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United States Government Accountability Office:
GAO: 

Report to Congressional Requesters: 

September 2012: 

Homeland Security: 

Agriculture Inspection Program Has Made Some Improvements, but 
Management Challenges Persist: 

GAO-12-885: 

GAO Highlights: 

Highlights of GAO-12-885, a report to congressional requesters. 

Why GAO Did This Study: 

According to DHS, invasive species cause an estimated $136 billion in 
lost agricultural revenue annually, and since September 11, 2001, 
concerns have persisted about the vulnerability of agriculture to 
deliberate introduction of foreign pests and disease. DHS and USDA 
manage the AQI program, which places agriculture inspectors at U.S. 
ports of entry to inspect imported agriculture products and intercept 
foreign pests. GAO reported in 2006 on management challenges in the 
program and made seven recommendations to improve it. GAO was asked to 
examine the extent to which (1) DHS and USDA implemented GAO’s 
recommendations; (2) data on arrivals, inspections, and interceptions 
are used for managing the program; and (3) the views of AQI 
agriculture specialists on their work environment have changed since 
2006. GAO surveyed a representative sample of agriculture specialists 
and supervisors; reviewed key documents and inspection procedures; 
visited five selected ports of entry based on size and entry pathways, 
such as air or sea; interviewed DHS and USDA officials; and reviewed 
AQI data. The survey instrument and most results can be viewed at 
[hyperlink, http://www.gao.gov/products/GAO-12-884SP]. 

What GAO Found: 

The Department of Homeland Security (DHS) and the U.S. Department of 
Agriculture (USDA) have taken steps to implement all seven of the 
recommendations GAO made in 2006 to improve the Agriculture Quarantine 
Inspection (AQI) program, but they face challenges in fully 
implementing four of them. Specifically, DHS and USDA have implemented 
GAO’s recommendations to improve information sharing, review DHS’s 
financial management system for the AQI program, and remove barriers 
to timely and accurate transfers of AQI user fees—collected for AQI 
services provided in connection with the arrival of international air 
passengers and conveyances at U.S. ports. However, DHS and USDA face 
challenges in fully implementing GAO’s recommendations to adopt 
meaningful performance measures, establish a national risk-based 
staffing model, improve the agriculture canine program, and revise 
user fees to cover program costs. For example, in 2006, GAO 
recommended that DHS and USDA adopt meaningful performance measures 
for assessing the AQI program’s effectiveness at intercepting foreign 
pests and disease. DHS and USDA have expanded the use of one type of 
performance measure but have not developed measures for all aspects of 
the AQI program that are important for its management. In addition, 
the AQI program does not have a strategic plan—a leading practice that 
would provide DHS and USDA with a framework for defining the mission 
of what the program seeks to accomplish, setting goals to achieve 
desired results, and identifying performance measures for gauging 
progress toward those goals. Furthermore, DHS has undertaken efforts 
to respond to GAO’s recommendation to develop a national, risk-based 
staffing model but does not yet have one, and DHS anticipates that the 
model will recommend significant staffing increases. DHS officials 
told GAO they do not have the resources to increase staff, but the 
agency has not developed a plan that assesses the risk of potential 
fiscal constraints on its ability to implement the staffing model. 
Without a plan or strategy to address potential resource constraints 
on staffing by considering the fiscal resources that may realistically 
be available, DHS risks increasing the vulnerability of the 
agriculture sector to foreign pests and disease. 

The AQI program uses data on arrivals, inspections, and interceptions 
at U.S. ports of entry to determine how well agriculture inspections 
identify prohibited materials and to review ports’ performance, but 
data quality issues may prevent AQI program officials from making full 
use of the data. For example, the data may not be reliable. DHS and 
USDA recognize that data quality is an ongoing issue and in 2004 
created an interagency group to address this issue. However, from 2010 
to 2011, joint DHS-USDA reviews of 22 selected ports found 
discrepancies in the data at about half of the ports reviewed (10 out 
of 22). Data reliability has the potential to affect other key efforts 
that are currently under way, such as the program’s staffing model. 
Without reliable data, AQI program officials do not have assurance 
that they have the information needed to manage the program. 

GAO also presents analysis of survey data from 2006 and 2012 on 
agriculture specialists’ and supervisors’ views about their work 
environment. 

What GAO Recommends: 

GAO recommends, among other things, that (1) DHS and USDA develop a 
joint strategic plan for the AQI program, (2) DHS develop a plan for 
implementing a staffing model, and (3) DHS and USDA take steps to 
improve the reliability of certain data. DHS and USDA agreed with the 
recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-12-885]. To view the 
e-supplement online, click on [hyperlink, 
http://www.gao.gov/products/GAO-12-884SP]. For more information, 
contact Lisa Shames at (202) 512-3841 or shamesl@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

DHS and USDA Have Taken Steps to Implement GAO's Seven 
Recommendations, but Have Not Fully Implemented Four of Them: 

Limitations in the Arrival, Inspection, and Interception Data May 
Hinder Their Use in Managing the Program: 

Survey Responses Show Some Changes in Agriculture Specialists' Views: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Summary of Responses to Open-ended Survey Questions in 
2006 and 2012: 

Appendix III: Comments from the U.S. Department of Agriculture: 

Appendix IV: Comments from the Department of Homeland Security: 

Appendix V: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Estimates for the Closed-ended Question "Do You Believe That 
You Are Sufficiently Trained to Perform Your Agriculture Inspection 
Duties?" (in percent): 

Table 2: Estimates for the Closed-ended Question "Is the Information 
Delivered to You in a Timely Manner to be Useful?" (in percent): 

Table 3: Estimates for the Closed-ended Question "Do You Have Enough 
Time to Look for Pests in Agriculture Materials Intercepted from 
Passengers?" (in percent): 

Table 4: Estimates for the Closed-ended Question "In General, Do You 
Feel that the Work of a CBP Agriculture Specialist Is Respected by CBP 
Officers and Management?" (in percent): 

Table 5: Estimates for the Closed-ended Question "In Your Experience, 
Does Your Port Currently Have Enough Agriculture Specialists to Carry 
Out Agriculture Duties?" (in percent): 

Table 6: GAO Summary of Responses to the Open-ended Question "What Is 
Going Well with Respect to Your Work as an Agriculture Specialist?" in 
2006 Compared with 2012: 

Table 7: GAO Summary of Responses to the Open-ended Question "What 
Would You Like to See Changed or Improved with Respect to Your Work as 
an Agriculture Specialist?" in 2006 Compared with 2012: 

Figure: 

Figure 1: Example of Primary and Secondary Inspection Procedures at an 
Airport: 

Abbreviations: 

APHIS: Animal and Plant Health Inspection Service: 

AQI: Agricultural Quarantine Inspection: 

CBP: Customs and Border Protection: 

DHS: Department of Homeland Security: 

GPRA: Government Performance and Results Act: 

PPQ: Plant Protection and Quarantine: 

USDA: U.S. Department of Agriculture: 

WADS: Work Accomplishment Data System: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

September 27, 2012: 

Congressional Requesters: 

The United States is one of the world's largest producers, consumers, 
exporters, and importers of agricultural commodities. However, some of 
these imported products may contain exotic pests and diseases. 
According to the Department of Homeland Security (DHS), invasive 
species cause an estimated $136 billion in lost agricultural revenue 
annually. For example, the Asian Longhorned Beetle has destroyed more 
than 30,000 trees in Illinois, New Jersey, and New York since it was 
discovered in 1996 in imported cargo, and it remains a significant 
problem today. Damages for this infestation have been estimated at 
more than $269 million, and according to the U.S. Department of 
Agriculture (USDA), if the infestation were to expand nationwide, it 
could cause more than $41 billion in losses. Furthermore, the 
terrorist attacks of September 11, 2001, heightened concerns about 
agriculture's vulnerability to terrorism, including the deliberate 
introduction of livestock, poultry, and crop diseases.[Footnote 1] 

Under the Agricultural Quarantine Inspection (AQI) program, 
international passengers and cargo at U.S. ports of entry are 
inspected to seize prohibited material and intercept foreign 
agricultural pests. Historically, USDA was responsible for the AQI 
program, but the Homeland Security Act of 2002 split responsibility 
for the AQI program between DHS and USDA's Animal and Plant Health 
Inspection Service (APHIS). DHS acquired the authority to inspect 
passenger declarations and cargo manifests; international passengers; 
baggage; cargo; and conveyances such as ships, aircraft, vehicles, 
buses, and rail cars; and to seize and quarantine suspect articles. 
Under this authority, DHS's Customs and Border Protection's (CBP) 
agriculture specialists perform these duties at ports of entry located 
at airports, seaports, and land borders throughout the United States. 
Inspection methods include the examination of baggage by hand, X-ray, 
and canine inspection, and the examination of documents accompanying 
incoming cargo to ensure compliance with plant and animal health and 
trade agreements. An agriculture inspection may result in an 
interception--the identification of items that may be confiscated or 
transferred to an APHIS facility for subsequent evaluation or 
treatment, depending on the product or material. APHIS remains 
responsible for setting inspection policy, overseeing CBP agriculture 
specialists' training, and managing and collecting AQI user fees--fees 
collected in connection with the arrival of international air 
passengers and conveyances at ports in the customs territory of the 
United States. 

For more than a decade, we have reported on challenges related to the 
AQI program.[Footnote 2] In particular, in 2006, we issued two reports 
on management challenges in the AQI program, including one in May 
2006, in which we identified shortcomings in the program's staffing, 
performance measures, inter-agency coordination, and inspection 
performance.[Footnote 3] In our May 2006 report, we made seven 
recommendations to DHS and USDA to improve the AQI program by (1) 
improving information-sharing, (2) undertaking a full review of DHS's 
financial management system for the AQI program, (3) removing barriers 
to timely and accurate AQI user fee transfers from USDA to DHS, (4) 
adopting meaningful performance measures, (5) establishing a national 
risk-based staffing model, (6) improving the agriculture canine 
program, and (7) revising user fees to cover AQI program costs. DHS 
and USDA generally agreed with these recommendations and in 2007 
created a joint task force to, among other things, identify and 
implement solutions. In November 2006, we issued a report with 
additional analysis of survey data from our May 2006 report regarding 
agriculture specialists' views on their work environment.[Footnote 4] 

Concerns persist that the agriculture sector remains vulnerable to the 
unintentional or deliberate introduction of pests and disease. In this 
context, you asked us to examine the AQI program. Our objectives for 
this report were to examine the extent to which (1) USDA and DHS have 
implemented recommendations we made in 2006 to improve the AQI 
program; (2) data on arrivals, inspections, and interceptions are used 
for managing the program; and (3) the views of agriculture specialists 
at CBP regarding their work environment have changed, if at all, since 
our 2006 reports. 

To address all of these objectives, we selected a nonprobability 
sample of five CBP ports of entry to visit in order to observe 
agriculture inspection work activities and discuss challenges related 
to conducting agriculture inspections and interceptions. These ports 
of entry included Austin, Texas; Baltimore, Maryland; Dallas, Texas; 
Miami, Florida; and San Ysidro, California. We selected these ports of 
entry based on size and entry pathways, such as air, sea, and land. 
Because we used a nonprobability sample, the information we obtained 
from these visits cannot be generalized to other CBP ports of entry. 
The visits instead provided us with more in-depth information on the 
perspectives of various agriculture specialists in these ports of 
entry about the management of the AQI program. 

