencies at each port and  make recommendations for corrective actions. For example, a review of  two ports found that they were both significantly understaffed, and that  CBP agriculture specialists at one of the ports were conducting superficial  inspections on commodities that should have been inspected more  intensely. At the same ports, the review identified best practices in the  placing of personnel from CBP, APHIS, and FDA in the same facility and the  targeting of tile imports from Italy and Turkey for possible agroterrorism  risks. As of February 2006, the joint review team has conducted reviews  of nine ports, and the agencies plan to complete seven additional reviews in  fiscal year 2006, according to a senior APHIS official.
section_title: CBP Has Established New Agriculture Liaisons to Advise Regional Directors
paragraphs: In May 2005, CBP required that each director in its 20 field offices identify  and appoint an agriculture liaison, with background and experience as an  agriculture specialist, to provide CBP field office directors with agriculture- related input for operational decisions and provide agriculture specialists  with senior-level leadership. CBP officials told us that all district field  offices had established the liaison position as of January 2006. The CBP  agriculture liaison duties include, among other things, advising the director  of the field office on agricultural functions; providing oversight for data  management, statistical analysis, and risk management; and providing  oversight and coordination for agriculture inspection alerts.
Since the creation of the position, agriculture liaisons have begun to  facilitate the dissemination of urgent alerts from APHIS to CBP. For  example, following a large increase in the discovery of plant pests at a port  in November 2005, the designated agriculture liaison sent notice to APHIS,  which then issued alerts to other ports. Subsequent communications  between APHIS and CBP identified the agriculture liaison at the initial port  as a contact for providing technical advice for inspecting and identifying  this type of plant pest.
section_title: Management and Coordination Problems May Leave U.S. Agriculture Vulnerable to Foreign Pests and Disease
paragraphs: Several management and coordination problems exist that may leave U.S.  agriculture vulnerable to foreign pests and disease. CBP has not developed  sufficient performance measures to manage and evaluate the AQI program.  CBP also has not developed a staffing model to determine how to allocate  newly hired agriculture specialists or used available data to evaluate the  effectiveness of the AQI program. In addition, information sharing and  coordination between CBP and APHIS has been problematic. Finally, the  agriculture canine program has deteriorated.
subsections: section_title: CBP Lacks Adequate Performance Measures for Agricultural Quarantine Inspections
paragraphs: The Government Performance and Results Act of 1993 requires federal  agencies to develop and implement appropriate measures to assess program performance. Yet, 3 years after the transfer, CBP has yet to  develop and implement its own performance measures for the AQI  program despite changes in the program’s mission. Instead, according to  senior CBP officials, CBP carried over two measures that APHIS used to  assess the AQI program before the transfer: the percentage of (1)  international air passengers and (2) border vehicle passengers that comply  with AQI regulations. However, these measures address only two  pathways, neglecting commercial aircraft, vessel, and truck cargo  pathways. CBP’s current performance measures also do not provide  information about changes in inspection and interception rates, which  could prove more useful in assessing the efficiency and effectiveness of  agriculture inspections in different regions of the country or at individual  ports of entry. They also do not address the AQI program’s expanded  mission—to prevent agroterrorism while facilitating the flow of legitimate  trade and travel. CBP officials told us that the agency recognizes that the  current performance measures are not satisfactory and is planning new  performance measures for the fiscal year 2007 performance cycle.  However, such measures had not yet been developed at the time of our  review.
section_title: CBP Made Progress Hiring Agriculture Specialists but Still Lacks a Risk-Based Staffing Model
paragraphs: To accomplish the split in AQI responsibilities in March 2003, APHIS  transferred a total of 1,871 agriculture specialist positions, including 317  vacancies, and distributed these positions across CBP’s 20 district field  offices. According to senior officials involved with the transfer, APHIS’s  determinations were made under tight time frames and required much  guess work. As a result, from the beginning, CBP lacked adequate numbers  of agriculture specialists and had little assurance that the appropriate  numbers of specialists were staffed at the ports of entry. Since then, CBP  has hired more than 630 specialists, but the agency has not yet developed  or used a risk-based staffing model for determining where to assign its  agriculture specialists.
Our guidelines for internal control in the federal government state that  agencies should have adequate mechanisms in place to identify and analyze  risks and determine what actions should be taken to mitigate them. One  such risk involves the changing nature of international travel and  agricultural imports, including changes to the (1) volume of passengers and  cargo, (2) type of agricultural products, (3) countries of origin, and (4)  ports of entry where passengers and cargo arrive in the United States. One  action to mitigate risk is development and implementation of a staffing  model to help determine appropriate staffing levels to address these  changing operating conditions.
APHIS developed a staffing model, prior to the transfer of AQI functions to  CBP, to calculate the number of agriculture specialists necessary to staff  the various ports according to work load. However, according to APHIS  officials, the model was no longer useful because it had not considered the  split of inspectors between the two agencies. Although APHIS updated the  model in June 2004 at CBP’s request, CBP still did not use this or any other  staffing model when assigning the newly hired specialists to the ports.  According to CBP officials, the agency did not use APHIS’s model because  it did not consider some key variables, such as the use of overtime by  staff. CBP officials also told us the agency is planning to develop its own  staffing model, but they were unable to provide us with planned milestones  or a timeline for completion. Until such a risk-based model is developed  and implemented, CBP does not know if it has an appropriate number of  agriculture specialists at each port.
