Air Passenger Screening: Transportation Security Administration Could Improve Complaint Processes
Published: 2012-11-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: TSA, which screens or oversees the screening of over 650 million air passengers per year, has processes for addressing complaints about air passengers screening experience at checkpoints, but concerns have been raised about these processes. The Conference Report accompanying the Consolidated Appropriations Act, 2012, directed TSA to ensure the traveling public is aware of these processes and GAO to review TSAs policies and procedures for resolving passenger complaints. This report addresses the extent to which TSA has (1) policies and processes to guide the receipt of air passenger screening complaints and use of this information to monitor or enhance screening operations, (2) a consistent process for informing passengers about how to make complaints, and (3) complaint resolution processes that conform to independence standards. To address these objectives, GAO reviewed TSA documentation, analyzed complaint data from October 2009 through June 2012, and interviewed TSA officials from headquarters offices and six airports selected for type of security, among other things. The airport interviews are not generalizable but provide insights.
section_title: What GAO Found
paragraphs: The Transportation Security Administration (TSA) receives thousands of air passenger screening complaints through five mechanisms, but does not have an agencywide policy or consistent processes to guide receipt and use of such information. For example, from October 2009 through June 2012, TSA received more than 39,000 screening complaints through its TSA Contact Center (TCC). However, the data from the five mechanisms do not reflect the full nature and extent of complaints because local TSA staff have discretion in implementing TSA's complaint processes, including how they receive and document complaints. For example, comment cards are used at four of the six airports GAO contacted, but TSA does not have a policy requiring that complaints submitted using the cards be tracked or reported centrally. A consistent policy to guide all TSA efforts to receive and document complaints would improve TSA's oversight of these activities and help ensure consistent implementation. TSA also uses TCC data to inform the public about air passenger screening complaints, monitor operational effectiveness of airport security checkpoints, and make changes as needed. However, TSA does not use data from its other four mechanisms, in part because the complaint categories differ, making data consolidation difficult. A process to systematically collect information from all mechanisms, including standard complaint categories, would better enable TSA to improve operations and customer service.
TSA has several methods to inform passengers about its complaint processes, but does not have an agencywide policy or mechanism to ensure consistent use of these methods among commercial airports. For example, TSA has developed standard signs, stickers, and customer comment cards that can be used at airport checkpoints to inform passengers about how to submit feedback to TSA; however, GAO found inconsistent use at the six airports it contacted. For example, two airports displayed customer comment cards at the checkpoint, while at two others the cards were provided upon request. Passengers may be reluctant to ask for such cards, however, according to TSA. TSA officials at four of the six airports also said that the agency could do more to share best practices for informing passengers about complaint processes. Policies for informing the public about complaint processes and mechanisms for sharing best practices among local TSA officials could help provide TSA reasonable assurance that these activities are being conducted consistently and help local TSA officials learn from one another about what practices work well.
TSA's complaint resolution processes do not fully conform to standards of independence to ensure that these processes are fair, impartial, and credible, but the agency is taking steps to improve independence. Specifically, TSA airport officials responsible for resolving air passenger complaints are generally in the same chain of command as TSA airport staff who are the subjects of the complaints. TSA is developing a new process that could help ensure greater independence by TSA units referring air passenger complaints directly to its Ombudsman Division and by providing passengers an independent avenue to make complaints to that division. TSA also plans to initiate a program by January 2013 in which selected TSA airport staff are to be trained as passenger advocates as a collateral duty. It is too early to assess the extent to which these initiatives will help mitigate possible concerns about independence.
section_title: What GAO Recommends
paragraphs: GAO recommends that TSA, among other actions, establish (1) a consistent policy for receiving complaints, (2) a process to systematically analyze information on complaints from all mechanisms, and (3) a policy for informing passengers about the screening complaint processes and mechanisms to share best practices among airports. TSA concurred and is taking actions in response.

section_title: Letter
paragraphs: The Transportation Security Administration (TSA), established by the  Aviation and Transportation Security Act (ATSA), provides for, or  oversees the provision of, security screening operations at the nation’s  commercial airports. In accordance with ATSA, all air passengers and  their accessible property must pass through a security checkpoint and  undergo screening before entering the sterile area of an airport. TSA  currently screens or oversees the screening of over 650 million air  passengers per year at 752 security checkpoints at over 440 commercial  airports nationwide. The December 2009 terrorist attempt to detonate an  explosive device during an international flight bound for Detroit prompted  TSA to implement changes to air passenger screening, including  accelerating the nationwide deployment of Advanced Imaging Technology  (commonly referred to as a full body scanner, which screens air  passengers for weapons, explosives, and other objects concealed under  layers of clothing) and introducing enhanced pat-down procedures to  screen air passengers who, for example, opt out of Advanced Imaging  Technology-based screening. Air passenger screening complaints reflect  a wide range of concerns, including those related to the use of Advanced  Imaging Technology and concerns about enhanced pat-down procedures  being unnecessarily intrusive.and resolving complaints that air passengers may have about their  screening experience at security checkpoints; however, public concerns  have been raised about these processes.
TSA has various processes for receiving  The Conference Report accompanying the Consolidated Appropriations  Act, 2012, directed TSA to make every effort to ensure that members of  the traveling public are aware of the procedures and processes for  making complaints about air passenger screening. Report also directed that we review TSA’s policies and procedures for  resolving passenger complaints, including an assessment of  organizational independence. In response, this report addresses the  following questions: (1) To what extent does TSA have policies and  processes in place to guide the receipt of air passenger screening  complaints and use this information to monitor or enhance screening  operations? (2) To what extent does TSA have a consistent process for  informing air passengers about how to make screening complaints? (3)  To what extent does TSA have complaint resolution processes that  conform to standards of independence to ensure that these processes  are fair, impartial, and credible?