To examine the implementation of recommendations from our May 2006 
report, we interviewed DHS and USDA officials and reviewed 
documentation and criteria related to CBP's performance measures, 
information-sharing between CBP and APHIS, DHS's financial management 
system, CBP's agriculture staffing model, CBP's agriculture canine 
program, AQI's user fee transfers, and AQI user fee modifications to 
cover AQI program costs. To examine the extent to which data on 
agriculture arrivals, inspections, and interceptions are used to 
manage the program, we reviewed DHS and USDA inspection and 
interception data, related summary reports, and policies, and 
interviewed key program officials at DHS and USDA headquarters, in the 
field, and at ports of entry. To address our objective on agriculture 
specialists' views, we developed a questionnaire to survey CBP 
agriculture specialists, which contained closed-ended and open-ended 
questions. Specifically, we surveyed a stratified random probability 
sample of 556 agriculture specialists and supervisors from the 
universe of 2,311 agriculture specialists, including supervisors and 
agriculture canine handlers at CBP. To facilitate comparison with the 
findings from our May 2006 and November 2006 reports, we developed 
similar questions for this survey. We also used the results of our 
survey to inform our analysis on the extent to which DHS and USDA have 
implemented some of the recommendations we made in 2006. We received 
an unweighted response rate of 74 percent, and the results of our 
analysis of closed-ended survey questions are generalizable to all 
agriculture specialists and supervisors at CBP. More details on our 
scope and methodology appear in appendix I. To view the full results 
of our survey, please see an electronic supplement to this report (GAO-
12-884SP). 

We conducted this performance audit from August 2011 to September 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. 

Background: 

From 1913 until 2002, USDA was responsible for the inspection of 
plants and animals at U.S. ports of entry. Following the September 11, 
2001, terrorist attacks, Congress passed the Homeland Security Act of 
2002,[Footnote 5] which combined the inspection activities of the 
Department of the Treasury's Customs Service, the Department of 
Justice's Immigration and Naturalization Service, and USDA's APHIS 
into the newly created DHS. The Secretaries of DHS and of 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. Under the memorandum of agreement, APHIS's 
responsibilities include managing user fees, overseeing agriculture 
specialists' training, and providing pest identification services; and 
CBP's responsibilities include conducting inspections and related 
activities. Consistent with the Homeland Security Act of 2002 and the 
agreement, in 2003 approximately 1,500 agriculture specialists who had 
formerly worked for APHIS became CBP employees. 

In 2003, CBP established an initiative called "One Face at the 
Border," which unified its three missions--customs, immigration, and 
agricultural inspection--by cross-training CBP customs and immigration 
officers and agriculture specialists in all three areas. The 
inspection procedures vary somewhat by the transportation pathway, 
such as airports, seaports, or land border crossings, but, generally, 
CBP officers conduct primary inspections, including interviewing 
passengers, and may refer passengers to agriculture specialists who 
conduct more detailed secondary inspections, including subsequent 
interviews of passengers or examination of baggage. Figure 1 shows an 
example of primary and secondary inspection procedures at an airport. 

Figure 1: Example of Primary and Secondary Inspection Procedures at an 
Airport: 

[Refer to PDF for image: procedure illustration] 

Primary Inspection: 

Passenger deplanes and proceeds to primary processing. 

Passenger claims baggage. 

CBP officer reviews the passenger's documents and interviews the 
passenger[A]; 
CBP agriculture canine team assesses the baggage area. 

Could passenger be carrying a prohibited agriculture item? 
No: Passenger exits the airport; 
Yes: Passenger is referred to secondary agriculture inspection. 

Secondary Inspection: 

Interview with agriculture specialist where passenger is given an 
opportunity to declare agriculture items and surrender prohibited 
commodities. 

Agriculture specialist x-rays baggage. 

Could passenger be carrying a prohibited agriculture item? 
No: Passenger exits the airport; 
Yes: Agriculture specialist manually inspects baggage. 
             
Does agriculture specialist find a prohibited agriculture item? 
No: Passenger exits the airport; 
Yes: Agriculture specialist seizes prohibited item[B]. 

Agriculture specialist determines if the items were declared, and if 
not, may issue a fine. 

Agriculture specialist releases passenger and baggage. 

Passenger exits the airport. 
                        
Source: GAO analysis of CBP documents and interviews; Art Explosion 
(clip art). 

[A] During the interview, the CBP officer offers the passenger the 
opportunity to amend documents and declare items. 

[B] After seizing the material, the agriculture specialist either 
sends an unknown detected pest to the APHIS pest identifiers or sends 
the material to the incinerator to be destroyed. 

[End of figure] 

As of April 2012, approximately 2,360 CBP agriculture specialists, 
including those who formerly worked with APHIS and those hired by CBP, 
were assigned to about half, or 167 of the 329 U.S. ports of entry. 
Each U.S. port of entry can include one or more pathway, such as 
airports, seaports, or land border crossings. For example, the port of 
Baltimore, Maryland, has an airport and seaport, whereas the port of 
Dallas, Texas, has just an airport. CBP port directors are responsible 
for overseeing operations at ports of entry and assigning agriculture 
specialists to specific port facilities. The ports of entry are 
organized into 20 district field offices across the United States, and 
these district offices are headed by CBP field office directors who 
also serve as liaisons between CBP headquarters and port management. 
In 2005, APHIS and CBP established a formal assessment process at 
select ports--known as joint quality assurance reviews--to ensure that 
ports of entry carry out agricultural inspections in accordance with 
APHIS's regulations, policies, and procedures. APHIS and CBP spent 
about $33,000 conducting eight such reviews in 2011, and, according to 
CBP officials, the reviews focus on ports that are considered to be 
high risk for agriculture. 

The Food, Agriculture, Conservation, and Trade Act of 1990, as 
amended, authorizes the Secretary of Agriculture to set and collect 
user fees for AQI services provided in connection with the arrival, at 
a port in the customs territory of the United States, of commercial 
vessels, commercial trucks, commercial railroad cars, commercial 
aircraft, and international passengers.[Footnote 6] The Secretary 
subsequently delegated this authority to APHIS. The fees are paid 
either directly by shipping companies or indirectly by air passengers 
through fees on tickets. CBP collects user fees for commercial vessels 
and trucks and deposits the collections into APHIS's user fees 
account. APHIS collects all other user fees and periodically transfers 
a pre-agreed portion of the total collections to CBP to support CBP's 
agriculture-related operations. APHIS has revised the AQI user fees 
several times since the act was passed. For example, through the 
rulemaking process, APHIS increased the user fees in November 1999 
and, in January 2003, extended the adjusted fees indefinitely. In 
August 2006, APHIS published a final rule affirming a December 2004 
interim rule that increased user fees again. We have previously 
reported on how the fees are set, collected, and distributed, and the 
benefits and challenges of this process to agencies and stakeholders, 
including the implications of consolidating these fees under the 
authority of DHS.[Footnote 7] 

DHS and USDA Have Taken Steps to Implement GAO's Seven 
Recommendations, but Have Not Fully Implemented Four of Them: 

DHS and USDA took steps to implement all seven recommendations we made 
in our May 2006 report, but they faced challenges fully implementing 
four of them. 

DHS and USDA Have Implemented Three Recommendations to Enhance the 
Effectiveness of the AQI Program: 

DHS and USDA have implemented our recommendations to (1) improve 
information-sharing, (2) undertake a full review of DHS's financial 
management system for the AQI program, and (3) remove barriers to 
timely and accurate AQI user fee transfers from USDA to DHS. 

Improve information-sharing. In our May 2006 report,[Footnote 8] we 
recommended that DHS and USDA ensure that they more effectively share 
urgent alerts and other information essential to safeguarding U.S. 
agriculture and that they transmit such information to agriculture 
specialists at the ports. At that time, we reported that agriculture 
specialists were not consistently receiving notifications of changes 
to inspection procedures or policies and urgent alerts from APHIS--
notices of emerging concerns about foreign pests and diseases--in a 
timely manner. In response to our recommendation, in 2007, DHS 
established the position of Deputy Executive Director for Agriculture 
Operational Oversight to serve as a primary point of contact for 
coordination among CBP, APHIS, and AQI stakeholders, such as state 
departments of agriculture, who would be largely responsible for 
eradicating foreign pests. In addition, CBP implemented a policy to 
disseminate urgent agriculture alerts to its field offices within 24 
hours of receipt, and the alerts are then disseminated to agriculture 
specialists at the ports. These alerts, as well as any changes in 
inspection procedures or policies, are also available on the AQI 
program's intranet site. Our survey results indicate that an estimated 
83 percent of the agriculture specialists and supervisors at CBP found 
that information regarding agriculture regulatory changes was 
delivered in a timely manner either always or most of the 
time.[Footnote 9] Our survey results also indicate that an estimated 4 
percent of agriculture specialists and supervisors at CBP believe that 
the timeliness of information provided to agriculture specialists is a 
very major challenge, while an estimated 57 percent believe it is only 
a minor challenge or not a challenge.[Footnote 10] 

Review DHS's financial management system. In 2006, we recommended that 
DHS 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.[Footnote 11] At that time, CBP's financial management 
system did not separately track time spent on agriculture activities 
from other types of activities. For example, a CBP officer conducting 
a primary inspection of an air passenger could ask questions related 
to immigration, customs, and agriculture activities, but only the time 
spent asking questions related to agriculture would generate AQI user 
fees and need to be reported to APHIS. However, CBP's financial system 
did not track this time separately. As a result, CBP provided APHIS 
with estimates of the time spent on agriculture activities and the 
associated costs. Since we last reported, CBP added agriculture-
specific activity codes to its financial management system, which, 
according to CBP officials, allows CBP to provide APHIS with actual 
costs related to user fees. In addition, CBP issued guidance to 
clarify how employees should account for activities that are 
simultaneously related to immigration, customs, and agriculture 
activities so that this information could be tracked for the purpose 
of collecting AQI user fees. According to APHIS and CBP officials, the 
new activity codes and guidance allow CBP to accurately report its 
costs by user fee type to APHIS and ensure financial accountability 
for funds allocated to AQI user fees. 

Accurately transfer user fees. In 2006, we recommended that USDA take 
steps to assess and remove barriers to the timely and accurate 
transfer of AQI user fees to DHS.[Footnote 12] At that time, transfers 
of user fees from USDA's APHIS to DHS's CBP were often delayed and 
their amounts were sometimes less than CBP expected, which adversely 
affected agricultural inspection activities. For example, in 2006, we 
reported that during fiscal years 2004 and 2005, CBP frequently did 
not receive the transfers at the time specified or for the agreed upon 
amount, causing some ports to reduce spending for supplies or to delay 
hiring or purchasing equipment. Since that time, APHIS and CBP have 
fully implemented a user fee transfer agreement that allows for a 
bimonthly transfer schedule that better accommodates the inflow of AQI 
user fee funds. This new user fee agreement also created chief budget 
liaisons at APHIS and CBP and provides for meetings at least 4 times a 
fiscal year to discuss AQI funding. Our analysis of transfer records 
provided by APHIS shows that, from fiscal year 2006 through 2011, 34 
of the 36 scheduled user fee transfers were made in accordance with 
the new, bimonthly transfer schedule. During that time, six scheduled 
transfers were less than the scheduled amount, and, for each, APHIS 
made up the difference either by adding an unscheduled transfer or by 
adding the difference to the next scheduled transfer. APHIS and CBP 
officials told us that transfers have been more timely and accurate 
since the changes were implemented. 

DHS and USDA Faced Challenges Implementing Four of Seven 
Recommendations: 

DHS and USDA faced challenges in fully implementing our 
recommendations to (1) adopt meaningful performance measures, (2) 
establish a national risk-based staffing model, (3) improve the 
agriculture canine program, and (4) revise user fees to cover AQI 
program costs. 