An area of potential vulnerability that should be considered in staffing the  ports relates to the experience level of agriculture specialists at the ports.  More than one-third of CBP agriculture specialists were hired since the  transfer—and most within the last year. For example, San Francisco lost 19  specialists since 2003 but gained only 14 new hires or transfers, leaving 24  vacancies as of the end of fiscal year 2005. APHIS officials expressed  concern about the turnover of staff at some ports because many of the  newly hired CBP agriculture specialists “will need time to get up to speed  and do not possess the institutional knowledge related to agricultural  issues that the more seasoned specialists had.” The official added that the  experience level of specialists is of particular concern at ports of entry  staffed by only 1 or 2 agriculture specialists.
section_title: CBP Has Not Used Key Data to Evaluate Effectiveness of AQI Program
paragraphs: According to APHIS, data in its Work Accomplishment Data System  (WADS) can help program managers evaluate the performance of the AQI  program by indicating changes in a key measure—the frequency with  which prohibited agricultural materials and reportable pests are found  (intercepted) during inspection activities. CBP agriculture specialists  routinely record data in WADS for each port of entry, including monthly  counts of (1) arrivals of passengers and cargo to the United States via  airplane, ship, or vehicle; (2) agricultural inspections of arriving passengers  and cargo; and (3) inspection outcomes (i.e., seizures or detections of  prohibited (quarantined) agricultural materials and reportable pests).  However, CBP has not used this data to evaluate the effectiveness of the  AQI program. Our analysis of the data shows that average inspection and  interception rates have changed significantly in some geographical regions  of the United States, with rates increasing in some regions and decreasing  in others (see tables 1 and 2).
Table 1 compares average inspection rates—the number of passenger and  cargo inspections relative to the total number of arrivals in each CBP  district field office—for the 42 months before and 31 months after the  transfer. Average inspection rates declined significantly in five district field  offices (Baltimore, Boston, Miami, San Francisco, and “Preclearance” in  Canada, the Caribbean, and Ireland), whereas rates increased significantly  in seven other districts (Buffalo, El Paso, Laredo, San Diego, Seattle,  Tampa, and Tucson).
Similarly, table 2 compares average interception rates—the number of pest  interceptions relative to the total number of passenger and cargo  inspections in each CBP district field office—for the two periods of time.  The average rate of interceptions decreased significantly at ports in six  district field offices—El Paso, New Orleans, New York, San Juan, Tampa,  and Tucson—while average interception rates have increased significantly  at ports in the Baltimore, Boston, Detroit, Portland, and Seattle districts.  Decreases in interception rates, in particular, may indicate that some CBP  districts are less effective at preventing entry of prohibited materials since  the transfer from APHIS to CBP.
Of particular note are three districts that have experienced a significant  increase in their rate of inspections and a significant decrease in their  interception rates since the transfer. Specifically, since the transfer, ports in  the Tampa, El Paso, and Tucson districts appear to be more efficient at  inspecting (e.g., inspecting a greater proportion of arriving passengers or  cargo) but less effective at interceptions (e.g., intercepting fewer  prohibited agricultural items per inspection). Also of concern are three  districts—San Juan, New Orleans, and New York—that are inspecting at  about the same rate, but intercepting less, since the transfer.
When we showed the results of our analysis to senior CBP officials, they  were unable to provide an explanation for these changes or to determine  whether the current rates were appropriate relative to the risks, staffing  levels, and staffing expertise associated with individual districts or ports of  entry. These officials also noted that CBP has had problems interpreting  APHIS data reports because CBP lacks staff with expertise in agriculture  and APHIS’s data systems in some district offices. CBP is working on a plan  to collect and analyze agriculture-related data in the system it currently  uses for customs inspections, but the agency has yet to complete or  implement the plan.
section_title: Information Sharing and Coordination between CBP and APHIS Have Been Problematic
paragraphs: CBP and APHIS have an interagency agreement for sharing changes to  APHIS’s policy manuals and agriculture inspection alerts, which impact  CBP’s agricultural mission. APHIS maintains several manuals on its Web  site that are periodically updated for agriculture specialists’ use. These  manuals include directives about current inspection procedures as well as  policies about which agricultural items from a particular country are  currently permitted to enter the United States. When APHIS updates a  manual, the agency sends advance notice to CBP headquarters personnel,  but agriculture specialists in the ports frequently do not receive these  notices. Before the transfer of agriculture specialists to CBP, APHIS e- mailed policy manual updates directly to specialists, according to a senior  APHIS official. However, since the transfer, CBP has not developed a list of  all agriculture specialists’ e-mail addresses. As a result, APHIS uses an “ad- hoc e-mail list” to notify CBP agriculture specialists of policy manual  updates. When an agriculture specialist or supervisor sends an e-mail to the  APHIS official who maintains the contact list, that person’s e-mail address  is then manually added to the list. The official also noted he has added e- mail addresses sent in by former APHIS personnel who noticed that they  were no longer receiving manual update notifications, as they had prior to  the transfer to CBP. However, the official also stated that his list is not an  official mailing list and is not representative of all of the ports. CBP also  could not tell us if the list was accurate or complete.
Several agriculture specialists we spoke with indicated that they (1)  frequently did not receive any notification from APHIS or CBP when  manuals were updated, (2) received updates sporadically, or (3) were  unsure whether they received all of the relevant updates. Moreover, based  on our survey of agriculture specialists, we estimate that 20 percent of  agriculture specialists do not regularly receive notices that the manuals  have been updated. According to our survey, 50 percent of agriculture  specialists always have access to the online manuals. However, according  to specialists we spoke with, it is difficult to keep up with changes to the  manuals without being notified as to which policies or procedures are  updated by APHIS. One inspector expressed dismay that specialists at the  port to which he had recently transferred were unaware of new regulations  for conducting inspections to safeguard against avian influenza.  Agriculture specialists at a different port told us that they continue to refer  to the hard copies of APHIS’s manuals, which APHIS has not updated since  it stopped producing hard copies in 2003.
In addition, although CBP and APHIS have established a process to  transmit inspection alerts down the CBP chain of command to agriculture  specialists, many frontline specialists we surveyed or interviewed at the  ports were not always receiving relevant agriculture alerts in a timely  manner. They identified the time required for dissemination of agriculture  alerts down the CBP chain of command as an issue of concern. Specifically,  based on our survey, we estimate that only 21 percent of specialists always  received these alerts in a timely manner. The level of information sharing  appears to be uneven between ports and pathways at ports. For example,  an agricultural specialist at one port told us that he received information  directly from APHIS on pest movements and outbreaks. An agriculture  supervisor at a second port noted that information sharing had improved  after port officials established a plant pest risk committee comprising local  officials from APHIS, CBP, and other agencies. However, an agriculture  specialist at a third port we visited told us that specialists there did not  receive any information on pests from APHIS, while a second specialist at  the same port expressed concern that alerts on disease outbreaks such as  avian influenza arrive many days after the outbreaks are first reported.