See H.R. Rep. No. 112-331, at 975 (2011) (accompanying H.R. 2055, 112th Cong. (1st  Sess. 2011), enacted as the Consolidated Appropriations Act, 2012, Pub. L. No. 112-74,  125 Stat. 786 (2011)). groups to obtain their perspectives on TSA’s processes for receiving and  documenting air passenger screening complaints and for using this  information to monitor or enhance screening operations. The views of  these industry groups are not generalizable to all members of the aviation  industry but provided us with additional perspective and insights. The  groups were selected to include organizations representing airlines,  airports, travel agencies, and travelers, among others. In addition, we  interviewed officials from the U.S. Department of Transportation’s  Aviation Consumer Protection Division. We also obtained and analyzed  air passenger screening complaint data from October 2009 through June  2012 from four TSA headquarters units. We selected October 2009 as  the starting point because it was the first month of the fiscal year that  included the December 2009 terrorist attempt to detonate an explosive  device during an international flight bound for Detroit, which prompted  TSA to implement changes to its air passenger screening operations. In  addition, we obtained and analyzed air passenger screening complaint  data from April 2011 through June 2012 from a database TSA uses to  document screening complaints collected through TSA’s Talk to TSA  web-based portal. This database became operational in April 2011,  according to TSA officials. On the basis of information from and  discussions with TSA officials related to the controls in place to maintain  the integrity of TSA’s complaint data, we determined that the data from  each database were sufficiently reliable for our purposes.
In addition, we selected a nonprobability sample of six airports—including  one airport participating in TSA’s Screening Partnership Program (SPP)— at which to interview TSA airport officials (and contractors’  representatives) about their processes for receiving and documenting air  passenger screening complaints and for using this information to inform  screening operations and improve customer service. We also obtained  supporting documentation and data from officials at these six airports. We  selected these airports based on airport security category and types of  screening equipment and initiatives at the airports, such as the use of  Advanced Imaging Technology and TSA’s enhanced behavior detection  pilot program. The selected airports are located in the Washington,  D.C.; Detroit; and Los Angeles metropolitan areas; and the SPP airport is  located in the San Francisco metropolitan area. We visited and observed  security checkpoints at four of the airports. At the five airports where  TSA performs the screening function, we interviewed TSA Federal  Security Director (FSD) staff responsible for screening and customer  service, such as TSA screening supervisors and managers and TSA  Customer Support Managers. At the SPP airport, we interviewed TSA  FSD staff responsible for customer service and contractor officials  responsible for screening. While the information gathered from the  interviews cannot be generalized to all commercial airports, it provided  important perspective to our analysis of air passenger screening  complaint processes, which is focused on airports at which TSA staff  conduct screening. At the TSA headquarters units and airports we  interviewed, we compared TSA’s processes for receiving and  documenting air passenger screening complaints and for using the  information to monitor and enhance screening operations and improve  customer service against Standards for Internal Control in the Federal  Government.
To address the second objective, we reviewed TSA documentation on  how the agency informs passengers about its air passenger complaint  processes, such as agency guidance, website information, comment  cards, and signs. We also interviewed officials at TSA and the selected  airports about the agency’s methods for informing air passengers about  TSA’s processes for making screening complaints (and about TSA’s  contractor’s complaint processes). We compared these methods with  Standards for Internal Control in the Federal Government.
To address the third objective, we obtained and analyzed TSA guidance  for resolving air passenger screening complaints, as well as the  organizational structure of TSA offices responsible for resolving screening  complaints. We compared this information with pertinent criteria from  Standards for Internal Control in the Federal Government and other  standards for independence, such as ombudsman standards for  governmental organizations, to assess the extent to which TSA’s screening complaint resolution processes are independent from those  responsible for conducting screening at airport checkpoints so as to  ensure that these processes are fair, impartial, and credible. We  interviewed TSA officials responsible for resolving screening complaints,  including customer support managers at the selected airports, as well as  aviation industry group representatives. We also interviewed TSA officials  about the agency’s plans for creating an external ombudsman function to  resolve screening complaints.
We conducted this performance audit from February 2012 to November  2012 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: Roles and Responsibilities for Receiving and Addressing Screening Complaints
paragraphs: TSA has various processes for receiving and addressing air passenger  complaints about the screening systems, procedures, and personnel at  airport security checkpoints. Specifically, several TSA headquarters  units and local TSA airport staff have responsibility and processes for  receiving and addressing these complaints, and, if necessary, referring  these complaints to other TSA offices for resolution. Figure 1 depicts the  four primary TSA headquarters units and the local TSA airport staff who  are responsible for receiving and addressing air passenger screening  complaints.
As highlighted in figure 1, the TSA Contact Center (TCC) receives,  documents, and helps resolve screening complaints that air passengers  make by telephone and e-mail. The TCC is TSA’s primary point of contact  for collecting, documenting, and responding to public questions,  concerns, or complaints regarding TSA security policies, procedures, and  programs; reports and claims of lost, stolen, or damaged items; and  employment issues.
These officials include Lead and Supervisory Transportation Security Officers as well as  Transportation Security Managers. At SPP airports, they include supervisory contractor  officials. FSDs and Assistant Federal Security Directors are responsible for overseeing  TSA security programs at all commercial airports. According to the Assistant Administrator  of TSA’s Office of Civil Rights & Liberties, Ombudsman and Traveler Engagement, the  agency is working on an initiative under which an unspecified number of TSA staff will  receive training as “passenger advocates” and begin working in this capacity to address  air passenger complaints at security checkpoints by January 2013. screener staff at other commercial airports. Customer Support  Managers work in conjunction with other FSD staff to resolve customer  complaints and communicate the status and resolution of complaints to  air passengers. They are also responsible for ensuring security  procedures and practices are consistently and effectively communicated  to air passengers, to the extent permitted by law and regulation.