Adopt Meaningful Performance Measures: 

In 2006, we recommended that DHS and USDA 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 and posing a risk to U.S. agriculture. 
[Footnote 13] At that time, CBP had not adopted performance measures 
that took into account the agency's expanded mission or considered all 
pathways by which prohibited agriculture items or foreign pests may 
enter the country. In response to our recommendation, in 2007, APHIS 
and CBP created a joint task force that expanded existing performance 
measures to more pathways, including passengers' baggage, pedestrians, 
and vehicles, as well as some cargo pathways. These performance 
measures provide information about the amount of prohibited 
agriculture items expected to be found in specific pathways during 
inspections, which can then be compared with data on the actual amount 
found. According to APHIS and CBP officials, this comparison can 
provide some information regarding the effectiveness of agricultural 
inspection activities as well as the relative risk that prohibited 
pests pose in a particular pathway. For example, in fiscal year 2011, 
APHIS estimated that 3.5 percent of international airline passengers 
were expected to be carrying prohibited agriculture items, and 
agricultural inspections actually found prohibited items in 3.2 
percent of international airline passengers, suggesting that the 
agricultural inspections may not have found all items for that year. 

Even as APHIS and CBP expanded existing performance measures, they did 
not develop measures for all aspects of the AQI program that are 
important for its management. Thus, existing performance measures are 
not sufficient to assess the program's overall effectiveness. For 
example, APHIS officials told us that the AQI program does not have 
performance measures for gauging the timeliness of APHIS's pest 
identification services, which form the basis for deciding how to 
treat inspected material. According to APHIS officials, they are 
working independently to develop such measures. In addition, CBP 
officials told us that there are no performance measures for gauging 
the extent to which the AQI program targets inspections to commodities 
or pathways of higher risk. Furthermore, there are no performance 
measures for assessing progress related to the AQI program's expanded 
mission to prevent agroterrorism, such as preventing the intentional 
introduction of pests harmful to agriculture by coordinating with 
intelligence entities. According to the Director of CBP's 
Agriculture/Bio Terror Countermeasures division, there is an ongoing 
effort to develop a measure of CBP's ability to prevent intentional 
introductions of harmful pathogens. CBP officials also told us that 
because the current performance measures are not designed to indicate 
what type of inspection procedure would most likely identify a 
prohibited item--for example, whether an item would be more likely to 
be found using an x-ray or a canine team--they are limited in their 
usefulness for effectively deploying their inspection resources. 
According to APHIS and CBP officials, the two agencies have not 
created additional performance measures for the AQI program because 
they have largely focused their performance management efforts on 
expanding their existing performance measures to additional pathways. 
In addition, they told us that developing additional performance 
measures has been a challenge because of the diverse missions of the 
two agencies. Our work on results-oriented organizations states that 
performance goals and measures that successfully address important and 
varied aspects of program performance are key elements of results-
oriented organizations.[Footnote 14] 

The AQI program also does not have a strategic plan that could serve 
as the framework for defining the mission of what the program seeks to 
accomplish, setting goals to achieve the desired results, and 
identifying performance measures for gauging progress towards those 
goals. The Government Performance and Results Act of 1993, as amended, 
[Footnote 15] (GPRA) requires, among other things, that federal 
agencies develop multi-year strategic plans, and we have previously 
reported that these requirements can also serve as leading practices 
for strategic planning at lower levels within federal agencies, such 
as planning for individual divisions, programs, or initiatives. 
[Footnote 16] The memorandum of agreement that established APHIS and 
CBP roles in the AQI program also emphasized the need for coordination 
between the two agencies. In 2007, a task force comprising of APHIS 
and CBP employees identified the need to create a joint agency AQI 
strategic plan, but an official with the task force told us that this 
effort was not successful because the two agencies took fundamentally 
different approaches to strategic planning that could not be resolved. 
Instead, according to APHIS and CBP officials, the two agencies have 
incorporated elements of AQI activities into each agency's separate 
strategic planning efforts. For example, the strategic plan for 
APHIS's Plant Protection and Quarantine program has a program goal of 
optimizing the effectiveness of pest exclusion and prevention 
activities. At the same time, CBP's Office of Field Operations has a 
separate draft strategic plan that contains an objective for 
protecting against the introduction of plant pests and foreign animal 
diseases. Each plan has different performance measures. These separate 
strategic plans do not reflect a coherent joint mission with program 
goals that can serve as the foundation for developing performance 
measures for the AQI program as a whole. Without a joint strategic 
plan defining the mission and goals of the AQI program, APHIS and CBP 
do not have a unified framework for developing meaningful performance 
measures. 

Establish a National Risk-Based Staffing Model: 

In 2006, we recommended that DHS and USDA 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.[Footnote 17] At that time, we found that CBP had not developed 
or used a risk-based staffing model to ensure that adequate numbers of 
agriculture specialists were staffed to the areas of greatest 
vulnerability for introducing pests and disease. In response to our 
recommendation, CBP has made multiple attempts to build a staffing 
model since 2006, but agency officials told us the agency has not yet 
developed a risk-based staffing model that takes into account 
specialized, port-specific needs. CBP officials said that after 
several attempts to create their own staffing model, they concluded 
they did not have the needed expertise or reliable data to do so. CBP 
officials told us that, in 2009, they hired a contractor for $300,000 
to develop a model, and the agency received the model in September 
2010. However, CBP determined that the model was inadequate because it 
did not incorporate specialized staffing needs, such as ports where 
unique commodities (e.g., cut flowers) are inspected. CBP is in the 
process of soliciting for a new contract to revise the staffing model 
to account for these specialized staffing needs, and they estimate 
that this new contract will cost an additional $300,000. CBP officials 
told us their goal is for the revised staffing model to be completed 
and approved by September 2014, but as of June 2012, officials said 
that the effort to finalize the contract solicitation is 4 months 
behind schedule. In addition, CBP officials were unable to provide 
contracting documents to substantiate their timeline. CBP officials 
told us they are having difficulty writing the new contract 
solicitation because DHS's information requirements for contracting 
documents have changed since they wrote the previous contract, and 
they were unaware of the new requirements when they submitted their 
draft documents. In addition, a CBP official involved in the 
contracting process told us that the AQI program generally does not 
use contractors; therefore, the program's experience in managing the 
contracting process is limited. 

CBP officials told us they anticipate that the revised staffing model 
will recommend significant increases in staff at many locations 
because the staffing model they received in September 2010 recommended 
a 32-percent increase in the total number of agriculture specialists 
for the AQI program. CBP officials also told us they currently do not 
have the resources to increase staff above replacement levels. 
However, the agency has not developed a plan or strategy that assesses 
the risk of potential fiscal constraints on their ability to implement 
the staffing model. Under standards for internal control in the 
federal government, agencies are to assess the risks they face from 
external and internal sources and to determine what actions should be 
taken to mitigate them.[Footnote 18] Because the AQI program may not 
have the fiscal resources to add the number of agriculture specialists 
that the model recommends, CBP faces the risk of being unable to keep 
up with the demand for agricultural inspections. In 2006, we reported 
that the changing nature of international travel and agricultural 
imports creates risks for introducing pests and disease.[Footnote 19] 
These risks include the volume of passengers and cargo, the type of 
agricultural products, countries of origin, and ports of entry where 
passengers and cargo arrive in the United States. Without a plan or 
strategy to optimize the allocation of staff to those ports of highest 
need that considers the fiscal resources that may realistically be 
available, CBP risks investing in a staffing model it cannot execute 
and increasing the vulnerability of the agriculture sector to foreign 
pests and disease. International trade could also be affected if 
agriculture specialists are not available to inspect cargo in a timely 
manner. 

Improve the Effectiveness of the Agriculture Canine Program: 

In 2006, we recommended that DHS and USDA work together to 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.[Footnote 20] At that time, the agriculture canine program was 
understaffed and proficiency scores of canine teams had declined. 
Agriculture canines are a key tool for targeting passengers and cargo 
for inspection by detecting the scent of specific prohibited 
agricultural items, such as citrus or beef. CBP officials told us that 
the use of canines can increase the number of agriculture 
interceptions. For example, at one port of entry that we visited, 
after a canine handler was assigned to work a pathway where no canine 
team had previously worked, interceptions increased by 800 percent. In 
response to our recommendation, CBP has: 

* Increased staffing levels. According to CBP officials, there are 
currently 114 active agriculture canine teams compared with the 
approximately 80 teams that were in place in 2006. We could not 
determine if the staffing levels were adequate without a final 
staffing model for the AQI program. According to CBP officials, the 
staffing model being developed by CBP includes staffing 
recommendations for agriculture canine teams. However, as discussed 
above, CBP officials told us that they do not have a plan to implement 
the staffing model results for deploying canine teams effectively at 
the ports because of current resource constraints. 

* Increased canine training requirements. In 2006, we reported that 60 
percent of the 43 agriculture canine teams tested failed the 2005 
proficiency test--an annual performance evaluation all canine 
enforcement teams must undergo to maintain certification of their 
detection capability. We recommended that USDA and DHS review canine 
training policies. In response, in 2007, trainers from USDA's National 
Detector Dog Training Center--the training center for agriculture 
canine teams--evaluated the annual agriculture canine certification 
program at selected ports. As a result of these evaluations, officials 
from CBP and the training center decided to extend the agriculture 
canine field training course by 1 week to add, among other things, 
hands-on training for conducting certifications at the ports. 
According to the national agriculture canine program manager, all 
current canine teams have passed the annual proficiency test. 

* Expanded management oversight. CBP hired a national agriculture 
canine program manager with canine and agriculture experience to help 
ensure that staffing and training policies are followed in the ports. 
This program manager is responsible for canine handler recruitment 
activities; monitoring the training and staffing status of canine 
handlers; and coordinating the flow of information among canine 
handlers, field offices, and training centers. For example, the 
agriculture canine program manager noted that one of her primary 
responsibilities is to coordinate with the National Detector Dog 
Training Center to assist agriculture canine teams with training 
procedures and policies. 

Even with these efforts, the agriculture canine program still faces 
challenges related to supervisory training and data reliability. 
First, supervisors may not have canine training or experience. Based 
on the results of our survey of agriculture specialists, we estimate 
that 35 percent of agriculture canine specialists at CBP believe that 
their supervisor did not have adequate agriculture canine expertise to 
advise them on any work-related concerns in the past year.[Footnote 
21] Our analysis of findings from the joint CBP-APHIS quality 
assurance reviews in 2010 and 2011 shows that canine handlers at 4 of 
the 15 ports with canine handlers that were reviewed reported to a 
supervisor who had not taken the formal canine supervisory training 
course. According to USDA's National Detector Dog Manual, the 
supervisory training class covers topics related to using canine 
teams, proficiency training, veterinary requirements, and work 
expectations. The agriculture canine program manager told us that this 
formal training class is available, but not mandatory, for canine 
supervisors. Port directors at individual ports of entry are 
responsible for determining whether a canine supervisor should take 
the class and whether the port has the resources to support sending 
the supervisor to the class. Not having supervisors with experience in 
agriculture canines can, according to the canine handlers we spoke 
with at ports of entry, make it difficult for the canine handlers to 
get support when they encounter difficulty or have questions. Also, in 
March 2004, we reported that investing in and enhancing the value of 
employees through training and development is crucial for the federal 
government to successfully acquire, develop, and retain talent. 
[Footnote 22] 

Second, we found that some data being used to support the agriculture 
canine program may not be sufficiently reliable for assessment because 
they are incomplete and inaccurate. In addition, some data being 
collected may not be meaningful. The agriculture canine program relies 
on multiple types of data to track the work activities of canine 
handlers, such as whether the handler is active or on leave and what 
training activities the team has completed. However, we found the 
following: 

* Some data are incomplete and inaccurate. For example, we analyzed 
data from fiscal years 2010 and 2011 on canine teams' weekly training 
exercises. The program manager uses this information to ensure that 
canine teams are meeting their training requirement and maintaining a 
minimum required proficiency level to conduct agricultural 
inspections. However, we estimate that the percent of missing values 
in this data set ranges from 13 percent to 22 percent from January 
2010 through July 2011. We could not accurately determine the precise 
number of missing values because, according to the canine program 
manager, the field offices do not maintain accurate records of the 
number of active canine teams. The canine program manager told us that 
canine teams periodically become inactive for a variety of reasons, 
such as medical leave or temporary reassignment of canine handlers, 
but the field offices do not change the team's status to inactive in 
the human capital tracking system, and as a result, the number of 
active canine handling teams in each quarter may be overstated. The 
canine program manager also noted that the proficiency data--which are 
collected quarterly by CBP field offices and forwarded to the 
agriculture canine program manager in CBP headquarters--have missing 
values because field offices do not consistently review the data for 
errors or missing values. When there are missing values, too much time 
may have elapsed for the canine handler to remember what the correct 
data should be. According to the agriculture canine program manager, 
to compensate for these data problems, she maintains a separate record 
of the current status of each canine team, which is generated from 
personal communications between her, the field offices, and canine 
handlers. The agriculture canine program manager also told us she is 
developing a web-based data reporting system that is intended to have 
a supervisory review process before the data are submitted; however, 
she did not have a timeline for this project because it is being 
developed informally. Without complete and accurate information 
regarding its canine teams, the AQI program does not have sufficient 
information to assess the status of the canine teams' proficiency 
level to ensure agriculture canine inspections are being conducted by 
qualified canine teams. 