With regard to coordination between CBP and APHIS, we found that APHIS  officers responsible for tracing the pathways of prohibited agricultural  items into the United States have experienced difficulty or delays in gaining  access to some ports of entry. After the transfer, APHIS and CBP agreed to  restrict APHIS officials’ access to ports of entry to ensure clear separation  of responsibilities between the two agencies. Under the memorandum of  agreement, CBP may grant or refuse access to ports by APHIS personnel,  but APHIS officials noted that the difficulties and delays in getting  information from the ports has made some of APHIS’s Smuggling  Interdiction and Trade Compliance (SITC) activities difficult, if not  impossible. Per the agreement, APHIS personnel—including SITC  inspectors—are to make advance arrangements with local CBP port  directors for access to agriculture inspection areas. CBP agreed to provide  APHIS with a written response to any request for access to ports of entry  but did not specify a time frame for this response.
Prior to the transfer, APHIS SITC inspectors regularly worked with APHIS  agriculture inspectors to (1) trace the movement of prohibited agricultural  items found in U.S. markets back to ports of entry (traceback), (2) identify  parties responsible for importing prohibited items, and (3) determine  which weaknesses in inspection procedures allowed the items to enter the  United States. Currently, SITC inspectors are still responsible for tasks  such as surveying local markets for prohibited agricultural products and  gathering information to identify and intervene in the movement of  smuggled agricultural commodities that could potentially harm U.S.  agriculture. According to SITC officials, their ability to gather timely  information at ports of entry is extremely important to SITC’s mission.  They added that delays in special operations or port visits following the  discovery of prohibited items make it much harder to trace the pathway of  such items into the United States.
Although SITC officials noted that their inspectors have received access to  some ports to perform their duties, they added that CBP has delayed or  denied access to SITC inspectors at other ports in both the eastern and  western United States. The SITC officials stated that there have been  incidents in which CBP did not respond to requests for access until months  after APHIS made them. For example, in 2005, SITC requested permission  to conduct two special operations at U.S. international airports to help  determine whether passengers or cargo from certain countries posed a risk  in importing or smuggling poultry products that could be infected with  avian influenza. In justifying the operations, SITC wrote, “Many illegal and  possibly smuggled avian products have been seized” in several states  surrounding the airports. In one case, CBP took 3 months to approve the  request; however, SITC had already canceled the operation 2 months  earlier because of CBP’s lack of response. CBP approved another special  operation several months after SITC’s request, but later canceled it because  SITC uniforms did not match CBP specialists’ uniforms, according to  senior SITC officials. They added that CBP’s other reasons for delaying or  canceling joint operations and visits included (1) inadequate numbers of  CBP specialists to participate in operations, (2) scheduling conflicts  involving CBP port management, and (3) concerns about SITC inspectors’  lack of security clearances.
section_title: Agriculture Canine Program Has Deteriorated
paragraphs: Agriculture canines are a key tool for targeting passengers and cargo for  inspection, but we found that the program has deteriorated since the  transfer. The number and proficiency of canine teams has decreased  substantially over the last several years. Specifically, APHIS had  approximately 140 canine teams nationwide at the time of the transfer, but  CBP currently has approximately 80 such teams, about 20 percent of which  are newly hired, according to agency officials. They added that, although  CBP has authorized the hiring of 15 more agriculture canine teams, the  positions remain vacant as of the end of 2005. According to APHIS, CBP  has not been able to fill available APHIS agriculture specialist canine  training classes. After consulting with CBP, APHIS scheduled 7 agriculture  canine specialist training classes in fiscal year 2005 but canceled 2 because  CBP did not provide students. Similarly, in fiscal year 2006, APHIS  scheduled 8 classes, but, as of April, had to cancel 3 for lack of students to  train. In 2005, 60 percent of the 43 agriculture canine teams tested failed the  USDA proficiency test, and APHIS officials told us proficiency has declined  since the transfer. These proficiency tests, administered by APHIS, require  the canine to respond correctly in a controlled, simulated work  environment and ensure that canines are working effectively to catch  potential prohibited agricultural material.
Potential reasons for the deterioration in proficiency scores include CBP  not following policy and procedures for the canine program and changes in  the program management structure. The policy manual for the canine  program states that canines should (1) receive about 4 hours of training per  week and (2) have minimal down time in order to maintain their  effectiveness. In general, canine specialists we interviewed expressed  concern that the proficiency of their canines was deteriorating due to a  lack of working time. That is, the dogs were sidelined while the specialist  was assigned to other duties. Furthermore, based on results of our survey,  we estimate that 46 percent of canine specialists were directed to perform  duties outside their primary canine duties several times a week or every  day. Additionally, an estimated 65 percent of canine specialists sometimes  or never had funding for training supplies. Another major change to the  canine program, following the transfer, was CBP’s elimination of all former  APHIS canine management positions. In some cases, agriculture canine  teams now report to supervisory agriculture specialists, who may not have  any canine experience. Formerly, canine teams reported to both the in-port  management and regional canine program coordinators, who were  experienced canine managers. The program coordinators monitored the  canine teams’ proficiency and ensured that teams maintained acceptable  performance levels. According to CBP, the agency is considering  developing a new management structure to improve the effectiveness of its  canine program. However, little progress has been made to date.
section_title: Financial Management Issues at CBP and APHIS Adversely Affect the AQI Program
paragraphs: The law authorizes user fees to cover the costs of the AQI program.  However, in the 3 years since the transfer, user fees have not been  sufficient to cover AQI program costs. CBP believes that unless the  current user-fee rates are increased, the program will continue to face  annual shortfalls to the detriment of the AQI program. In addition, CBP  underwent a financial management system conversion for fiscal year 2005  and was unable to provide APHIS with actual cost information needed to  evaluate the extent to which individual user fees cover program costs.  Furthermore, APHIS did not always make regular transfers of funds to CBP  as it had agreed to, causing CBP to use other funding sources or to reduce  spending.