TSA has an operations directive that specifies roles, responsibilities, and  time frames for resolving and responding to screening complaints that air  passengers submit to the TCC and FSD staff. This directive does not  apply to complaints received through other mechanisms, as we discuss  later in this report. The agency has also given TSA headquarters units  and FSDs discretion in addressing these complaints at airports under  their jurisdiction, according to TSA officials. This operations directive  provides instructions for processing public inquiries, including air  passenger screening complaints, received by the TCC and FSD staff.  The directive indicates that inquiries received by the TCC will be  answered by the TCC or will be forwarded to the appropriate FSD staff for  response, and that inquiries received by FSD staff will be answered by  FSD staff or will be forwarded to the TCC for response. In addition, the  operations directive provides several time frames for responding to  complaints. For example, TSA should respond within 48 hours for e-mail  inquiries addressed by the TCC, and within 72 hours for telephone  inquiries addressed by the TCC.
Overall, upon receiving a complaint, TSA headquarters units and local  TSA airport staff may address the complaint directly or refer it to other  offices for review and resolution after determining which one has the  necessary expertise and knowledge to address the alleged incident. For  example, according to TSA officials, if an air passenger submits the  complaint through the TCC, TCC staff attempt to resolve it by providing a  response to the air passenger using pertinent template language that  explains TSA policy and screening procedures. Alternatively, the TCC  may refer screening complaints for resolution to other TSA headquarters  offices, depending on the specific allegation. For example, complaints  alleging discrimination on the basis of a disability or medical condition are  referred to the Disability Branch. Also, the TCC may forward complaints  about customer service to the customer service representative at the  airport identified in the complaint for investigation and resolution.  Alternatively, if an air passenger submits a complaint directly to TSA staff  at the airport, it is the responsibility of these staff members to investigate  and resolve the complaint or, if necessary, refer it to TSA units at  headquarters, such as the Disability Branch. For example, according to  TSA officials, if an air passenger makes a complaint in person at the  checkpoint, TSA supervisors and managers are to attempt to resolve the  complaint at the checkpoint before the situation escalates.
Regardless of whether a complaint is initially received by a TSA  headquarters unit or at the airport at which the incident took place,  according to TSA officials, local TSA airport officials generally conduct  most follow-up investigations since they are well placed to collect  additional airport-specific information and interview local staff. However,  specific actions taken to investigate and resolve complaints vary by  airport. For example, customer service representatives may be involved  in reviewing screening complaints, obtaining additional information from  the air passengers to determine when and where the incident took place,  and reviewing video footage of the incident to help identify additional  details of the incident, such as the identity of the screener(s) who may  have been involved in the incident and what had actually happened  during the incident. If the situation warrants it, the customer service  representative may forward the complaint as well as the video footage to  the TSA screening supervisor or manager for additional review and  action. The supervisor or manager may review the video footage and  obtain a statement from the screener to determine what happened during  the incident and the extent to which the screener may have been at  fault—for example, whether the screener violated TSA standard operating  procedures, or behaved unprofessionally or inappropriately toward the air  passenger.
Depending on the nature and severity of the allegation, TSA airport staff  may also elevate the complaint and evidence to the airport’s Assistant  Federal Security Director (AFSD) for Screening or to TSA headquarters  units, such as the Disability Branch or the Office of Inspections, for formal  investigation. If the investigation were to find fault with the screener, the  screener’s supervisor or manager is to determine the corrective action to  be taken. Corrective actions specified in TSA’s guidance range from  mandating the screener to take additional training to correct the behavior  to terminating the screener’s employment for multiple repeat offenses or  single egregious actions, such as theft of air passenger property.  Following the outcome of the investigation and any resulting corrective  actions, the TSA headquarters unit or the FSD or his/her staff, such as a  customer service representative, is to communicate the status of the  resolution to the air passenger—such as by reiterating that TSA  procedures were followed or by issuing an apology and informing the air  passenger that corrective actions were taken.
section_title: Lack of an Agencywide Policy, Consistent Processes, and Agency Focal Point Limits TSA’s Ability to Receive and Use Complaint Information
paragraphs: TSA’s five centralized mechanisms for receiving air passenger screening  complaints provide the agency with a significant amount of information it  can use to monitor or enhance screening operations. However, TSA does  not have agencywide policy, consistent processes, or an agency focal  point to guide the receipt of these complaints or to use complaint  information to inform management about the nature and extent of the  screening complaints to help improve screening operations and customer  service.
subsections: section_title: Five Mechanisms Receive Thousands of Air Passenger Complaints
paragraphs: TSA receives and documents screening complaints that air passengers  submit through four headquarters units—the TCC, the Executive  Secretariat, the Multicultural Branch, and the Disability Branch—as well  as the Talk to TSA web-based feedback mechanism, which e-mails the  screening complaint information directly to designated TSA airport staff.  As shown in figure 3, the number of complaints submitted through these  mechanisms fluctuated somewhat from October 2009 through June 2012.  The major exception was a very large increase in the number of  complaints submitted to three mechanisms in November and December  2010, which may be attributed to several factors, including a November  2010 public opt-out campaign reported by the media to protest the use of  Advanced Imaging Technology and enhanced pat-down procedures for  screening air passengers.
The volume of complaints that TSA received through each of its five main  mechanisms varied from October 2009 through June 2012. Also, because  these mechanisms use different categories for screening complaints and  have different capabilities for data analysis, we were not able to combine  the data from these mechanisms to discuss overall patterns and trends in  volume or categories of complaints. A discussion of complaint information  in each mechanism follows.