* Some data being collected may not be meaningful. Specifically, the 
agriculture canine program is gathering data on the amount of time 
canine teams actively inspect and intercept pests; however, according 
to CBP officials, these data are not useful for the AQI program. 
Before the creation of DHS, the U.S. Customs Service collected these 
data to measure the cost effectiveness of its drug-detecting canines, 
and CBP continued to collect these data for agriculture canines. The 
use of these data to determine the cost effectiveness of a canine 
program depends heavily on determining the value of the seized 
contraband, which is not easily determined for agriculture. For 
example, according to CBP officials, a pound of seized cocaine has an 
associated street value that can be compared with the cost of 
performing inspections. For agriculture products, the monetary value 
of the seized item may be minimal; instead, the value of the activity 
is in preventing the introduction of a harmful agricultural pest or 
disease and avoiding the potential economic harm, which, according to 
CBP, is difficult to project or calculate. 

Without sufficiently reliable data, the AQI program cannot assess the 
effectiveness of the canine program. Furthermore, by collecting data 
that are not meaningful or useful for assessing the effectiveness of 
its canine handlers, the AQI program may be using resources to collect 
data it does not need. 

Revise User Fees: 

In 2006 we recommended that DHS and USDA work together to revise the 
user fees to ensure that they cover the AQI program's costs.[Footnote 
23] At that time we found that, although the Secretary of Agriculture 
had the discretion to prescribe user fees to cover the costs of the 
AQI program, program costs had exceeded user fee collections since the 
transfer of AQI inspection activities to DHS's CBP. In 2009, APHIS 
attempted to increase the AQI user fees using an interim rulemaking 
process that increased AQI user fees by approximately 10 percent. 
However, later that year they withdrew the interim rule because, 
according to APHIS officials, stakeholders objected to the lack of a 
formal comment period in the interim rulemaking process. We have 
previously reported that APHIS's use of interim rules to adjust user 
fees limits stakeholder input.[Footnote 24] APHIS officials are 
exploring other regulatory alternatives for adjusting the fees. In 
October 2010, APHIS hired a contractor to conduct a comprehensive fee 
review to determine the full cost of AQI services, identify potential 
changes to the fee structure, and recommend new fees. APHIS officials 
estimated that, should APHIS and DHS agree that user fees need to be 
increased, APHIS will publish a proposed rule by the summer of 2013. 
GAO is conducting a separate evaluation of the AQI user fees' 
structure and options for setting and distributing them. 

Limitations in the Arrival, Inspection, and Interception Data May 
Hinder Their Use in Managing the Program: 

The AQI program uses data on arrivals, inspections, and interceptions 
to determine how well agricultural inspections identify prohibited 
materials and to review ports' performance, but data quality issues 
may prevent AQI program officials from making full use of the data. 
More specifically, CBP and APHIS officials told us that they determine 
how well agricultural inspections identify prohibited materials by 
comparing the actual counts of arrivals, inspections, and 
interceptions against the existing performance measure of the amount 
of prohibited agricultural items expected to be found in a specific 
pathway. In addition, AQI officials use the data to identify annual 
trends specific to a particular port and to determine whether any 
changes in the number of inspections or interceptions at that port can 
be explained by external factors--such as a change in trade or travel 
patterns--or indicate a performance problem at the port that needs to 
be corrected. However, we found limitations that may undermine the 
data's overall usefulness for managing the program. Specifically: 

* The data may not be reliable. According to APHIS officials, data 
quality is an ongoing issue with the AQI data systems, including the 
Work Accomplishment Data System (WADS)--the primary repository for 
arrival, inspection, and interception data. As a result, in 2004, 
APHIS and CBP created an interagency stakeholder group with a goal of 
ensuring data quality and accuracy by performing quarterly visual 
checks of WADS data and providing data quality training to agriculture 
specialists at the ports upon request. Since 2006, 30 of the 167 ports 
with agriculture specialists have received this training. At some 
ports, agriculture specialists record arrivals, inspections, and 
interceptions every day on paper or spreadsheets and enter this 
information into WADS at the end of the month, which may affect the 
reliability of the data by introducing transcription errors. In 
addition, from 2010 through 2011, the joint CBP-APHIS quality 
assurance reviews, which focused on 22 ports, found instances of 
discrepancies between data recorded in WADS and data recorded on daily 
logs at about half of the ports reviewed (10 out of the 22 ports). For 
example, at one port that was reviewed, the number of passengers 
referred to secondary inspection was underreported by nearly 10 
percent, and reviews of other ports identified some data that were 
overreported or had not been recorded. APHIS and CBP officials told us 
that supervisors review the data monthly at all the ports, and that 
there is a quarterly review process by the interagency stakeholder 
group; however both of these reviews rely primarily on a visual 
comparison of current and historical numbers and thus detect only 
unusually large changes at a port. According to APHIS officials, the 
monthly supervisory review process does not require supervisors to 
compare the numbers in WADS with the daily log sheets or other 
databases because the policy and procedures do not have specific 
requirements on how data are to be reviewed. We have previously 
reported that agencies should ensure that data are free of systematic 
error or bias and that what is intended to be measured is actually 
measured.[Footnote 25] According to a senior APHIS official, ensuring 
AQI data quality and accuracy is a continuing challenge because of 
various factors, including changes in the APHIS and CBP personnel 
involved in data collection. 

* The data cannot be easily analyzed. WADS captures data on the number 
of arrivals, inspections, and interceptions independently from one 
another, and these data cannot be linked without extensive analysis. 
CBP officials told us that being able to connect a specific arrival to 
an inspection and the resulting interceptions would be useful 
information for assessing the effectiveness of targeting activities 
and inspection procedures. However, the analysis necessary to do so is 
time consuming and cumbersome, undermining the use of the data for 
managing the program. In addition, the way in which some data are 
recorded in WADS complicates analysis, according to APHIS and CBP 
officials. For example, WADS captures the number of agricultural 
inspections carried out at individual ports by agriculture 
specialists. It does not count the number of agricultural inspections 
carried out by CBP officers when agriculture specialists are not 
present. Therefore, WADS is not a representation of the total number 
of agricultural inspections carried out at ports and cannot be used to 
analyze the number of agricultural inspections conducted in relation 
to total number of arrivals. In another example, each inspection is 
counted once in WADS, but the number of interceptions that are 
recorded from an inspection varies depending on what is found. 
Specifically, if a passenger were inspected and found to be carrying 
five different types of fruit, the agriculture specialist would record 
that result as five interceptions for one inspection. However, if the 
passenger had five pieces of one type of fruit, it would be recorded 
as one interception. As a result, it is difficult to analyze the 
number of agricultural interceptions found in relation to the total 
number of inspections conducted. 

* The data have inherent limitations beyond AQI program control. The 
number of agricultural arrivals, inspections, and interceptions varies 
from year to year and by pathway. According to APHIS and CBP 
officials, the variation is caused by numerous factors, including 
weather, economics, and politics that affect travel and trade, as well 
as variances in inspection targeting procedures. For example, arrivals 
of a commodity from a particular country may drop sharply because of 
severe weather conditions, such as hurricanes or droughts, or because 
trade sanctions and embargoes have been put in place for political 
reasons. APHIS and CBP officials noted that they target inspections on 
the basis of factors such as pathways, commodities known to be a risk 
for agricultural pests, country of origin, and a shipper's history of 
violations. Together, these factors can result in inspection and 
interception numbers that do not correlate with the number of arrivals 
for a particular pathway. For example, APHIS officials told us that 
one pathway, such as cargo trucks, may have a high number of arrivals, 
but if the cargo these trucks are carrying is considered a low risk 
for carrying prohibited pests, then it would be expected that the data 
for this pathway would show fewer inspections and interceptions. 

Some of these data limitations have the potential to affect other key 
efforts that are currently underway, such as the program's staffing 
model and the effort to analyze the structure and amounts of AQI user 
fees--both critical to the AQI program. For example, contractor 
documents related to the staffing model stated that WADS data are not 
reliable for understanding the actual workload of agriculture 
specialists, and that the contractor had to undertake significant 
effort to make the data usable. Specifically, the contractor's 
analysis estimated that about 2 percent of pedestrians are inspected 
by agriculture specialists, but that the data in WADS indicated that 
agriculture specialists inspected 33 percent of pedestrians.[Footnote 
26] In addition, the contractor analyzing user fees noted concerns 
regarding potentially inconsistent or inaccurate data entry, which 
could result in decreased confidence with data reporting and analysis. 
Without reliable data on work activities, AQI program officials cannot 
be assured that they have the information they need to manage the 
program. 

Survey Responses Show Some Changes in Agriculture Specialists' Views: 

According to our analysis of agriculture specialists' and supervisors' 
responses to our 2012 survey and the results from our 2006 survey, 
some aspects of agriculture specialists' and supervisors' views about 
their work environment have changed since 2006. The responses to our 
open-and closed-ended questions show that views about some areas have 
improved, some concerns expressed in 2006 have persisted, and some 
concerns have increased. (To view the full results of our survey, 
please see the electronic supplement to this report, GAO-12-884SP.) 

Survey Responses Show Improvement in Some Areas: 

According to our analysis of the responses to the 2006 and 2012 
surveys, agriculture specialists and supervisors believe some aspects 
of the AQI program have improved since we last reported. Notably, in 
2006, "nothing is going well" was the second most common response to 
our open-ended question, "What is going well with respect to your work 
as an agriculture specialist?"; in 2012, it was one of the least 
common responses, suggesting that, in general, respondents believe 
aspects of the AQI program have improved. (See appendix II for a 
summary of responses to this open-ended question for 2006 compared to 
2012.) Based on our analysis of survey results, agriculture 
specialists and supervisors specifically believe that training and 
information-sharing have improved. 

Training. More agriculture specialists and supervisors at CBP now 
believe they are sufficiently trained to perform their agriculture 
inspection duties than did in 2006, according to our analysis of 
responses to the closed-ended questions in our 2012 survey. 
Specifically, we estimate that 76 percent of agriculture specialists 
and supervisors at CBP employed before the merger believe they are 
definitely sufficiently trained to perform their agricultural 
inspection duties, and 51 percent employed after the merger believe 
they are definitely sufficiently trained.[Footnote 27] This represents 
an increase from 2006, when we estimated 58 and 36 percent, 
respectively.[Footnote 28] (See table 1.) 