subsections: section_title: User Fees Have Not Been Sufficient to Cover AQI Program Costs
paragraphs: The Secretary of Agriculture has the discretion to prescribe user fees to  cover the costs of the AQI program, but program costs have exceeded user- fee collections since the transfer of AQI inspection activities to CBP.  Following the events of September 11, 2001, a sharp drop in the number of  international airline passengers entering the United States caused a drop in  AQI revenue (approximately 80 percent of total AQI user-fee collections  come from fees on international airline passengers). Despite the drop in  revenue, APHIS had to increase AQI inspection activities because of post- September 11 concerns about the threat of bioterrorism. According to  USDA, agriculture specialists began inspecting a greater volume of cargo  entering the United States and a greater variety of types of cargo than they  had in prior years. Such operations are personnel-intensive and, therefore,  costly. Consequently, when the transfer occurred in fiscal year 2003, AQI  program costs exceeded revenues by almost $50 million. The shortfall  increased to almost $100 million in the first full fiscal year after the  transfer. Table 3 provides AQI user-fee collections and program costs for  fiscal years 2001 through 2005.
For fiscal years 2004 and 2005, the 2 full fiscal years since the transfer, total  AQI costs exceeded user-fee collections by more than $125 million.  Consequently, in fiscal years 2004 and 2005, APHIS used AQI user-fee  collections from previous years, and CBP used another available appropriation to cover AQI costs. In October 2004, APHIS’s Associate  Deputy Administrator of Plant Protection and Quarantine wrote to the  Executive Director of CBP’s Office of Budget, noting, “We are in dire need  of generating increased revenue for the AQI program; without an increase,  the AQI account could run out of money on or about July 19, 2005.” The  letter also discussed a three-phase approach to ensuring fiscal solvency for  the AQI program. The first phase consisted of establishing increased  interim user-fee rates to cover costs of pay raises and inflation. The second  phase involved removing the exemption from paying AQI user fees granted  to passengers, cargo, and commercial vehicles at ports of entry along the  U.S.—Canada border. The third phase included identifying all current and  future needs of the AQI program, not just pay raises and inflation, to ensure  that user fees fully cover AQI program costs. APHIS estimated that it would  take up to 2 years to complete the entire Federal Register process and  make new phase-three fees effective.
On December 9, 2004, APHIS proceeded with the first phase by publishing  an interim rule to raise user fees, effective January 1, 2005, through 2010.  However, because of the method APHIS used to estimate AQI program  costs, this phase-one increase in user-fee revenues is not likely to be  enough to cover program costs through fiscal year 2010. Specifically,  APHIS used estimated fiscal year 2004 program costs—$327 million—plus  1.5 percent of these costs for pay raises and inflation (or about $4.9 million)  to set the fiscal year 2005 user fees. However, APHIS’s base calculation  used CBP’s estimated share of fiscal year 2004 user-fee funds—totaling  $194 million—but not CBP’s actual reported costs for fiscal year 2004— totaling $222.5 million. Thus, the difference between CBP’s actual and  estimated costs of $28.5 million was not included in the base calculation,  resulting in less revenue for the program. CBP subsequently  acknowledged that APHIS’s decision not to include CBP’s actual fiscal year  2004 costs in the user-fee increase “has put CBP in the position where  incoming APHIS user-fee revenues fall short of the expected cost of  operating the  program.” CBP finance officials also told us that  because the costs of performing AQI activities was approximately $222  million in each of the previous 2 years, it is unlikely that the projected $211  million to be transferred to CBP for fiscal year 2006 will be sufficient to  cover program costs for fiscal year 2006 and beyond.
Despite the shortfall between user-fee collections and program costs,  APHIS has not completed the second or third phases of its proposal. As of  May 2006, the Secretary of Agriculture had not made a decision whether to  proceed with the proposal to lift the Canadian exemption. CBP officials  told us that unless the Canadian exemption is lifted, the agency cannot hire  the over 200 additional agriculture specialists that it has determined are  needed to perform additional inspections on the northern border. APHIS  officials told us that because lifting the Canadian exemption will affect  estimates of future revenue used in calculating new user-fee rates, APHIS  and CBP have not begun the third phase of revising user fees, which APHIS  estimates will take approximately 2 years.
section_title: CBP Could Not Provide APHIS with the Actual Cost Information
paragraphs: CBP is required by the interagency agreement to establish a process in its  financial management system to report expenditures by each AQI fee type,  such as those paid by international passengers and commercial aircraft.  APHIS uses this information to set user-fee rates and to audit user-fee  collections. Although CBP provided detailed cost information by activity  and user-fee type to APHIS for fiscal year 2004, CBP provided only  estimated cost information for fiscal year 2005 because of a weakness in  the design of the agency’s new financial management system. In November  2005, CBP conducted an internal review and determined that its reported  costs of almost $208 million did not include about $15 million in additional  salary costs for CBP agriculture supervisors. CBP officials told us that  these costs were not included, in large part, because the agency adopted a  new financial management system in fiscal year 2005 that allowed  agriculture supervisors to record their time spent on AQI activities in a  joint account that combined customs, immigration, and agricultural  quarantine inspection activities. Thus, the costs related to only agricultural  activities could not be segregated.