The TCC received the bulk of the air passenger screening complaints that  the agency documented during this time period. Using TCC data, TSA  has reported that it receives about 750,000 public inquiries annually  through the TCC and that 8 percent of these inquiries involve air  passenger complaints (including complaints about screening). As noted  below, however, this information does not include complaint data from  other TSA complaint mechanisms. Specifically, the TCC received a total  of 39,616 screening complaints that air passengers submitted by e-mail  and telephone from October 2009 through June 2012. The TCC divides  screening complaints into seven main categories, five having multiple  subcategories. Figure 4 shows the total numbers of screening complaints  by the seven main TCC categories, such as 17,153 complaints about pat- down procedures.
Figure 5 depicts the numbers of screening complaints that the TCC  received from October 2009 through June 2012 by the four main TCC  categories having the most complaints. As shown in figure 5, the numbers  of screening complaints in these four categories remained relatively  stable over this period. The major exception was a very large increase in  the number of complaints about pat-down procedures in November and  December 2010 and continuing periods of a relatively higher level of pat- down complaints through September 2011. As mentioned before, this  increase in complaints may be attributed to several factors, including the  November 2010 public opt-out campaign reported by the media to protest  the use of Advanced Imaging Technology and enhanced pat-down  procedures for screening air passengers.
The Office of the Executive Secretariat received 4,011 complaints that air  passengers submitted by mail. For instance, these complaints include  screening complaints related to, among other issues, Advanced Imaging  Technology and enhanced pat-down procedures.
The Multicultural Branch received 2,899 written screening complaints  alleging violations of civil rights and civil liberties, 469 of which it  processed as cases. Figure 6 shows the number of cases, by 11  categories, that the branch processed, such as 141 cases related to  allegations of discrimination based on race or ethnicity.
The Disability Branch received 920 written screening complaints alleging  discrimination on the basis of disability and medical condition. From  these, the branch processed 1,233 cases. Figure 7 shows the number  of cases, by 27 categories, that the branch processed, such as 201 cases  related to inappropriate screening.
The Talk to TSA web-based mechanism received 4,506 air passenger  screening complaints from April 2011 through June 2012. When  submitting complaints through this mechanism, air passengers can select  up to five complaint categories from a list of 20 possible categories.  Figure 8 shows the number of screening complaints by 20 categories that  the branch received, such as 1,512 complaints about the professionalism  of TSA staff during the screening process.
TSA has established five centralized mechanisms for receiving air  passenger complaints, but it has not established an agencywide policy,  consistent processes, or a focal point to guide receipt and use of this  information to inform management about the nature and extent of the  screening complaints to help improve screening operations and customer  service.
With regard to agencywide policy, TSA has not established a policy to  guide airports’ efforts to receive air passenger complaints. In the absence  of such a policy, TSA officials at airports have wide discretion in how they  implement TSA’s air passenger complaint process, including how they  receive and document the complaints. For example, at the six airports  that we contacted, the use of customer comment cards, which the U.S.  General Services Administration (GSA) considers a relatively inexpensive  means for government agencies to receive customer feedback, varied by  airport. Specifically, customer comment cards were not used at two of  the six airports we contacted, according to TSA officials at those airports,  while at the other four airports customer comment cards were used to  obtain air passenger input in varying ways. At two of these four airports,  customer comment cards were on display at counters in the security  checkpoints. At the other two airports, neither customer comment cards  nor information about the cards was on display, but the cards were  available to air passengers upon request, according to TSA airport  officials. Passengers who are concerned about being late for their flight or  about appearing uncooperative may be reluctant to ask for such cards,  however.
In addition, when TSA receives a customer comment card, either through  air passengers mailing the cards, giving them to TSA screening  supervisors or managers, or depositing the cards in a box at the security  checkpoint, the card is to go to a customer service representative at the  airport. However, TSA does not have a policy requiring that customer  service representatives track these comment card submissions or report  them to one of TSA’s five centralized mechanisms for receiving  complaints if the card includes a complaint. As a result, TSA does not  know the full nature and extent of the complaints that air passengers  make through customer comment cards. Also, TSA officials reported that  the agency does not require TSA airport staff to collect and document  information on the screening complaints that air passengers submit in  person at the airport level because the agency has given these officials  broad discretion in addressing these screening complaints. However,  without an agencywide policy to guide the receipt and tracking of  screening complaints at the airport level, TSA does not have reasonable  assurance that headquarters and airport entities involved in the  processes of receiving, tracking, and reporting these complaints are  conducting these activities consistently.
Further, TSA does not have a process to use all the information it  currently collects in its efforts to inform the public of the nature and extent  of air passenger screening complaints, monitor air passenger satisfaction  with screening operations, and identify patterns and trends in screening  complaints to help improve screening operations and customer service.  For example, TSA has five centralized mechanisms through which it  receives air passenger complaints, but the agency does not combine  information from all of these sources to analyze the full nature and extent  of air passenger screening complaints. TSA officials have noted that the  agency receives about 750,000 contacts per year from the public by e- mail and telephone through the TCC, and that about 8 percent of these  contacts are related to complaints. However, this information does not  include data on complaints received through other headquarters units or  the Talk to TSA web-based form. We recognize that differences in  complaint categories among the various databases could hinder any  efforts by TSA to combine the complaint data, which we discuss further  below.