Table 1: Estimates for the Closed-ended Question "Do You Believe That 
You Are Sufficiently Trained to Perform Your Agriculture Inspection 
Duties?" 

Definitely yes; 
Employed before the merger: 2006: 58%; 
Employed before the merger: 2012: 76%; 
Employed after the merger: 2006: 36%; 
Employed after the merger: 2012: 51%. 

Confidence intervals[A]; [shaded row] 
Employed before the merger: 2006: 52.4%-62.6%; 
Employed before the merger: 2012: 66.6%-83.0%; 
Employed after the merger: 2006: 28.2%-44.3%; 
Employed after the merger: 2012: 44.6%-58.3%. 

Probably yes; 
Employed before the merger: 2006: 32%; 
Employed before the merger: 2012: 19%; 
Employed after the merger: 2006: 39%; 
Employed after the merger: 2012: 36%. 

Confidence intervals; [shaded row] 
Employed before the merger: 2006: 27.4%-37.2%; 
Employed before the merger: 2012: 12.3%-27.5%; 
Employed after the merger: 2006: 31.2%-46.6%; 
Employed after the merger: 2012: 29.7%-42.8%. 

Uncertain; 
Employed before the merger: 2006: 1%; 
Employed before the merger: 2012: 4%; 
Employed after the merger: 2006: 11%; 
Employed after the merger: 2012: 2%. 

Confidence intervals; [shaded row] 
Employed before the merger: 2006: 0.5%-2.8%; 
Employed before the merger: 2012: 1.3%-10.2%; 
Employed after the merger: 2006: 7.4%-15.5%; 
Employed after the merger: 2012: 0.5%-4.5%. 

Probably not; 
Employed before the merger: 2006: 4%; 
Employed before the merger: 2012: 1%; 
Employed after the merger: 2006: 8%; 
Employed after the merger: 2012: 5%. 

Confidence intervals; [shaded row] 
Employed before the merger: 2006: 2.7%-7.0%; 
Employed before the merger: 2012: 0.0-3.6%; 
Employed after the merger: 2006: 4.7%-13.3%; 
Employed after the merger: 2012: 2.4%-9.2%. 

Definitely not; 
Employed before the merger: 2006: 3%; 
Employed before the merger: 2012: 0; 
Employed after the merger: 2006: 5%; 
Employed after the merger: 2012: 5%. 

Confidence intervals; [shaded row] 
Employed before the merger: 2006: 1.7%-6.0%; 
Employed before the merger: 2012: 0.0-3.6%; 
Employed after the merger: 2006: 2.7%-9.0%; 
Employed after the merger: 2012: 2.6%-9.5%. 

No answer; 
Employed before the merger: 2006: 1%; 
Employed before the merger: 2012: 0; 
Employed after the merger: 2006: 2%; 
Employed after the merger: 2012: 0. 

Confidence intervals; [shaded row] 
Employed before the merger: 2006: 0.6%-3.9%; 
Employed before the merger: 2012: 0.0%-1.9%; 
Employed after the merger: 2006: 0.4%-7.8%; 
Employed after the merger: 2012: 0.0%-2.1%. 

Source: GAO analysis of survey data. 

Notes: Numbers may not add to 100 percent due to rounding. 

In 2006, the question was phrased as: "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?" 

[A] The shaded rows contain the 95 percent confidence intervals. 

[End of table] 

Additionally, based on our analysis of the responses to our closed-
ended questions, we estimate 28 percent of agriculture specialists and 
supervisors at CBP believe that the sufficiency of training is not a 
challenge to conducting agriculture duties at their port, and another 
29 percent believe it is only a minor challenge.[Footnote 29] We did 
not ask about whether or not training was a challenge in our closed-
ended questions in 2006, but at that time, training was the fourth 
most frequent response to our open-ended question, "What would you 
like to see changed or improved with respect to your work as an 
agriculture specialist?" Our analysis of the responses to our 2012 
survey shows that views about training have generally improved, but 
out of 406 respondents, we received 68 comments in response to an open-
ended question listing certain aspects of training they would like to 
see changed or improved. For example, some respondents commented that 
they would like to see more specific or refresher training on 
agriculture pests that they may encounter on the job, and one 
respondent commented that he would like the opportunity for more hands-
on--rather than web-based--training. 

Information-sharing. According to our analysis of 2006 and 2012 survey 
responses, information-sharing has also improved. Based on the 
responses to our closed-ended question on whether information is 
delivered in a timely manner, we estimate that 36 percent of 
agriculture specialists and supervisors at CBP believe that 
information on agriculture regulatory changes is always delivered in a 
timely manner, and another 48 percent believe the information is 
delivered in a timely manner most of the time.[Footnote 30] These 
views reflect an increase from 2006, when we estimated 17 percent of 
agriculture specialists and supervisors at CBP believed such 
information was always delivered in a timely manner, and 38 percent 
believed it was delivered in a timely manner most of the time. 
[Footnote 31] Additionally, we estimate that, compared with 2006, 
statistically more agriculture specialists and supervisors at CBP in 
2012 believe they always receive information on urgent alerts, pest 
alerts, and updated pages for the agriculture regulatory manual in a 
timely manner.[Footnote 32] (See table 2.) We estimate that 57 percent 
of agriculture specialists and supervisors at CBP in 2012 believe the 
timeliness of information provided to agriculture specialists is 
either not a challenge or is a minor challenge to conducting 
agriculture duties at their port.[Footnote 33] We did not ask this 
question in 2006. 

Table 2: Estimates for the Closed-ended Question "Is the Information 
Delivered to You in a Timely Manner to be Useful?" 

Type of information: Urgent agriculture alerts; 
Response: Always: 2006[A]: 21%; 
Response: Always: 2012[B]: 34%; 
Response: Most of the time: 2006: 41%; 
Response: Most of the time: 2012: 47%; 
Response: Some of the time: 2006: 25%; 
Response: Some of the time: 2012: 15%; 
Response: Never or almost never: 2006: 7%; 
Response: Never or almost never: 2012: 2%; 
Response: Did not receive: 2006: 3%; 
Response: Did not receive: 2012: 1%; 
Response: No answer: 2006: 2%; 
Response: No answer: 2012: 1%. 

Type of information: Confidence intervals[C]; [shaded row] 
Response: Always: 2006[A]: 17.8%-24.9%; 
Response: Always: 2012[B]: 28.8%-39.4%; 
Response: Most of the time: 2006: 37.3%-45.8%; 
Response: Most of the time: 2012: 41.4%-52.5%; 
Response: Some of the time: 2006: 21.4%-28.8%; 
Response: Some of the time: 2012: 11.2%-19.5%; 
Response: Never or almost never: 2006: 5.5%-10.1%; 
Response: Never or almost never: 2012: 0.8%-4.1%; 
Response: Did not receive: 2006: 1.8%-4.3%; 
Response: Did not receive: 2012: 0.5%-3.0%; 
Response: No answer: 2006: 1.1%-4.5%; 
Response: No answer: 2012: 0.1%-2.1%. 

Type of information: Pest alerts; 
Response: Always: 2006[A]: 19%; 
Response: Always: 2012[B]: 33%; 
Response: Most of the time: 2006: 42%; 
Response: Most of the time: 2012: 47%; 
Response: Some of the time: 2006: 25%; 
Response: Some of the time: 2012: 16%; 
Response: Never or almost never: 2006: 8%; 
Response: Never or almost never: 2012: 2%; 
Response: Did not receive: 2006: 4%; 
Response: Did not receive: 2012: 2%; 
Response: No answer: 2006: 2%; 
Response: No answer: 2012: 1%. 

Type of information: Confidence intervals; [shaded row] 
Response: Always: 2006[A]: 16.0%-22.9%; 
Response: Always: 2012[B]: 28.0%-38.6%; 
Response: Most of the time: 2006: 37.4%-46.0%; 
Response: Most of the time: 2012: 41.1%-52.3%; 
Response: Some of the time: 2006: 22.0%-29.3%; 
Response: Some of the time: 2012: 11.7%-20.1%; 
Response: Never or almost never: 2006: 6.0%-10.9%; 
Response: Never or almost never: 2012: 0.7%-3.5%; 
Response: Did not receive: 2006: 2.5%-5.3%; 
Response: Did not receive: 2012: 0.7%-3.7%; 
Response: No answer: 2006: 1.0%-4.0%; 
Response: No answer: 2012: 0.2%-2.9%. 

Type of information: Regulatory changes; 
Response: Always: 2006[A]: 17%; 
Response: Always: 2012[B]: 36%; 
Response: Most of the time: 2006: 38%; 
Response: Most of the time: 2012: 48%; 
Response: Some of the time: 2006: 26%; 
Response: Some of the time: 2012: 15%; 
Response: Never or almost never: 2006: 12%; 
Response: Never or almost never: 2012: 1%; 
Response: Did not receive: 2006: 5%; 
Response: Did not receive: 2012: 0; 
Response: No answer: 2006: 2%; 
Response: No answer: 2012: 0. 

Type of information: Confidence intervals; [shaded row] 
Response: Always: 2006[A]: 14.3%-21.0%; 
Response: Always: 2012[B]: 30.2%-40.8%; 
Response: Most of the time: 2006: 33.4%-41.9%; 
Response: Most of the time: 2012: 42.3%-53.4%; 
Response: Some of the time: 2006: 22.2%-29.7%; 
Response: Some of the time: 2012: 11.2%-19.4%; 
Response: Never or almost never: 2006: 9.75%-15.4%; 
Response: Never or almost never: 2012: 0.4%-3.1%; 
Response: Did not receive: 2006: 3.3%-6.2%; 
Response: Did not receive: 2012: 0.0-1.6%; 
Response: No answer: 2006: 1.3%-4.2%; 
Response: No answer: 2012: 0.0-1.4%. 

Type of information: Updated pages for agriculture regulatory manual; 
Response: Always: 2006[A]: 18%; 
Response: Always: 2012[B]: 37%; 
Response: Most of the time: 2006: 31%; 
Response: Most of the time: 2012: 46%; 
Response: Some of the time: 2006: 17%; 
Response: Some of the time: 2012: 10%; 
Response: Never or almost never: 2006: 18%; 
Response: Never or almost never: 2012: 3%; 
Response: Did not receive: 2006: 14%; 
Response: Did not receive: 2012: 4%; 
Response: No answer: 2006: 2%; 
Response: No answer: 2012: 1%. 

Type of information: Confidence intervals; [shaded row] 
Response: Always: 2006[A]: 14.8%-21.7%; 
Response: Always: 2012[B]: 31.5%-42.2%; 
Response: Most of the time: 2006: 26.6%-34.8%; 
Response: Most of the time: 2012: 40.3%-51.4%; 
Response: Some of the time: 2006: 13.7%-20.2%; 
Response: Some of the time: 2012: 7.0%-13.9%; 
Response: Never or almost never: 2006: 14.9%-21.5%; 
Response: Never or almost never: 2012: 1.3%-5.1%; 
Response: Did not receive: 2006: 11.7%-17.3%; 
Response: Did not receive: 2012: 1.8%-5.6%; 
Response: No answer: 2006: 1.5%-4.2%; 
Response: No answer: 2012: 0.3%-3.2%. 

Source: GAO analysis of survey data. 

Notes: Numbers may not add to 100 percent due to rounding. 

In 2006, the question was phrased as: "Is the information delivered to 
you in a timely manner?" 

[A] In 2006, there were 626 responses. 

[B] In 2012, there were 397 responses for urgent agriculture alerts, 
394 for pest alerts, and 396 responses each for regulatory changes and 
updated pages for agriculture manual. 