A senior CBP finance official told us that CBP’s Office of Finance could  have provided rough estimates of costs by activity to APHIS but chose not  to do so because they did not want to combine actual and estimated costs  in the same document. Instead, CBP provided estimates of cost by user-fee  type in January 2006. CBP did provide APHIS with the required accounting  of obligations incurred by program office (e.g., Office of Training and  Development, Applied Technology Division, Office of Asset Management,  and Office of Chief Counsel) and budget codes (e.g., salary, overtime, and  office supplies) for fiscal year 2005. However, a senior APHIS budget  official told us that this cost information was not helpful to APHIS for  reviewing the user-fee rates because they needed the breakdown of actual  costs by user-fee type and because APHIS could not determine if the costs  were accurate. Until CBP’s financial management system can provide  actual costs by activity and AQI user-fee type, APHIS will not be able to  accurately determine the extent to which the user fees need to be revised.  In addition, without such information, APHIS does not know whether  inspections of international airline passengers and commercial aircraft,  vessels, trucks, and railroad cars are being funded by revenue from the  appropriate user fee.
section_title: APHIS Did Not Always Make Regular Transfers of AQI Funds to CBP
paragraphs: Although many of the AQI functions were transferred to CBP when the  Department of Homeland Security was formed, APHIS continues to collect  most user fees and transfers a portion of the collections to CBP on a  periodic basis. For fiscal years 2004 and 2005, these transfers were often  delayed and their amounts were sometimes less than expected, which  adversely affected CBP agricultural inspection activities. In February 2004,  USDA and DHS agreed that APHIS would transfer one-fourth of the annual  amount of estimated user-fee collections to CBP at the beginning of each  quarter, or if the balance in the account was not sufficient to transfer the  full quarterly amount in advance, APHIS could make monthly transfers.  APHIS officials told us, however, that the agency chose to transfer funds to  CBP every other month because the AQI account would not always have  had sufficient funds to make quarterly transfers, and monthly transfers  would have been administratively burdensome. Nevertheless, as table 4  shows, CBP frequently did not receive the transfers at the time specified or  for the agreed upon amount in fiscal years 2004 and 2005. Consequently,  according to CBP officials, the agency’s finance office had to use funding  sources that they had planned to use for other purposes. In addition, CBP  officials told us some ports had to reduce spending for supplies needed for  inspection activities or delay hiring personnel or purchasing equipment.  Then, for the last transfer of the fiscal year, APHIS did not notify CBP until  August 2005 that the transfer would total $43.9 million, about $11 million  more than expected (see table 4). As a result, CBP’s budget plans had to be  revised late in the year to accommodate this additional funding.
In addition, technical difficulties in the fund transfer process also delayed  the transfer of funds to CBP, and at one point during fiscal year 2004, CBP  did not have available funding from user fees for over 6 months. In this  instance, APHIS transferred $88.5 million from October 2003 to February  2004 into a DHS Treasury account used for fiscal year 2003 transfers.  However, APHIS officials told us that the Office of Management and Budget  had established a new Treasury account for CBP, and CBP officials did not  advise APHIS of the change. Ultimately, APHIS withdrew the funds from  the original account and transferred them as part of the April 2004 transfer,  which totaled $118 million, but it took longer than 5 months to resolve the  issue. Similarly, two other fund transfers were delayed in fiscal year 2005  because APHIS did not comply with a Treasury rule requiring that agencies  cite the relevant statutory authority when submitting a request to transfer  funds to another agency. In one instance, APHIS ultimately transferred  $65.6 million to CBP in February 2005 rather than transferring one payment  in January 2005 for $32.8 million and another payment in February 2005 for  $32.8 million.
In October 2005, APHIS and CBP revised their agreement, which outlined  the process the agencies would follow for transferring user fees and the  financial reporting on the use of those funds. Under the revised agreement,  APHIS, beginning in November 2005, is to make 6 bimonthly transfers to  CBP in fiscal year 2006 totaling $211.1 million. Figure 3 illustrates the  process APHIS uses to collect user fees and transfer funds to CBP for fiscal  year 2006.
As shown in figure 3, APHIS was to transfer $35,186,667 to CBP in  November 2005. However, contrary to the new agreement, APHIS  transferred $35,166,667—$20,000 less than CBP expected—on November  30, 2005. When asked why they did not receive the correct amount in  accordance with the revised agreement, CBP officials agreed to investigate  the discrepancy and found that their staff was working to correct the  problem. APHIS officials told us that their budget office used a rounded  amount of $211 million for the fiscal year to distribute the payments,  resulting in the $20,000 shortage for the distribution. APHIS officials told us  that the budget office did not have a copy of the current distribution  schedule from the revised agreement and did not know the exact amount of  the required payment. They also stated that the budget office now has the  agreement and will make the proper bimonthly transfers going forward.  According to APHIS officials, the January 2006 transfer included an  additional $20,000 to address the discrepancy we identified with the  November transfer. APHIS and CBP believe that the revised agreement,  which also provides for quarterly face-to-face meetings between the  agencies, should improve communication, assure transparency in the  transfer process, and prevent future problems in the transfer of funds.
section_title: Conclusions
paragraphs: The global marketplace and increased imports of agricultural products and  international travelers into the United States have increased the number of  pathways for the movement and introduction of foreign, invasive  agricultural pests and diseases, such as avian influenza and foot-and-mouth  disease. Maintaining the effectiveness of federal programs to prevent  accidental or deliberate introduction of potentially destructive organisms is  critical given the importance of agriculture to the U.S. economy.  Accordingly, effective management of AQI programs is necessary to ensure  that agriculture issues receive appropriate attention in the context of CBP’s  overall missions of detecting and preventing terrorists and terrorist  weapons from entering the United States and facilitating the orderly and  efficient flow of legitimate trade and travel.
Although the transfer of agricultural quarantine inspections from USDA’s  APHIS to DHS’s CBP has resulted in some improvements as a result of the  integration of agriculture issues into CBP’s overall antiterrorism mission,  significant coordination and management issues remain that leave U.S.  agriculture vulnerable to the threat of foreign pests and disease. Because  the Homeland Security Act of 2002 divided AQI responsibilities between  USDA and DHS, the two departments must work more closely to address  key coordination weaknesses, including enhancing communication  between APHIS’s AQI policy experts and CBP’s agriculture specialists in  the field, to ensure that critical inspection information reaches these  frontline inspectors; to review policies and procedures for the agriculture  canine program to improve the effectiveness of this key inspection tool;  and to revise AQI user fees. Furthermore, both departments must work to  address key management weaknesses in their respective areas of  responsibility. Specifically, in light of the AQI program’s expanded mission,  DHS needs to develop and adopt meaningful performance measures to  assess the AQI program’s effectiveness at intercepting prohibited  agricultural materials; implement a national risk-based staffing model to  ensure that adequate numbers of agriculture specialists are staffed to areas  of greatest vulnerability; and review its financial management systems to  ensure financial accountability for funds allocated to the AQI program. It is  also important that user fees be adjusted to meet the program’s costs, as  authorized (but not required) by law. Without decisive action, APHIS and  CBP could be forced to cut back on agriculture inspections if costs  continue to exceed program revenues. Such cutbacks could increase the  potential for animal and plant pests and diseases to enter the United States  and could disrupt trade if agriculture specialists were not available to  inspect and clear passengers and cargo on a timely basis. By overcoming  these challenges, the United States would be in a better position to protect  agriculture from the economic harm posed by foreign pests and disease.