TSA informs the public of the nature and extent of air passenger  screening complaints through the U.S. Department of Transportation’s  monthly Air Travel Consumer Report, but the number TSA reports in this  publication only includes complaints received through the TCC and does  not include the complaints TSA received through its other four  mechanisms. The July 2012 report, for example, noted that TSA had  received about 900 air passenger screening complaints in May 2012, with  screening complaints about courtesy and personal property constituting  the bulk of the complaints and screening complaints about processing  time and screening procedures constituting the rest of the complaints.  Further, TSA is using only the complaints received through the TCC to  calculate an air passenger satisfaction indicator in its Office of Security  Operations’ Executive Scorecard. According to TSA, the purpose of this  scorecard is for FSD management and staff to monitor operational  effectiveness of airport security checkpoints and make changes as  needed, such as to improve screening operations and customer service.  TSA officials further stated that the agency has primarily been using the  TCC because the TCC information on air passenger screening  complaints is readily available. According to the Assistant Administrator of  TSA’s Office of Civil Rights & Liberties, Ombudsman and Traveler  Engagement, partly as a result of our review, the agency began  channeling information from the Talk to TSA database to the TCC in early  October 2012. However, it is unclear whether the agency will compile and  analyze data from the Talk to TSA database and its other centralized  mechanisms in its efforts to inform the public about the nature and extent  of screening complaints. It is also unclear whether these efforts will  include data on screening complaints submitted locally through customer  comment cards or in person at airport security checkpoints.
In addition, as discussed earlier, because TSA does not have a  consistent process for categorizing air passenger complaints data,  including standardized categories of complaints, it is unable to compile  and analyze all of the data to identify patterns and trends. Specifically,  each of the five centralized mechanisms has different screening  complaint categories and different capabilities to analyze the data. As a  result, TSA cannot compile information from all five mechanisms to  identify patterns and trends in air passenger complaints and monitor its  efforts to resolve complaints on a systemic basis. For example, while the  TCC database and the Talk to TSA database each may have categories  with identical or similar names, such as Advanced Imaging Technology  and pat-downs, other categories are unique to certain databases. For  instance, the TCC database does not have categories or subcategories  corresponding to the Talk to TSA categories of carry-on property out of  view, permitted/prohibited items, expert traveler and family lanes, or  liquids, among others. As a result, TSA cannot combine the data from  different databases to identify whether particular aspects of the screening  experience may warrant additional attention or whether TSA’s efforts to  improve customer service are having any effect on the number of  complaints.
Standards for Internal Control in the Federal Government calls for  agencies to develop control activities, such as policies, procedures,  techniques, and mechanisms that enforce management’s directives. A  consistent policy to guide local TSA officials’ efforts to receive, track, and  report complaints would help provide TSA reasonable assurance that  these activities are being conducted in a consistent manner throughout  commercial airports and provide the agency with improved ability to  oversee these local efforts. Moreover, a process to systematically collect  information on air passenger complaints from all mechanisms, including  standardization of the categories of air passenger complaints to provide a  basis for comparison, would give TSA a more comprehensive picture of  the volume, nature, and extent of air passenger screening complaints and  better enable the agency to improve screening operations and customer  service.
GAO/AIMD-00-21.3.1. interviewed stated that the five mechanisms were designed at different  times and for different purposes, and they agreed that the agency could  benefit from a consistent complaints policy, a process to collect  information from all mechanisms, and a focal point to coordinate these  efforts.
section_title: TSA Has Several Methods to Inform Air Passengers about Making Screening Complaints, but Does Not Consistently Implement Them
paragraphs: TSA has several methods to inform air passengers about its processes  for making screening complaints; however, as with receipt and use of  screening complaint data, it does not have an agencywide policy,  guidance, and a focal point to guide these efforts, or mechanisms to  share information on guidance and best practices among TSA airport staff  to ensure consistency in making air passengers aware of TSA processes  for submitting complaints about the screening process.
subsections: section_title: Methods at Headquarters and Airports
paragraphs: At the headquarters level, TSA’s primary method for providing information  to air passengers about TSA screening policies and processes is through  the agency’s website. During fiscal year 2012, TSA made improvements  to its website to make it easier for air passengers to find information about  how to provide feedback to TSA, including compliments and complaints,  according to TSA officials. For example, the home page of TSA’s website  currently displays an icon that allows air passengers to ask questions or  submit feedback directly to TSA staff via an electronic form. The home  page also displays an icon that provides information for air passengers to  contact the TCC, which receives the majority of documented air- passenger-screening-related complaints, and other TSA units involved in  addressing screening complaints. At the airport level, TSA has developed  several methods that local TSA staff can use to provide information at the  checkpoints for air passengers to submit feedback to TSA, such as  displaying signs and stickers and providing customer comment cards that  contain information for contacting TSA and that allow air passengers to  submit compliments and complaints.
Figure 9 shows examples of TSA’s methods for informing air passengers  on how to submit feedback to the agency.
TSA has developed standard signs, stickers, and customer comment  cards that can be used at airport checkpoints to inform air passengers  about how to submit feedback to the agency; however, in the absence of  agencywide policy and guidance to inform air passengers, FSDs have  discretion in how and whether to use these methods. As a result, there  was inconsistent implementation of these methods at the six airports we  contacted. For example, at one airport we visited, all four checkpoints had  visible signs and stickers advertising TSA’s contact information, while at  another airport, we did not observe any signs or visible materials at the  checkpoints advertising how to contact TSA, and at a third airport, we  observed signs that were partially obscured from air passengers’ view.  Specifically, at one checkpoint at that third airport, we observed a sign  with a quick response code for providing feedback to TSA about  passengers’ screening experience. However, this sign was placed in a  corner away from direct air passenger traffic. Also, as previously  discussed, at two of six airports we contacted, customer comment cards  were displayed at the checkpoint, while at two other airports customer  comment cards were provided only to air passengers who specifically ask  for the cards or TSA contact information or who request to speak with a  screening supervisor or manager, according to TSA airport officials. As  mentioned earlier, passengers who are concerned about being late for  their flight or about appearing uncooperative may be reluctant to ask for  such cards, however. At the remaining two airports, customer comment  cards were not used, according to TSA officials at those airports.  Representatives from four of the eight aviation industry groups that we  interviewed also stated that the type and amount of information provided  to air passengers about feedback mechanisms, such as how to submit  complaints, vary among airports.