[C] The shaded rows contain the 95 percent confidence intervals. 

[End of table] 

Survey Responses Show Some Concerns Persist: 

According to our analysis of the responses to our 2012 survey, some of 
the concerns agriculture specialists and supervisors at CBP reported 
in 2006 persist. In particular, concerns remain about CBP's chain of 
command, the agriculture mission, and working relationships among co-
workers. 

CBP's chain of command. Our analysis indicates that respondents remain 
concerned about CBP's chain of command--including concerns about poor 
communication related to internal policies, supervisors lacking 
agriculture experience, and the need for an agriculture chain of 
command that is separate from CBP. In 2006, CBP's chain of command was 
the third most frequent response to our open-ended question, "What 
would you like to see changed or improved with respect to your work as 
an agriculture specialist?" Similarly, in 2012, it was the category 
noted most often as something to be changed or improved. Furthermore, 
based on our analysis of closed-ended questions in 2012, we estimate 
that 30 percent of agriculture specialists and supervisors at CBP 
believe the CBP chain of command is a very major challenge to 
conducting agriculture duties at their port, and another 23 percent 
believe it is a major challenge.[Footnote 34] (See appendix II for a 
summary of responses to the open-ended question, "What would you like 
to see changed or improved with respect to your work as an agriculture 
specialist?" in 2006 compared to 2012.) We did not ask about CBP's 
chain of command in our closed-ended questions in 2006. 

Agriculture mission. As with the results of our 2006 survey, 2012 
survey respondents identified the priority given to the agriculture 
mission among the top four aspects of the AQI program they would like 
to see changed or improved. Further, we estimate that 39 percent of 
agriculture specialists and supervisors at CBP believe the priority 
given to the agriculture mission is a very major challenge to 
conducting agriculture duties at their port, and another 23 percent 
believe it is a major challenge based on our analysis of responses to 
closed-ended questions in 2012.[Footnote 35] Out of 406 survey 
respondents, 86 respondents identified the priority given to the 
agriculture mission as something they would like to see changed or 
improved in response to our open-ended question. Respondents noted 
that competing priorities sometimes prevented them from performing 
their missions and that agriculture specialists do not have enough 
time to complete their tasks, such as looking for pests in agriculture 
materials intercepted from passengers. Not having enough time to 
complete agriculture-mission related tasks is a concern for about the 
same percentage of agriculture specialists and supervisors at CBP in 
2012 as it was in 2006. (See table 3.) 

Concern for the priority given to the agriculture mission persists, 
but 91 out of 406 respondents indicated in their response to the open-
ended question about what is going well that they believe some aspects 
of the AQI mission are going well, such as inspections and 
interceptions. 

Table 3: Estimates for the Closed-ended Question "Do You Have Enough 
Time to Look for Pests in Agriculture Materials Intercepted from 
Passengers?" 

Always; 
2006[A]: 10%; 
2012 [B]: 11%. 

Confidence intervals[C]; [shaded row] 
2006[A]: 8.1%-13.0%; 
2012 [B]: 8.2%-15.2%. 

Most of the time; 
2006[A]: 27%; 
2012 [B]: 31%. 

Confidence intervals; [shaded row] 
2006[A]: 23.0%-30.9%; 
2012 [B]: 25.9%-36.1%. 

Some of the time; 
2006[A]: 31%; 
2012 [B]: 30%. 

Confidence Intervals; [shaded row] 
2006[A]: 27.2%-35.4%; 
2012 [B]: 25.1%-35.4%. 

Never or almost never; 
2006[A]: 15%; 
2012 [B]: 8%. 

Confidence Intervals; [shaded row] 
2006[A]: 12.5%-18.5%; 
2012 [B]: 4.9%-10.9%. 

Not applicable; 
2006[A]: 15%; 
2012 [B]: 18%. 

Confidence Intervals; [shaded row] 
2006[A]: 11.9%-17.8%; 
2012 [B]: 13.4%-22.4%. 

No answer; 
2006[A]: 2%; 
2012 [B]: 2%. 

Confidence Intervals; [shaded row] 
2006[A]: 1.1%-3.6%; 
2012 [B]: 0.9%-4.8%. 

Source: GAO analysis. 

Notes: Numbers may not add to 100 percent due to rounding. 

[A] In 2006, there were 626 responses. 

[B] In 2012, there were 400 responses. 

[C] The shaded rows contain the 95 percent confidence intervals. 

[End of table] 

Working relationships. Working relationships among co-workers is still 
a concern for agriculture specialists and supervisors, according to 
our analysis of the 2006 and 2012 survey data. Specifically, we 
estimate a similar percentage of agriculture specialists and 
supervisors at CBP in 2006 and 2012 believe their work is definitely 
not respected by CBP management--42 percent in 2006 and 43 percent in 
2012--and by CBP officers--35 percent in 2006 and 28 percent in 
2012.[Footnote 36] (See table 4). Respondents identified working 
relationships in both 2006 and 2012 as one of the most frequent 
responses to the open-ended question asking respondents what they 
would like to see changed or improved. In particular, some respondents 
stated that CBP officers and management do not respect their work or 
mission, and others noted that agriculture specialists are not treated 
as part of the team. However, in both 2006 and 2012, respondents also 
identified working relationships among co-workers as one of the most 
frequent responses to our open-ended question of what is going well, 
suggesting that while some aspects of working relationships continue 
to be a concern, other aspects of working relationships are going 
well. In particular, some respondents noted that their fellow 
agriculture specialists were dedicated, highly-qualified, or hard 
working. 

Table 4: Estimates for the Closed-ended Question "In General, Do You 
Feel that the Work of a CBP Agriculture Specialist Is Respected by CBP 
Officers and Management?" 

CBP officers; 
Response: Definitely yes: 2006[A]: 7%; 
Response: Definitely yes: 2012[B]: 8%; 
Response: Probably yes: 2006: 18%; 
Response: Probably yes: 2012: 20%; 
Response: Uncertain: 2006: 14%; 
Response: Uncertain: 2012: 17%; 
Response: Probably not: 2006: 26%; 
Response: Probably not: 2012: 28%; 
Response: Definitely not: 2006: 35%; 
Response: Definitely not: 2012: 28%; 
Response: No answer: 2006: 0; 
Response: No answer: 2012: 0. 

Confidence intervals[C]; [shaded row] 
Response: Definitely yes: 2006[A]: 4.8%-8.8%; 
Response: Definitely yes: 2012[B]: 4.9%-11.2%; 
Response: Probably yes: 2006: 14.9%-21.9%; 
Response: Probably yes: 2012: 15.3%-24.0%; 
Response: Uncertain: 2006: 10.9%-17.0%; 
Response: Uncertain: 2012: 12.8%-21.5%; 
Response: Probably not: 2006: 22.4%-30.0%; 
Response: Probably not: 2012: 22.9%-33.0%; 
Response: Definitely not: 2006: 31.3%-39.6%; 
Response: Definitely not: 2012: 22.5%-32.6%; 
Response: No answer: 2006: 0.2%-0.9%; 
Response: No answer: 2012: 0.0%-2.1%. 

CBP management; 
Response: Definitely yes: 2006[A]: 6%; 
Response: Definitely yes: 2012[B]: 6%; 
Response: Probably yes: 2006: 14%; 
Response: Probably yes: 2012: 15%; 
Response: Uncertain: 2006: 15%; 
Response: Uncertain: 2012: 15%; 
Response: Probably not: 2006: 22%; 
Response: Probably not: 2012: 21%; 
Response: Definitely not: 2006: 42%; 
Response: Definitely not: 2012: 43%; 
Response: No answer: 2006: 1%; 
Response: No answer: 2012: 1%. 

Confidence intervals; [shaded row] 
Response: Definitely yes: 2006[A]: 4.1%-7.6%; 
Response: Definitely yes: 2012[B]: 3.3%-8.7%; 
Response: Probably yes: 2006: 11.3%-17.6%; 
Response: Probably yes: 2012: 11.2%-18.9%; 
Response: Uncertain: 2006: 12.4%-18.6%; 
Response: Uncertain: 2012: 11.6%-20.0%; 
Response: Probably not: 2006: 19.1%-26.3%; 
Response: Probably not: 2012: 16.0%-25.2%; 
Response: Definitely not: 2006: 37.6%-46.2%; 
Response: Definitely not: 2012: 37.7%-48.8%; 
Response: No answer: 2006: 0.4%-1.3%; 
Response: No answer: 2012: 0.0%-2.1%. 

Source: GAO analysis. 

Notes: Numbers may not add to 100 percent due to rounding. 

In 2006, the question was phrased as: "In general, do you feel that 
your work as a CBP Agriculture Specialist is respected by CBP Officers 
and Management?" 

[A] In 2006, there were 626 responses. 

[B] In 2012, there were 400 responses for CBP Officers and 398 
responses for CBP Management. 

[C] The shaded rows contain the 95 percent confidence intervals. 

[End of table] 

Survey Responses Show Increasing Concerns in Some Areas: 

Our analysis of the responses to the closed-ended questions in our 
2012 survey indicates that agriculture specialists' and supervisors' 
concerns about staffing levels and salary and benefits have increased 
since 2006. Both of these issues were also mentioned more frequently 
in 2012 in response to the open-ended question about what they would 
like to see changed or improved. 

Staffing levels. In 2012, respondents identified staffing levels as 
the second most frequently cited issue they would like to see changed 
or improved. In 2006, staffing was the sixth most frequently offered 
response. Furthermore, we estimate that 50 percent of agriculture 
specialists and supervisors at CBP believe that their port definitely 
does not have enough agriculture specialists to carry out agriculture 
duties, and an additional 21 percent believe that their port probably 
does not, based on our analysis of closed ended questions.[Footnote 
37] In 2006, we estimated that 42 percent of agriculture specialists 
and supervisors at CBP believed their port definitely did not have 
enough agriculture specialists to carry out agricultural duties, and 
an additional 21 percent believed that their port probably did 
not.[Footnote 38] (See table 5.) In addition, in 2012, we estimate 
that 31 percent of agriculture specialists and supervisors at CBP 
believe that staffing levels of agriculture specialists is a very 
major challenge to conducting agriculture duties at their port, and 
another 24 percent believe it is a major challenge.[Footnote 39] We 
did not ask this question in 2006. 

Table 5: Estimates for the Closed-ended Question "In Your Experience, 
Does Your Port Currently Have Enough Agriculture Specialists to Carry 
Out Agriculture Duties?" 

Definitely yes; 
2006: 12%; 
2012: 7%. 

Confidence intervals[A]; [shaded row] 
2006: 9.8%-15.0%; 
2012: 4.6%-10.3%. 

Probably yes; 
2006: 16%; 
2012: 14%. 

Confidence intervals; [shaded row] 
2006: 12.6%-18.9%; 
2012: 10.7%-18.6%. 

Uncertain; 
2006: 8%; 
2012: 7%. 

Confidence intervals; [shaded row] 
2006: 6.2%-11.3%; 
2012: 4.7%-10.9%. 

Probably not; 
2006: 21%; 
2012: 21%. 

Confidence intervals; [shaded row] 
2006: 17.6%-25.1%; 
2012: 16.2%-25.4%. 

Definitely not; 
2006: 42%; 
2012: 50%. 

Confidence intervals; [shaded row] 
2006: 37.5%-46.0%; 
2012: 44.4%-55.6%. 

No answer; 
2006: 1%; 
2012: 0. 

Confidence intervals; [shaded row] 
2006: 0.5%-2.8%; 
2012: 0.0%-2.1%. 

Source: GAO analysis. 

Note: Numbers may not add to 100 percent due to rounding. 