section_title: Recommendations for Executive Action
paragraphs: To ensure the effectiveness of CBP and APHIS agricultural quarantine  inspection programs designed to protect U.S. agriculture from accidental  or deliberate introduction of foreign pests and disease, we are making the  following seven recommendations: We recommend that the Secretaries of Homeland Security and Agriculture  work together to  adopt meaningful performance measures for assessing the AQI  program’s effectiveness at intercepting foreign pests and disease on  agricultural materials entering the country by all pathways—including  commercial aircraft, vessels, and truck cargo—and posing a risk to U.S.  agriculture;  establish a process to identify and assess the major risks posed by  foreign pests and disease and develop and implement a national staffing  model to ensure that agriculture staffing levels at each port are  sufficient to meet those risks;   ensure that urgent agriculture alerts and other information essential to  safeguarding U.S. agriculture are more effectively shared between the  departments and transmitted to DHS agriculture specialists in the ports;  improve the effectiveness of the agriculture canine program by  reviewing policies and procedures regarding training and staffing of  agriculture canines and ensure that these policies and procedures are  followed in the ports; and  revise the user fees to ensure that they cover the AQI program’s costs.
We recommend that the Secretary of Homeland Security undertake a full  review of its financial management systems, policies, and procedures for  the AQI program to ensure financial accountability for funds allocated for  agricultural quarantine inspections.
We recommend that the Secretary of Agriculture take steps to assess and  remove barriers to the timely and accurate transfer of AQI user fees to  DHS.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided USDA and DHS with a draft of this report for their review and  comment. We received written comments on the report and its  recommendations from both departments.
USDA commented that the report accurately captures some of the key  operational challenges facing the two departments as they work to protect  U.S. agriculture from unintentional and deliberate introduction of foreign  agricultural pests and diseases. USDA generally agreed with the report’s  recommendations, adding that APHIS has already made some  improvements to address our recommendations. For example, the  department reported that APHIS has made improvements in the transfer of  funds to CBP as a result of revisions to the interagency agreement with  CBP. We had noted these changes in the report. In addition, USDA offered  to work with DHS on our recommendations that DHS (1) adopt meaningful  performance measures to assess AQI program’s effectiveness and (2)  establish a process to identify and assess the major risks posed by foreign  pests and disease and develop and implement a national staffing model to  address those risks. We modified the recommendations to involve USDA  accordingly. USDA’s written comments and our detailed response appear in  appendix III. USDA also provided technical comments that we  incorporated, as appropriate, throughout the report.
DHS commented that the report was balanced and accurate and agreed  with its overall substance and findings. DHS generally agreed with our  recommendations and indicated that CBP has begun the process of  implementing, or has implemented parts of, our recommendations. For  example, as we note in the report, CBP has begun the process of creating  new performance measures for assessing the AQI program’s effectiveness.  DHS stated that the new measures are scheduled to be in place by the  beginning of fiscal year 2007. Also, DHS commented that CBP has  developed a prototype staffing model methodology that it intends to  develop into a final model to monitor and track the evolving staffing needs  and priorities of the agency. With regard to our recommendation that DHS  review its financial management systems to ensure accountability for AQI  funds, DHS stated that it believes actions taken over the course of our  review have addressed our concerns. We continue to believe that DHS  needs to monitor outcomes of these recent changes during the coming  fiscal year to ensure that they provide necessary accountability for the use  of AQI funds. DHS’s written comments and our detailed response appear in  appendix IV. DHS also provided technical comments that we incorporated,  as appropriate, throughout the report.
We are sending copies of this report to the Secretaries of Homeland  Security and Agriculture and interested congressional committees. We will  also make copies available to others on request. In addition, this report will  be available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-3841 or bertonid@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions to this report are  listed in appendix V.
section_title: Scope and Methodology
paragraphs: To assess the extent to which the U.S. Department of Agriculture (USDA)  and the Department of Homeland Security (DHS) have changed the  Agricultural Quarantine Inspection (AQI) program since the transfer of  responsibilities from USDA to DHS, we reviewed the 2003 Memorandum of  Agreement between the United States Department of Homeland Security  and the United States Department of Agriculture, dated February 28, 2003,  and the associated appendixes governing how USDA and DHS are to  coordinate inspection responsibilities. We also reviewed agency  documentation, including training materials for newly hired Customs and  Border Protection (CBP) officers, information on databases used by CBP  agricultural specialists to target agriculture inspections, joint-agency  reports on port compliance with agricultural inspection policy, and  information related to CBP’s establishment and utilization of new  agriculture liaison positions. In addition, we interviewed key program  officials at USDA’s Animal and Plant Health Inspection Service (APHIS) and  CBP to discuss changes to the AQI program, including officials responsible  for training, implementing inspection targeting initiatives, conducting port  reviews, and overseeing communication of agricultural issues within CBP.
To assess how the departments have managed and coordinated their  agriculture inspection responsibilities, we reviewed the interagency  memorandum of agreement between DHS and USDA and its associated  appendixes. We also reviewed agency documentation, including DHS’s  Performance and Accountability Reports, APHIS’s model for staffing  agriculture specialists at ports, data from APHIS’s Work Accomplishment  Data System for fiscal years 2000 through 2005, agency e-mails  communicating agriculture alerts and policy information, proposals for  joint-agency special operations at ports, and agency policy governing  agriculture inspection training and the agriculture canine program. We  performed a reliability assessment of the data we analyzed for fiscal years  2000 through 2005 and determined that the data were sufficiently reliable  for the purposes of this report. We also visited all three training centers for  port of entry staff that conduct agricultural training—the USDA  Professional Development Center, in Frederick, Maryland; the USDA  National Detector Dog Training Center in Orlando, Florida; and the Federal  Law Enforcement Training Center (FLETC) in Glynco, Georgia—to  observe training and interview current students, instructors, and staff. In  addition, we interviewed key program officials at CBP and APHIS with  knowledge of AQI management issues, such as performance measures,  staffing, interagency coordination, training, and the agriculture canine  program.