TSA airport officials we interviewed at three of the six airports we  contacted stated that the agency could take additional actions to enhance  air passenger awareness of TSA’s complaint processes, such as posting  information on shuttle buses or providing fact sheets or brochures to air  passengers earlier in the screening process or during airport check-in.  For example, an official at one airport suggested that TSA display audio  or video materials describing TSA’s complaint process, rather than  posting more signs. Also, as we previously discussed, TSA’s screening  complaint processes entail taking corrective actions to improve screening  systems, procedures, and staff. However, if air passengers wish to submit  screening complaints but are not aware of the processes for doing so, air  passengers may be less likely to submit complaints to the agency, thus  potentially limiting the agency’s efforts to identify systemic issues and  take corrective actions or make any needed improvements to the  screening process.
The Conference Report accompanying the Consolidated Appropriations  Act, 2012, directed TSA to make every effort to ensure members of the  traveling public are aware of the procedures and process for making  complaints about passenger screening. Moreover, Standards for  Internal Control in the Federal Government states that in order to ensure  effective communication to achieve agency goals, management should  ensure there are adequate means of communicating with, and obtaining  information from, external stakeholders that may have a significant impact  on the agency’s achieving its goals. The standards also call for  agencies to develop control activities, such as policies, procedures,  techniques, and mechanisms that enforce management’s directives. TSA  has methods and made efforts to inform air passengers about complaint  processes, but opportunities exist to increase air passenger awareness,  such as through greater use of the TSA website and brochures or other  materials displayed or provided at airport checkpoints, as well as through  more consistent implementation of these efforts at airports. TSA officials  at four of the six airports we contacted also said that the agency could do  more to share best practices among customer service representatives for  addressing passenger complaints, including for informing air passengers  about complaint processes. For example, TSA holds periodic conference  calls for Customer Support Managers to discuss customer service.  However, Customer Support Managers have not used this mechanism to  discuss best practices for informing air passengers about processes for  submitting complaints, according to the officials we interviewed. Also,  TSA has not sponsored other information-sharing mechanisms, such as  training or conferences, for Customer Support Managers to learn about  best practices for informing air passengers, among other things. TSA  officials also recognize that passengers may intentionally choose not to  submit their complaints to TSA at the airport checkpoint because of the  perception that raising a complaint could result in being unfairly subjected  to additional screening or being treated rudely by screening officials. In  addition, TSA does not have a focal point to coordinate agencywide policy  for informing air passengers about complaint processes, or to suggest  additional refinements to the overall process for increasing air passenger  awareness of the complaints mechanisms.
Accordingly, greater awareness of TSA complaint processes could help  alleviate passengers’ potential reluctance to submit complaints at the  checkpoint. An agencywide policy to inform the public about the  processes for making complaints, a focal point for developing this policy  and guiding TSA’s efforts to implement it, and mechanisms for sharing  best practices among local TSA officials could help provide TSA  reasonable assurance that these activities are being conducted in a  consistent manner across commercial airports and help local TSA officials  better inform the public by learning from one another about what practices  work well.
section_title: TSA’s Complaint Resolution Processes Lack Independence, but TSA Is Taking Steps to Increase Independence
paragraphs: TSA’s complaint resolution processes do not fully conform to standards of  independence established to help ensure that these types of processes  are fair, impartial, and credible. Specifically, at the airport level, TSA  officials who are responsible for resolving air passenger complaints  (referred to in this report as complaint investigators) are not independent  of the TSA airport staff who are the subjects of the complaints. Instead,  complaint investigators are generally located in the same airport and  report to the same chain of command as the individuals who are cited in  the complaints. As previously discussed, TSA receives the bulk of the  documented screening complaints via the TCC, and, if necessary, these  complaints are ultimately investigated and resolved at the local airport  level. Under TSA’s process, complaints may be referred to other TSA  offices, such as TSA’s Disability and Multicultural Branches. These TSA  branches address complaints from all air passengers with disabilities or  medical conditions or from air passengers alleging violations of other civil  rights or civil liberties. However, all screener-related complaints are  investigated at the airport level, even for complaints that are initially  referred to the Disability or Multicultural Branch.
The American Bar Association Revised Standards for the Establishment  and Operation of Ombuds Offices, which can be used to guide federal  complaint processes, states that a key indicator of independence is  whether anyone subject to the ombudsman’s jurisdiction can control or  limit the ombudsman’s performance of assigned duties. Further, the  ombudsman is to conduct inquiries and investigations in an impartial  manner, free from initial bias and conflicts of interest. Similarly, the U.S.  Ombudsman Association advocates that to maintain independence, the  ombudsman should have the discretion to prescribe how complaints are  to be made, received, and acted upon, including the scope and manner of  investigations. Moreover, to ensure impartiality, the ombudsman should  absent himself or herself from involvement in complaints where a conflict  of interest or the appearance of conflict of interest may exist. These  standards maintain that independence and impartiality are important  when addressing complaints because they establish confidence that the  process is fair and credible. While TSA is not required to comply with  ombudsman standards, these voluntary standards can serve as a useful  guideline for implementing the core principles of an effective complaint- handling process. In addition, Standards for Internal Control in the  Federal Government states that key duties and responsibilities need to be  divided or segregated among different people.
At all six airports that we contacted, TSA Customer Support Managers  stated that they receive air passenger complaints, review video footage of  the incident, and communicate with complainants about the status and  resolution of their complaints. Customer Support Managers also stated  that they do not conduct formal investigations to determine the cause of a  complaint or whether the screener involved in the complaint was at fault  or the air passenger was misinformed. Rather, at the five airports that we  contacted at which TSA has direct responsibility for screening operations,  the Customer Support Managers collect information about the facts and  circumstances related to the complaint and forward this information to the  screener’s supervisory chain. At these five airports, the TSA screener supervisor or manager is responsible for obtaining the screener’s  statement and determining fault as well as any corrective actions that  may be taken against the screener. However, TSA Customer Support  Managers as well as all TSA screening personnel, including TSA  screening supervisors and managers, report to FSDs, and are therefore  in the same chain of command as the subjects of air passenger  complaints. Because FSDs may be concerned about complaints reflecting  negatively on their management of TSA screening operations, this raises  questions about independence and the appearance of impartiality and  their ability to conduct credible, unbiased investigations. Figure 10 depicts  a simplified example of the typical reporting structure at airports at which  TSA has direct responsibility for screening operations.
