The U.S. Government Accountability Office (GAO) today released a report concerning its evaluation of U.S. Customs and Border Protection's (CBP) Customs-Trade Partnership Against Terrorism (C-TPAT) program. In the report released today, the GAO recommended that CBP develop: (1) standardized guidance for field offices regarding the tracking of information on security validations; and (2) a plan with milestones and completion dates to fix the “dashboard” data reporting tool, so the C-TPAT program can produce accurate data on C-TPAT member benefits.
The GAO report assesses the extent to which: (1) CBP is meeting its security validation responsibilities; and (2) C-TPAT members are receiving benefits.
The title of the GAO report is: Supply Chain Security: Providing Guidance and Resolving Data Problems Could Improve Management of the Customs-Trade Partnership Against Terrorism Program, GAO-17-84: (February 8, 2017). Read the report on the GAO release.
C-TPAT, is a voluntary program in which CBP staff validate that members' supply chain security practices meet minimum security criteria. In return, members are eligible to receive benefits, such as a reduced likelihood their shipments will be examined.
Staff from the C-TPAT program have faced challenges in meeting C-TPAT security validation responsibilities because of problems with the functionality of the program's data management system (Portal 2.0). In particular, since the system was updated in August 2015, C-TPAT staff have identified instances in which the Portal 2.0 system incorrectly altered C-TPAT members' certification or security profile dates, requiring manual verification of member data and impairing the ability of C-TPAT security specialists to identify and complete required security validations in a timely and efficient manner. While the focus of CBP's staff was initially on documenting and addressing Portal 2.0 problems as they arose, the staff have begun to identify root causes that led to the Portal 2.0 problems. For example, CBP staff cited unclear requirements for the system and its users' needs—coupled with inadequate testing—as factors that likely contributed to problems.
In response, CBP staff have outlined recommended actions, along with timeframes for completing the actions. The staff will continue to work on identifying and addressing potential root causes of the Portal problems through 2017. C-TPAT officials advised the GAO that despite the Portal 2.0 problems, they believe that required security validations are being tracked and completed as a result of record reviews taking place at field offices. However, the field office reviews were developed in the absence of standardized guidance from C-TPAT headquarters. 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.
CBP cannot determine the extent to which C-TPAT members are receiving benefits because of data problems. Specifically, since 2012, CBP has compiled data on certain events or actions it has taken regarding arriving shipments—such as examination and hold rates and processing times—for both C-TPAT and non-C-TPAT members through its “dashboard” data reporting tool. However, on the basis of GAO's preliminary analyses and subsequent data accuracy concerns cited by C-TPAT program officials, GAO determined that data contained in the dashboard could not be relied on for accurately measuring C-TPAT member benefits. Also, CBP has likely relied on such “questionable data” since it developed the dashboard in 2012 and, thus, cannot be assured that C-TPAT members have consistently received the benefits that CBP has publicized.
C-TPAT officials stated that they are analyzing the dashboard to finalize an action plan to correct the data concerns. C-TPAT officials also are exploring new member benefits, and industry officials generally have spoken positively of the C-TPAT program.
For more information, contact a professional with KPMG’s Trade & Customs practice:
Douglas Zuvich | +1 (312) 665-1022 | firstname.lastname@example.org
Andrew Siciliano | +1 (631) 425-6057 | email@example.com
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