[A] The shaded rows contain the 95 percent confidence intervals. 

[End of table] 

Salary and benefits. Salary and benefits were also higher on the list 
of things respondents would like to see changed or improved in 2012 
compared with 2006. In 2012, salary and benefits was the fourth most 
mentioned category, compared with 2006, when it was the seventh most 
mentioned category. Specifically, in 2012, 77 out of 406 respondents 
identified salary and benefits as something they would like to see 
changed or improved. In their responses to our open-ended question, 
respondents mentioned wanting the same retirement system as their CBP 
officer co-workers, lacking a career ladder for agriculture 
specialists and supervisors, and lacking promotion opportunities. For 
example, CBP officers are considered law enforcement officers and are 
generally eligible for full retirement benefits after 20 years of 
creditable service. Agriculture specialists are not considered law 
enforcement officers and, generally, become eligible for full 
retirement benefits after 30 years of creditable service. 

Conclusions: 

The AQI program is a key component of U.S. efforts to protect 
agriculture from the unintentional or deliberate introduction of pests 
and disease, and effective management of the AQI program requires a 
coordinated effort by DHS and USDA. Since we reported in 2006, both 
DHS and USDA have made progress in implementing our recommendations 
and overcoming some of the management challenges we identified, 
including ensuring that user fees are transferred to CBP and that 
important agriculture information is shared with agriculture 
specialists in a timely manner. 

However, the AQI program continues to wrestle with fundamental 
problems that undermine the management of the program and risks 
wasting resources in a fiscally constrained environment. Specifically, 
in the absence of a strategic plan that lays out the program's joint 
mission and goals, APHIS and CBP do not have a framework for defining 
the program's mission, setting goals to achieve the desired results, 
and identifying performance measures for gauging progress towards 
those goals. 

Furthermore, the agencies may not have sufficient information on which 
to base key decisions to support the AQI program because the data the 
two agencies are collecting and using for managing the program may not 
be reliable. Without ensuring that the data on arrivals, inspections, 
and interceptions across ports are entered accurately, the AQI program 
may not have sufficiently reliable data for supporting critical 
efforts for managing the program. When discrepancies exist between 
data in WADS and data recorded on daily logs at about half of the 
ports reviewed by the 2010 to 2011 joint CBP-APHIS quality assurance 
reviews, it could be an indicator of more widespread data quality 
issues related to failures with the supervisory review policy and 
procedures in ensuring that data are entered accurately. In addition, 
the data supporting the agriculture canine program are hindered by the 
absence of a timely and consistent data review process at CBP field 
offices, resulting in incomplete and inaccurate data. Moreover, the 
agriculture canine program continues to collect some data that may not 
be meaningful or relevant to the program, further straining the 
program's resources. Without sufficiently reliable data, the AQI 
program cannot assess the effectiveness of the canine program. 
Furthermore, by collecting data that are not meaningful or useful for 
assessing the effectiveness of its canine handlers, the AQI program 
may be using resources to collect data it does not need. 

Finally, the agencies may not be using their resources effectively. 
Having devoted 6 years and hundreds of thousands of dollars in 
contracts to develop a staffing model, CBP still does not have a risk-
based staffing model that provides assurance that those ports of 
highest vulnerability for the entry of pests and disease are 
adequately staffed. Furthermore, DHS has not assessed the risk that 
insufficient resources may pose to implementing the staffing model 
once it is completed. Without a plan or strategy for how it will 
implement this staffing model that considers the fiscal resources that 
may realistically be available, the agency risks investing in a 
staffing model that it cannot execute. CBP also risks increasing the 
vulnerability of the agriculture sector to foreign pests and disease 
or disrupting international trade if agriculture specialists cannot 
keep up with demand for agriculture inspections. In addition, well-
trained supervisory staff are a crucial resource for supporting the 
agriculture canine teams, but the results of our survey and the joint 
CBP-APHIS quality assurance reviews indicate that some supervisory 
staff may not have canine training or experience because of barriers 
such as a lack of resources at ports and the voluntary nature of 
supervisory canine training. As a result, supervisors in the AQI 
program may not have the skills necessary to manage issues unique to 
the canine program, such as the health and training of the canine. 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. 

Recommendations for Executive Action: 

We are making the following six recommendations. 

To help ensure the CBP and APHIS agricultural quarantine inspection 
program protects U.S. agriculture from accidental or deliberate 
introduction of foreign pests and disease, we recommend that the 
Secretaries of Agriculture and of Homeland Security work together to 
take the following three actions: 

* Develop a strategic plan for the AQI program that lays out its joint 
mission and program goals. 

* Once the strategic plan is completed, as part of a coordinated 
strategic planning effort, identify corresponding meaningful 
performance measures for monitoring progress towards those goals. 

* Continue taking steps to improve the reliability of AQI data on 
arrivals, inspections, and interceptions across ports, including 
reviewing the supervisory review policy and procedures to ensure the 
data are entered accurately. 

In addition, we recommend the Secretary of the Department of Homeland 
Security, in consultation with USDA where appropriate, take the 
following three actions: 

* Take steps to ensure the agriculture canine program has reliable and 
meaningful data, including instituting a timely and consistent review 
process at CBP field offices, and evaluate the relevance of data 
collected for the agriculture canine program. 

* Develop a plan or strategy for implementing the forthcoming AQI 
staffing model that assesses the risk of potential fiscal constraints 
and determines what actions should be taken to mitigate that risk by 
considering the fiscal resources that may realistically be available 
to ensure that agriculture staffing levels at each port are sufficient. 

* Identify any agriculture canine supervisors who do not have canine 
training or experience and work with port directors to overcome any 
barriers to providing formal training. 

Agency Comments and Our Evaluation: 

We provided USDA and DHS with a draft of this report for their review 
and comment. In their written comments, both agencies agreed with our 
recommendations, and DHS provided technical comments, which we 
incorporated as appropriate. USDA's comments appear in appendix III. 
DHS's comments appear in appendix IV. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to the Secretaries of Agriculture and Homeland Security, the 
appropriate congressional committees, and other interested parties. In 
addition, the report is available at no charge on GAO's website at 
[hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or shamesl@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. 

Signed by: 

Lisa Shames: 
Director, Natural Resources and Environment: 

List of Congressional Requesters: 

The Honorable Susan M. Collins: 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Daniel K. Akaka: 
Chairman: 
Subcommittee on Oversight of Government Management, the Federal 
Workforce, and the District of Columbia: 
Committee on Homeland Security and Governmental Affairs United States 
Senate: 

The Honorable Kirsten E. Gillibrand: 
Chairman: 
Subcommittee on Livestock, Dairy, Poultry, Marketing, and Agriculture 
Security Committee on Agriculture, Nutrition, and Forestry: 
United States Senate: 

The Honorable Dianne Feinstein: 
United States Senate: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to examine the extent to which (1) U.S. Department 
of Agriculture (USDA) and the Department of Homeland Security (DHS) 
have implemented recommendations we made in 2006 to improve the 
Agricultural Quarantine Inspection (AQI) program; (2) data on 
arrivals, inspections, and interceptions are used for managing the 
program; and (3) the views of agriculture specialists at Customs and 
Border Protection (CBP) regarding their work environment have changed, 
if at all, since our 2006 reports. 

To address all of these objectives, we visited or spoke with officials 
at a nonprobability sample of five CBP ports of entry to observe 
agriculture work activities and discuss challenges related to 
conducting agriculture inspections and interceptions. These ports of 
entry were Austin, Texas; Baltimore, Maryland; Dallas, Texas; Miami, 
Florida; and San Ysidro, California. We selected these ports of entry 
based on size; the presence of agriculture specialists, supervisors, 
and canine handlers; and entry pathways, such as air, sea, and land. 
Because we used a nonprobability sample, the information we obtained 
from these visits cannot be generalized to other CBP ports of entry. 
The visits instead provided us with more in-depth information on the 
perspectives of various agriculture specialists in these ports of 
entry about the management of the AQI program. 

To examine the extent to which GAO's May 2006 recommendations have 
been implemented,[Footnote 40] we interviewed DHS and USDA officials 
and reviewed documentation related to (1) improving information-
sharing, (2) undertaking a full review of DHS's financial management 
system for the AQI program, (3) removing barriers to timely and 
accurate AQI user fee transfers from USDA to DHS, (4) adopting 
meaningful performance measures, (5) establishing a national risk-
based staffing model, (6) improving the agriculture canine program, 
and (7) revising user fees to cover AQI program costs. Specifically: 

* To determine the extent to which USDA's Animal and Plant Health 
Inspection Service (APHIS) and DHS's CBP improved information-sharing, 
we obtained and reviewed CBP's agriculture information sharing 
policies and protocols regarding agriculture alerts and policy 
updates, among other things, to evaluate changes since our 2006 
report. We discussed these policies with agriculture specialists and 
supervisors during our site visits. We also interviewed the Deputy 
Executive Director for Agriculture Operational Oversight to discuss 
changes in information-sharing policies and protocols since 2006. We 
conducted a nationally representative survey of agriculture 
specialists and supervisors at CBP, details of which are discussed 
below, and analyzed the results to determine the extent to which 
agriculture specialists and supervisors believe that information-
sharing is a challenge. 

* To determine the extent to which DHS reviewed its financial 
management system, we reviewed guidance on procedures for accounting 
for CBP work activities related to agriculture and interviewed 
officials with CBP's Budget Group and APHIS's Financial Management 
Division to discuss how the changes have affected the financial 
accountability for funds allocated for agriculture quarantine 
inspections. 

* To review how USDA and DHS have removed barriers to user fee 
transfers, we obtained the updated Memorandum of Agreement signed by 
the Secretaries of Agriculture and Homeland Security that modified the 
user fee fund transfer schedule. We also received AQI user fee fund 
transfer records from APHIS to compare the timing and amount of 
transfers to the agreed upon amount. We interviewed officials from 
CBP's Budget Group and APHIS's Financial Management Division regarding 
the transfers to evaluate whether the steps taken by USDA have 
resulted in timely and accurate transfers to DHS. 

* To evaluate APHIS's and CBP's progress in developing meaningful 
performance measures for the AQI program, we reviewed strategic 
planning documents, such as the Plant Protection and Quarantine (PPQ) 
strategic plan and selected sections of the Office of Field 
Operations' draft strategic plan, for how AQI activities are 
incorporated into these plans. We interviewed AQI officials, including 
PPQ officials with strategic planning responsibilities, CBP officials 
with the Office of Field Operations Strategic Planning Division, and 
an official with the APHIS-CBP joint agency task force to discuss the 
existing AQI performance measures, including how they are used to 
assess performance, their limitations for measuring key AQI 
activities, and the extent to which APHIS and CBP are developing 
additional performance measures for managing the AQI program. We also 
discussed the extent to which the AQI program has developed a 
strategic plan with a joint mission and program goals, and we compared 
this to leading practices we have previously reported on for federal 
strategic planning at lower levels within federal agencies, such as 
planning for individual divisions, programs, or initiatives.[Footnote 
41] 

* To evaluate the extent to which CBP has established a national risk-
based staffing model, we reviewed CBP contracting documents related to 
CBP's efforts to develop a model and interviewed officials from CBP's 
Office of Field Operations and the Deputy Executive Director for 
Agriculture Operational Oversight regarding their progress towards, 
and their implementation plan and strategy for, a model. As part of 
evaluating the potential impact of the AQI program not having a risk-
based staffing model, we reviewed standards for internal control in 
the federal government.[Footnote 42] 

* To assess the effectiveness of the canine program, we analyzed and 
reviewed agriculture canine units' quarterly proficiency scores from 
fiscal years 2006 through 2011, the agriculture canine training 
manual, agriculture canine units' leash time data from fiscal years 
2006 through 2011, and CBP's agriculture canine daily statistics 
template. We discussed these with the CBP agriculture canine program 
manager to determine the extent to which the data can be used for 
assessing the agriculture canine program. To determine the extent to 
which the proficiency data have missing values, we compared the number 
of active agriculture canine teams for each quarter provided by the 
agriculture canine program manager to the number of canine teams that 
reported a proficiency score for that quarter and discussed the 
limitations of this approach with the agriculture canine program 
manager. We also reviewed the results of APHIS-CBP joint quality 
assurance reviews from 2010 through 2011, the most recent years for 
which complete data are available, for those ports that had canine 
handlers to determine the number of reviews that found canine handlers 
did not have supervisors with canine training. We also analyzed the 
results of our survey, discussed below, to determine the extent to 
which canine handlers believe their supervisor has adequate 
experience. We interviewed the agriculture canine program manager on 
training policy and procedures for canine handlers and supervisors, 
steps CBP has taken to address staffing issues raised in our 2006 
report, and data quality issues with the agriculture canine program. 