TSA officials stated that the desire to resolve complaints locally led to  TSA’s decision to allow complaint investigators to be located in the same  airport with those whom they are investigating. Also, TSA officials noted  that resource constraints may limit the agency’s ability to send TSA  officials from headquarters offices to conduct independent investigations  of complaints at each airport. However, the lack of independence of the  complaint investigators creates the potential for a conflict of interest to  arise between the investigator and the individual under investigation. For  this reason, in accordance with ombudsman standards, it is important for  the structure of the complaint process to ensure the independence of  complaint investigators in order to maintain impartial investigations, as  well as to maintain the appearance of impartiality during investigations,  not only to ensure that they are being fair, but also to uphold the  credibility of the complaint process. Having a more independent complaint  resolution process would better position TSA to make informed and  unbiased decisions about complaints and ensure that corrective actions  are taken, as needed, against screeners who are reported to have  exhibited unprofessional or inappropriate behavior with air passengers.
While TSA has an Ombudsman Division that could help ensure greater  independence in the complaint processes, it primarily focuses on handling  internal personnel matters and is not yet fully equipped to address  external complaints from air passengers, according to the head of that  division. However, recognizing the importance of independence in the  complaint processes, TSA is developing a new process for referring air  passenger complaints directly to this office from airports and for providing  air passengers an independent avenue to make complaints about airport  checkpoint screening. In August 2012, during the course of our review,  TSA’s Ombudsman Division began addressing a small number of air  passenger complaints forwarded from the TCC, according to the head of  that division. TSA also began advertising the division’s new role in  addressing passenger screening complaints via the TSA website in  October 2012. The Assistant Administrator of TSA’s Office of Civil Rights  & Liberties, Ombudsman and Traveler Engagement stated that she  expected the Ombudsman Division to begin addressing a greater number  of air passenger complaints as a result. According to the Assistant  Administrator, the division will not handle complaints for which there  exists an established process that includes an appeal function, such as  disability complaints or other civil rights or civil liberties complaints, in  order to avoid duplication of currently established processes. Since the  external function of the Ombudsman Division has not yet been fully  implemented, it is too early to assess the extent to which this new  function of the complaints resolution process will conform to professional  standards for organizational independence, and help mitigate possible  concerns about impartiality and objectivity.
TSA is also in the process of developing a Passenger Advocate Program,  which the agency plans to begin implementing by January 2013,  according to the Assistant Administrator of TSA’s Office of Civil Rights &  Liberties, Ombudsman and Traveler Engagement. This program will entail  training selected TSA airport staff to take on a collateral passenger  advocate role, according to that official. Passenger advocates will  respond in real time to identify and resolve traveler-related screening  complaints quickly, consistent with TSA policies and screening  procedures, according to the Assistant Administrator. Advocates will also  respond to air passenger requests, assist air passengers with medical  conditions or disabilities, and be prepared to assist air passengers who  provide advance notification to TSA via the national TSA Cares helpline.  According to the Assistant Administrator, the Passenger Advocate  Program will work in conjunction with the new external complaint function  of the Ombudsman Division and provide air passenger advocates with the  option to refer air passengers directly to the Ombudsman Division.  Because passenger advocates are to serve under the FSD chain of  command, this arrangement also raises questions about whether there is  a lack of independence between passenger advocates and the subjects  of air passenger complaints. The Assistant Administrator explained that  any perception of lack of independence would be addressed by training  passenger advocates to explain to air passengers that they may submit  complaints directly to the Ombudsman, who is outside of the airport chain  of command. Because this program has not yet been approved by the  TSA Administrator or implemented, it is too early to assess the extent to  which passenger advocates will help mitigate possible concerns about  impartiality and objectivity in the complaint processes.
section_title: Conclusions
paragraphs: According to available data, TSA receives a relatively small number of  complaints considering the millions of air passengers the agency screens  each month. However, the agency’s ability to understand the full nature  and extent of those complaints is limited because TSA does not  systematically collect some of the screening complaint data at the airport  level, uses only some of the data it has available to it in its reports and  analysis, and collects the data in a manner that makes it difficult for the  agency to aggregate and analyze the data for trends. Further, the  inconsistent nature of implementation of the screening complaint  processes at commercial airports limits TSA’s ability to oversee these  efforts. Thus, a policy to consistently guide agencywide efforts to receive,  track, and report air passenger screening complaints would help provide  TSA reasonable assurance that TSA headquarters and airport entities are  conducting these activities consistently. Moreover, a consistent process  to systematically analyze information on air passenger screening  complaints from all mechanisms for receiving complaints, including  standardized screening complaint categories and capabilities for data  analysis, would give TSA a more comprehensive picture of the volume,  nature, and extent of air passenger screening complaints and better  enable the agency to improve screening operations and customer  service. In addition, designating a focal point for developing and  coordinating agencywide policy on air passenger screening complaint  processes, guiding the analysis and use of the agency’s screening  complaint data, and informing the public about the nature and extent of  screening complaints would help ensure that these efforts are  implemented consistently throughout the agency. Finally, TSA has a  number of methods to inform the public about its processes for submitting  screening complaints, but does not have an agencywide policy to guide  these efforts or mechanisms for sharing best practices for informing air  passengers about screening complaint processes, which could help TSA  staff—particularly at the airport level—better inform the public by learning  from one another about what is working well.