Furthermore, to ascertain agricultural specialists’ assessment of the  agriculture quarantine inspection program since the transfer of inspection  responsibilities from USDA to DHS, we drew a stratified random  probability sample of 831 agriculture specialists from the approximately  1,800 specialists (current as of Oct. 14, 2005) in the Department of  Homeland Security’s Customs and Border Protection. All canine specialists  were placed in one stratum; other strata were defined by the number of  specialists at the respective ports. We conducted a Web-based survey of all  specialists in the sample. Each sampled specialist was subsequently  weighted in the analysis to account statistically for all specialists in the  population. We received a response rate of 76 percent. We chose to sample  agriculture specialists who had recently been hired by CBP, as well as  former APHIS employees who had been transferred to CBP, including  agriculture supervisors, to get their various perspectives on the AQI  program.
The survey contained 31 questions that asked for opinions and assessments  of (1) agriculture inspection training, (2) agriculture inspection duties, (3)  communication and information sharing within CBP and between other  agencies, and (4) changes in the number of agriculture inspections and  interceptions since the transfer. In addition, the survey included questions  specifically for canine handlers, agriculture supervisors, and former APHIS  employees. In developing the questionnaire, we met with CBP and APHIS  officials to gain a thorough understanding of the AQI program. We also  shared a draft copy of the questionnaire with CBP officials, who provided  us with comments, including technical corrections. We then pretested the  questionnaire with CBP agriculture specialists at ports of entry in Georgia,  Maryland, Texas, and Washington state. During these pretests, we asked  the officials to complete the Web-based survey as we observed the process.  After completing the survey, we interviewed the respondents to ensure that  (1) questions were clear and unambiguous, (2) the terms we used were  precise, (3) the questionnaire did not place an undue burden on CBP  agriculture specialists completing it, and (4) the questionnaire was  independent and unbiased. On the basis of the feedback from the pretests,  we modified the questions, as appropriate.
The questionnaire was posted on GAO’s survey Web site. When the survey  was activated, the officials who had been selected to participate were  informed of its availability with an e-mail message that contained a unique  user name and password. This allowed respondents to log on and fill out a  questionnaire but did not allow respondents access to the questionnaires of  others. The survey was available from November 17, 2005, until January 9,  2006. Results of the survey to CBP agriculture specialists are summarized  in appendix II.
Because we followed a probability procedure based on random selections,  our sample is only one of a large number of samples we might have drawn.  Since each sample could have provided different estimates, we express our  confidence in the precision of our particular sample’s results as 95 percent  confidence intervals (e.g., plus or minus 7 percentage points). These are  intervals that would contain the actual population values for 95 percent of  the samples we could have drawn. As a result, we are 95 percent confident  that each of the confidence intervals in this report from our survey of  agriculture specialists will include the true values in the study population.  All percentage estimates from the survey of agriculture specialists have  margins of error (that is, confidence interval widths) of plus or minus 10  percentage points or less, unless otherwise noted. All numerical estimates  other than percentages (e.g., means) have margins of error not exceeding  plus or minus 15 percent of the value of those estimates, unless otherwise  noted.
To determine how funding for agriculture inspections has been managed  since the transfer from USDA to DHS, we reviewed the interagency  memorandum of agreement between DHS and USDA—specifically the  appendix, Article 5: Transfer of Funds, originally signed on February 9,  2004, and revised on October 5, 2005. Further, we compared the amount of  revenue generated from the user fees with program costs reported by CBP  and APHIS on agriculture inspections in fiscal years 2001 through 2005. We  also reviewed relevant agency documentation, including proposals for  increasing user-fee collections, budget classification handbooks, cost  analysis worksheets, and user-fee collection and expense analyses. In  addition, we reviewed how funds were transferred between APHIS and  CBP and the impact of these transfers on their operations. Lastly, we  interviewed senior CBP and APHIS financial management officials  concerning AQI user-fee collections, cost management, and the transfer of  funds from APHIS to CBP.
We conducted our review from April 2005 through March 2006 in  accordance with generally accepted government auditing standards.
section_title: Results of GAO Survey of CBP Agricultural Specialists
paragraphs: This appendix provides the results from our Web-based survey of CBP  agriculture specialists. (App. I contains details of our survey methodology.)  We selected a statistical sample of 831 specialists. Within this population,  we asked questions of, and analyzed data for, three groups: (1) former  APHIS inspectors—also referred to as plant protection and quarantine  (PPQ) officers in the survey; (2) newly hired CBP agriculture specialists;  and (3) canine agriculture specialists. The survey contained 31 questions  about the experiences and opinions of the specialists. We omitted  questions 3 and 23, which were used to help respondents navigate the  survey. We received 628 completed surveys—an overall response rate of 76  percent. We indicate the number of respondents below each question  because not every respondent answered every question. We also rounded  the responses to the nearest whole percent, and, therefore, totals may not  add to 100 percent.
Part 1: Demographic Information 1. What is your job title at CBP? 2. For which of the following pathways did you conduct agricultural  inspections during the past year? (Please check all that apply.) n=624 Part 2: Information from Former USDA PPQ Officers 4. When did you begin working as a USDA PPQ Officer (not as an  agriculture technician or aide)? 5. During your first year working as a USDA PPQ Officer, about how many  weeks did you spend in on-the-job (in port) training? (Please include such  things as shadowing, observation, and coaching. Do not include time  spent at the Professional Development Center. If you spent less than one  week, please enter 1.) 6. Do you believe you received sufficient training (on-the-job and at the  Professional Development Center) to enable you to perform your  agriculture inspection duties? n=448 7. Are you, personally, doing more, about the same number, or fewer  agriculture inspections compared to what you were doing before being  transferred to CBP? 8. Are you, personally, doing more, about the same number, or fewer  agriculture interceptions compared to what you were doing before being  transferred to CBP? n=448 9. Which of the following inspection activities did you regularly perform as  a PPQ Officer prior to being transferred to CBP, and which do you regularly  perform now? (Please check all that apply.)
