CBP Unable to Tell if C-TPAT Members Getting Benefits Due to Inaccurate Data, GAO Says

While program officials are “analyzing the Dashboard to finalize an action plan” to address the integrity of data, it is too early to know the extent of issues that the review will cover, the GAO said. The Department of Homeland Security (DHS) concurred with a GAO recommendation for CBP to develop a plan with “milestones and completion dates” to repair the Dashboard and improve the accuracy of the system’s data.

GAO’s preliminary review of C-TPAT program data across the air, truck, vessel and rail modes of transportation from fiscal year 2011 to fiscal year 2015 indicated that C-TPAT member shipments didn’t consistently experience shorter processing times or reduced exam and hold rates compared with non-members’ shipments across the same transportation modes. The C-TPAT director and staff familiar with the Dashboard “expressed surprise” that the data didn’t show a more regular administration of benefits and that C-TPAT Tier 2 members did not consistently enjoy quicker processing or fewer exams and holds, despite a statement in CBP’s fiscal 2016 budget request that C-TPAT importers are four to six times less likely than outsiders to incur a security or compliance exam, GAO said.

CBP doesn’t collect data on other stated C-TPAT member benefits, such as access to C-TPAT security specialists, partly because of natural difficulties in quantifying benefits that have a qualitative nature and in capturing a big-picture view across ports with varying infrastructures, GAO said. C-TPAT officials plan to primarily focus on identifying and correcting data issues for currently tracked core benefits instead of extending C-TPAT tracking to other benefits, the report says.

C-TPAT officials told GAO that “there appear to be” errors in the data or in “formulas used to compute various actions that are uploaded into the Dashboard, such as shipment examinations, holds, and processing times,” the report says. The C-TPAT office hasn’t regularly reviewed Dashboard data, and program officials haven’t identified factors behind the “apparent accuracy and reliability issues” of Dashboard data. CBP staff haven’t completed verification, user acceptance testing, or periodic data checks of the Dashboard “because of competing priorities,” and CBP officials said new requirements need to be verified and tested, according to the report. C-TPAT and Targeting and Analysis System Program Directorate staff are analyzing Dashboard data to develop an action plan to correct the problems, the report says. “Despite these issues, C-TPAT officials are exploring new member benefits, and industry officials we met with generally spoke positively of the C-TPAT program,” the report summary says.

In addition to Dashboard data issues, recordkeeping problems in C-TPAT’s internal Portal 2.0 data management system have made it more difficult for CBP to complete certifications, security validations and revalidations in a timely and efficient fashion, the report says. Noting that backup manual tracking methods sometimes vary across field offices, GAO recommended that CBP issue blanket standards to improve the accuracy of field offices’ company certification data. As CBP transitioned from the Portal 1.0 to Portal 2.0 C-TPAT content management system in August 2015, the new software incorrectly changed C-TPAT members’ certification or security validation dates, according to C-TPAT field office directors and security specialists who talked with GAO.

The Portal 2.0 glitches have sometimes required CBP to manually verify member data and hampered the ability of C-TPAT security specialists to complete security validations in a timely and efficient manner, the report says. CBP staff reported to GAO that unclear requirements for Portal 2.0’s and users’ needs, as well as poor testing, contributed to the technological problems. While C-TPAT officials told the GAO that field offices are conducting C-TPAT record reviews, and that the offices “have assurance” of required security validations being tracked and completed, those field office reviews were developed without any standardized guidance from C-TPAT headquarters, the report says.

GAO recommended that the CBP commissioner develop standardized guidance for C-TPAT field offices to use in tracking and reporting information on the number of required and completed security validations. “While the current validation tracking processes used by field offices do account for security validations conducted over the year, standardizing the process used by field offices for tracking required security validations could strengthen C-TPAT management’s assurance that its field offices are identifying and completing the required security validations in a consistent and reliable manner,” the report says. DHS concurred with the report’s recommendations, and in an attached letter to the GAO, Jim Crumpacker, director of DHS’s GAO-Office of Inspector General Liaison Office, noted that several improvements have been made to the C-TPAT portal since December 2016, including importer and exporter entity security profile questions, international harmonization and verification of status between partners. CBP staff told GAO they would continue to work to identify and address potential root causes of portal problems through this year, the report said.