section_title: Recommendations for Executive Action
paragraphs: To improve TSA’s oversight of air passenger screening complaint  processes, we recommend that the Administrator of TSA take the  following four actions, consistent with standards for internal control, to establish a consistent policy to guide agencywide efforts for receiving,  tracking, and reporting air passenger screening complaints; establish a process to systematically compile and analyze information  on air passenger screening complaints from all complaint  mechanisms; designate a focal point to develop and coordinate agencywide policy  on screening complaint processes, guide the analysis and use of the  agency’s screening complaint data, and inform the public about the  nature and extent of screening complaints; and establish agencywide policy to guide TSA’s efforts to inform air  passengers about the screening complaint processes and establish  mechanisms, particularly at the airport level, to share information on  best practices for informing air passengers about the screening  complaint processes.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Department of Homeland Security  (DHS) for comment. DHS, in written comments received October 16,  2012, concurred with the recommendations and identified actions taken,  under way, or planned to implement the recommendations. Written  comments are summarized below, and official DHS comments are  reproduced in appendix I. In addition, DHS provided written technical  comments, which we incorporated, as appropriate.
In response to our recommendation that TSA establish a consistent policy  to guide agencywide efforts for receiving, tracking, and reporting air  passenger screening complaints, DHS concurred with the  recommendation and stated that TSA would review current intake and  processing procedures at headquarters and in the field and develop  policy, as appropriate, to better guide the efforts of headquarters and field  locations in receiving, tracking, and reporting air passenger screening  complaints. We believe that these are beneficial steps that would address  our recommendation, provided that the resulting policy refinements  improve the existing processes for receiving, tracking, and reporting all air  passenger screening complaints, including the screening complaints that  air passengers submit locally at airports through comment cards or in  person at security checkpoints.
In response to our recommendation that TSA establish a process to  systematically compile and analyze information on air passenger  screening complaints from all complaint mechanisms, DHS concurred  with the recommendation and stated that TSA, through the TCC, is taking  steps to increase its analysis of passenger complaint information and will  build on this effort to further compile and analyze information on air  passenger screening complaints. However, DHS did not provide  additional details on the steps TSA is taking, so we cannot comment on  the extent to which these steps will fully address our recommendation. In  its technical comments, TSA stated that the agency began channeling  information from the Talk to TSA database to the TCC on October 3,  2012, and we updated our report accordingly. However, it is still unclear  whether TSA will compile and analyze data from the Talk to TSA  database and its other centralized mechanisms in its efforts to inform the  public about the nature and extent of screening complaints and whether  these efforts will include data on screening complaints submitted locally at  airports through customer comment cards or in person at airport security  checkpoints. It is also unclear how TSA will address the difficulties we  identified in collecting standardized screening data across different  complaint categories and mechanisms. As highlighted in our report,  establishing a consistent process to systematically compile and analyze  information on air passenger screening complaints will help provide TSA  with a more comprehensive picture of the volume, nature, and extent of  air passenger screening complaints and better enable the agency to  improve screening operations and customer service for the traveling  public.
In response to our recommendation that TSA designate a focal point for  the complaints identification, analysis, and public outreach process, DHS  concurred with the recommendation and stated that the Assistant  Administrator for the Office of Civil Rights & Liberties, Ombudsman and  Traveler Engagement is the focal point for overseeing the key TSA  entities involved with processing passenger screening complaints. We are  encouraged that the agency has identified a focal point for these efforts  but note that the Assistant Administrator only oversees the TSA’s  complaint-related processes in the Office of Civil Rights & Liberties,  Ombudsman and Traveler Engagement. Thus, it will be important for the  Assistant Administrator to coordinate with other TSA offices when acting  as the TSA focal point to address the weaknesses we identified in our  report. For example, as mentioned in DHS’s comment letter, it will be  important for the Assistant Administrator to work closely with the office of  the Assistant Administrator of Security Operations because this office  oversees screening operations at commercial airports and security  operations staff in the field who receive screening complaints submitted  through customer comment cards or in person at airport security  checkpoints. The Assistant Administrator for the Office of Civil Rights &  Liberties, Ombudsman and Traveler Engagement will also need to  coordinate with the Office of the Executive Secretariat, which is not  mentioned in DHS’s comment letter, given the thousands of air passenger  complaints that this office receives, as well as with other DHS and TSA  offices that have a role in the air passenger complaint processes— including, but not limited to, the TSA Office of Inspections, TSA Office of  Legislative Affairs, and the DHS Office of the Inspector General.
In response to our recommendation that TSA establish agencywide policy  to guide TSA’s efforts to inform air passengers about the screening  complaint processes and establish mechanisms, particularly at the airport  level, to share information on best practices for informing air passengers  about the screening complaint processes, DHS concurred with the  recommendation. DHS stated that TSA would develop a policy to better  inform air passengers about the screening complaint processes, to  include mechanisms for identifying and sharing best practices for  implementing these processes at the airport level. We will continue to  monitor TSA’s progress in implementing this recommendation.
We are sending copies of this report to the Secretary of Homeland  Security, the TSA Administrator, appropriate congressional committees,  and other interested parties. In addition, the report is available at no  charge on the GAO website at http://www.gao.gov.
If you or your staff have any questions concerning this report, please  contact me at (202) 512-4379 or at lords@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  that last page of this report. GAO staff who made major contributions to  this report are listed in appendix II.
section_title: Appendix I: Comments from the Department of Homeland Security
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Jessica Lucas-Judy (Assistant  Director), Carissa Bryant, and Juan Tapia-Videla made significant  contributions to the work. Also contributing to this report were David  Alexander, Lydia Araya, Tom Lombardi, Lara Miklozek, and Linda Miller.