Specialist (percent)
Specialist (percent)
Specialist (percent)
Specialist (percent)
Part 3: Information from CBP Agriculture Specialists Hired After  March 1, 2003. 10. When did you begin working as a CBP Agriculture Specialist? n=173 11. During your first year working as a CBP Agriculture Specialist, about  how many weeks did you spend in on-the-job (in port) training? (Please  include such things as shadowing, observation, and coaching. Do not  include time spent at the Professional Development Center. If you spent  less than one week, please enter 1.)
Began in 2003 or 2004  (mean number of weeks)
Began in 2005  (mean number of weeks)
12. Do you believe you received sufficient training (on-the-job and at the  Professional Development Center) to enable you to perform your  agriculture inspection duties? n=174 Part 4: Your Work at CBP 13. During the past 6 months about what percentage of your time did you  spend on agriculture and nonagriculture CBP duties? (Please enter  percentages in boxes. If none, enter 0. Percentage total should be 100.)
Agriculture inspections and associated activities Customs and Immigration inspections and associated activities Work not related to inspections (e.g., administrative work, training)
14. For each pay period, do you provide the number of hours you worked  on agriculture inspection and the number of hours you worked on customs  and immigration inspection to your supervisor or timekeeper? n=626 15. Are the following supplies readily available to you? (Please check one in  each row. If you do not use a supply, please check ‘Do not Use.’) 16. Do you have easy access to USDA regulatory manuals during  inspections? (Please check one in each row.) n=626 17. Do you have enough time to look for pests in agriculture materials  intercepted from passengers? 18. How easy or difficult is it for you to get samples to a pest identifier? n=626 19. When you send a sample to a pest identifier, about how long does it  usually take to get the results?
20. How are the following types of information delivered to you? If you do  not receive a type of information on a regular basis, please indicate that.  (Please check all that apply.)
Not received  on a regular  (percent) (percent) communication (percent) basis (percent)
21. Is the information delivered to you in a timely manner? (Please check  one in each row.) 22. During the past year, about how many hours per month did you spend  compiling and entering data into the databases listed below? (Please check  one in each row.) n=626 Part 5: Questions for Canine Handlers 24. Are the following resources readily available to you? (Please check one  in each row.) 25. During the past year, have there been any instances when you thought it  would be helpful to contact the National Detector Dog Training Center, but  you were told by CBP management not to contact them? n=62 26. Does CBP management allow you enough time each month to schedule  training with your dog? 27. During the past year, about how frequently have you been directed to  perform duties outside your primary mission as a Canine Handler? n=62 Part 6: Your Views and Opinions about Working at CBP 28. Based on you own experiences, how would you describe the work- related communication between Agriculture Specialists and the others  listed below? (Please check one in each row.)
section_title: Comments from the Department of Agriculture
subsections: section_title: GAO Comments
paragraphs: 1. We agree with USDA’s suggestion regarding two of our  recommendations. We now recommend that the Secretaries of  Agriculture and Homeland Security work together to (1) adopt  meaningful performance measures for assessing the AQI program’s  effectiveness at intercepting foreign pests and disease and (2) establish  a process to identify and assess the major risks posed by foreign pests  and disease and develop and implement a national staffing model to  meet those risks. 2. USDA noted that revisions to APHIS’s agreement with CBP should  address the concerns we raised in the report regarding the timely and  accurate transfer of AQI funds to CBP. USDA states that APHIS made  the first three transfers of fiscal year 2006 on time. We discuss these  positive steps in our report and note a problem with one of APHIS’s  transfers. As USDA carries out its three-phase approach to revising user  fees, and DHS works to advance proposed consolidation of customs,  immigration, and agriculture user fees (see app. IV), we believe that  USDA must ensure that it follows the revised agreement to ensure  timely and accurate transfer of AQI user fees to DHS.
section_title: Comments from the Department of Homeland Security
subsections: section_title: GAO Comments
paragraphs: 1. We continue to believe that the title of the report reflects our  conclusion that U.S. agriculture is vulnerable to the unintentional or  deliberate introduction of foreign pests and diseases as a result of the  management and coordination issues we raise in the report. Until DHS  adopts and tracks meaningful performance measures to assess the  effectiveness of the AQI program, DHS does not know the effectiveness  of the AQI program at performing its mission. Further, until DHS  implements a national risk-based staffing model for agriculture  specialists, it does not know whether adequate numbers of agriculture  specialists are staffed to ports of entry most vulnerable to the  introduction of foreign pests and disease. 2. We acknowledge, in the report, the steps that CBP has taken to improve  communication and information sharing between headquarters and  field offices. However, given the problems with information sharing  that we identified in our survey of agriculture specialists, we continue  to believe that additional actions are warranted to ensure that urgent  agriculture alerts and other information are transmitted through the  CBP chain of command to the agriculture specialists. 3. We acknowledge the operational challenges facing CBP as a result of  having to manage three different sets of user fees (i.e., agriculture,  customs, and immigration) to support inspection functions at U.S. ports  of entry. For example, we identified in the report some of the  timekeeping issues surrounding the need to appropriately separate  time spent on agriculture, customs, and immigration functions. We  understand that CBP concluded that to adequately address these  challenges, congressional action may be required to consolidate the  different user fees and their associated spending, fee setting, and costs  recovery authorities and exemptions.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Maria Cristina Gobin (Assistant  Director), Terrance N. Horner Jr., Jeff Isaacs, Lynn Musser, Omari Norman,  Minette Richardson, Steve Rossman, Sidney Schwartz, Robyn Trotter, and  Diana Zinkl made key contributions to this report. Other contributors  included Nancy Crothers, Casey Keplinger, and Kim Raheb.