* To evaluate how DHS and USDA have revised user fees since 2006, we 
reviewed Federal Register documents relating to APHIS's attempts to 
revise AQI user fees. We interviewed APHIS officials on their plans 
for future revisions to the user fee structure. GAO is conducting a 
separate evaluation of the AQI user fee structure and options of 
setting and distributing them. 

To examine the extent to which data on agriculture arrivals, 
inspections, and interceptions are used for managing the AQI program, 
we reviewed DHS and USDA inspection and interception data, related 
summary reports, and policies. Specifically, we obtained and analyzed 
data from USDA APHIS's Work Accomplishment Data System for fiscal 
years 2001 through 2011 and reviewed data collection and entry 
procedures and definitions of required data elements that may impact 
the use of the data for managing the program. We reviewed DHS and USDA 
joint Quality Assurance Reviews--joint agency reports on port 
compliance with agricultural inspection policy--from 2010 through 
2011, the most recent years for which data were available. We reviewed 
documents related to contractor-led efforts for key aspects of the AQI 
program to determine how those efforts were impacted by data quality 
issues. Additionally, we interviewed key program officials at USDA and 
DHS to discuss the reliability of the data and whether there were 
limitations in the data that may affect the extent to which these data 
on agricultural quarantine inspections and interceptions are used to 
make AQI program decisions. To assess the reliability of arrival, 
inspection and interception data, we observed data collection and data 
entry procedures at selected ports of entry; reviewed the finding of 
CBP-APHIS joint quality assurance reviews from 2010 and 2011; and 
interviewed agriculture inspectors, supervisors and program managers. 
We concluded that inspection and interception data in APHIS's Work 
Accomplishment Data System (WADS) may hinder managers' ability to 
definitively determine whether patterns observed in inspection and 
interception data are attributable to real changes in the number of 
inspections and interceptions, or to errors in the data collection and 
entry processes. We found that potential weaknesses exist at several 
places in the data collection process. The process for recording 
inspections and interceptions varies significantly from port to port. 
At some ports, inspectors record inspection information on a paper 
clipboard and then proceed to enter that information into an 
electronic system following the inspection. However, at other 
locations, paper records of inspections and interceptions are compiled 
and entered into electronic form as much as one month after the 
inspection took place. The multiple steps involved in data entry 
increase the likelihood of errors; and at some ports, the amount of 
time that elapses between inspection and interception activities and 
data entry reduces the usefulness of inspector recall to correct any 
ambiguities or errors found in paper records. 

To determine the extent to which the views of agriculture specialists 
regarding their work environment have changed, if at all, since GAO 
last reported, we conducted a nationally representative survey of 
agriculture specialists and supervisors at CBP regarding their work 
environment. The survey consisted of closed-ended and open-ended 
questions. Specifically, we drew a stratified random probability 
sample of 556 agriculture specialists and supervisors from the 
universe of 2,311 specialists in the DHS's CBP who were engaged in 
agricultural inspection duty as of October 2011 and still engaged in 
this duty as of February 2012. We excluded 10 respondents from our 
sample of 556 as out-of-scope because these individuals performed 
management duties outside of CBP ports. All agriculture canine 
handlers were placed in one stratum; other strata were defined by the 
number of specialists at the respective ports. Each sample was 
subsequently weighted in the analysis to account statistically for all 
specialists in the population. We received an unweighted response rate 
of 74 percent. The survey results for the closed-ended questions are 
generalizable to all agriculture specialists and supervisors at CBP. 

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. This 
is the interval that would contain the actual population values for 95 
percent of the samples we could have drawn. In developing the survey, 
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, to ensure that the questions were clear and unambiguous, 
terminology was used correctly, the questionnaire did not place an 
undue burden on agency officials, the information could feasibly be 
obtained, and the survey was comprehensive and unbiased. On the basis 
of the feedback we received, we made changes to the content of the 
survey. We posted the questionnaire on GAO's survey website. When the 
survey was activated, the agriculture specialists who had been 
selected to participate were informed of its availability by 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. We sent reminder 
and follow-up e-mails to agriculture specialists who had not completed 
their surveys in a specific time period to increase our response rate. 
Since this was a Web-based survey, respondents entered their answers 
directly into the electronic questionnaire, eliminating the need to 
key data into a database, thus minimizing error. The survey was 
available from February 6, 2012, until March 9, 2012. Results of the 
survey are summarized in GAO-12-884SP. 

To facilitate comparison with the findings from our prior report, we 
used a questionnaire for this survey similar to the one we used in 
2006. The 2006 questionnaire focused on the transition from 
agriculture specialists and supervisors in USDA to CBP, and we 
recognize that there may be demographic shifts in these agriculture 
specialists and supervisors that we did not calculate. However, we do 
not believe this affected the results of our analysis. The 2012 survey 
contained 25 closed-ended questions that asked for opinions and 
assessments of (1) agricultural inspection training, (2) agricultural 
inspection duties, (3) agricultural inspection supplies and equipment, 
(4) communication and information-sharing within CBP and between other 
agencies, and (5) challenges related to conducting agricultural work 
activities. Some of those questions were specifically for agriculture 
canine handlers. In addition, the survey contained two open-ended 
questions asking for opinions and assessments of what is going well 
and what could be improved in regards to the work of agriculture 
specialists. We conducted a content analysis on the responses to the 
open-ended questions using all of the same categories that were used 
in 2006, adding new categories as appropriate. We categorized the 
responses based on the descriptions of the categories from 2006. The 
responses were placed into as many categories as appropriate; however, 
each response was placed no more than once in any category. We 
conducted an independent review of the results and resolved any 
disagreement. 

We conducted this performance audit from August 2011 to September 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. 

[End of section] 

Appendix II: Summary of Responses to Open-ended Survey Questions in 
2006 and 2012: 

Table 6: GAO Summary of Responses to the Open-ended Question "What Is 
Going Well with Respect to Your Work as an Agriculture Specialist?" in 
2006 Compared with 2012: 

Category: Agriculture mission; 
Description: See improvement in inspections or interceptions; 
positive mentions of the mission; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 34; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 91. 

Category: Relationships with co-workers (Working relationships); 
Description: Relationships with CBP officers are good; 
receive respect from coworkers; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 113; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 66. 

Category: Salary and benefits; 
Description: Like salary, overtime, benefits, retirement system, or 
work schedule; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 54; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 35. 

Category: Equipment, supplies, uniforms; 
Description: Have tools and supplies needed; 
likes uniform; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 18; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 33. 

Category: Training; 
Description: Training is going well, have enough knowledge to do job; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 50; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 31. 

Category: Information-sharing; 
Description: Receive information from within CBP; 
good communication with other agencies; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 25; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 30. 

Category: Dedicated agriculture specialists; 
Description: Fellow agriculture specialists are highly-qualified or 
dedicated; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: Not counted[B]; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 30. 

Category: Access to databases; 
Description: Have access to databases; 
increased ability to target because of access; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 27; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 21. 

Category: "One Face at the Border" initiative; 
Description: Integration of DHS and USDA good thing; 
common goals; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 34; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 20. 

Category: Flexibility to do job; 
Description: Given enough flexibility or time to perform job as see 
fit; 
flexible job duties; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 28; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 19. 

Category: I like my job; 
Description: Like my job; 
feel performing an important mission; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 34; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 16. 

Category: Nothing is going well; 
Description: Nothing or not much is going well; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 93; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 14. 

Category: Overall going well; 
Description: Overall things are going well (no specifics); 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 10; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 8. 

Category: Have a job; 
Description: Have a job, get paid; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 28; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 6. 

Category: Staffing; 
Description: Staffing levels are good/adequate; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 26; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 4. 

Category: Other; 
Description: Statements not frequent enough to be own category; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 33; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 37. 

Source: GAO analysis of survey responses to this question. 

[A] Responses to this question may have been placed in more than one 
category. 

[B] In 2006, this category was not mentioned frequently enough to be 
counted separately. 

[End of table] 

Table 7: GAO Summary of Responses to the Open-ended Question "What 
Would You Like to See Changed or Improved with Respect to Your Work as 
an Agriculture Specialist?" in 2006 Compared with 2012: 

Category: Problems with CBP chain of command; 
Description: Want separate chain of command for agriculture; 
want to be separated from rest of CBP (similar to Border Patrol); 
want agriculture supervisors; supervisors do not understand mission; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 167; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 125. 

Category: Staffing levels; 
Description: Not enough staff; heavy workload; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 113; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 112. 

Category: Respect or relationships (Working relationships); 
Description: Disrespect or lack of comprehension from management or 
CBP officers regarding mission; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 190; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 109. 

Category: Priority given to the agriculture mission; 
Description: Weakening of agriculture mission; competing priorities 
prevent agriculture inspector from performing mission; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 179; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 86. 

Category: Salary and benefits; 
Description: Salary not enough; 
lack of promotion opportunities for agriculture specialists; lack of 
career ladder; issues with retirement policy; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 97; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 77. 

Category: Training; 
Description: Training opportunities missing or unsatisfactory; 
training for non-agriculture specialists inadequate; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 123; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 68. 

Category: Overtime policy; 
Description: Not enough access to overtime; overtime schedule is 
inflexible; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 75; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 50. 

Category: Policies related to self defense; 
Description: Concern for personal safety; want to be armed; want self-
defense training; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 59; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 41. 

Category: Equipment/supplies; 
Description: Not enough supplies or funding for supplies; difficulty 
obtaining supplies; inadequate office space; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 113; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 39. 

Category: Information-sharing; 
Description: Not receiving information from USDA; 
difficulty communicating with specialists at other ports; lack of 
information sharing from other agencies; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 93; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 38. 

Category: Opportunities for temporary assignments; 
Description: Want opportunities for temporary assignments; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 37; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 30. 

Category: Uniforms; 
Description: Want different uniform for any reason, including to look 
different than armed co-workers or for additional durability; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: Not counted[B]; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 22. 

Category: Data/paperwork; 
Description: Entering required data or completing paperwork is time 
consuming or inefficient; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: Not counted[B]; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 20. 

Category: Return to USDA; 
Description: Agriculture mission should be placed back under USDA; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 61; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 8. 

Category: Other; 
Description: Statements not frequent enough to be own category; 
2006: Number of comments out of 626 total respondents reflecting this 
category[A]: 117; 
2012: Number of comments out of 406 total respondents reflecting this 
category[A]: 79. 

Source: GAO analysis of survey responses to this question. 

[A] Responses to this question may have been placed in more than one 
category. 

[B] In 2006, this category was not mentioned frequently enough to be 
counted separately. 

[End of table] 

[End of section] 

Appendix III: Comments from the U.S. Department of Agriculture: 

USDA: 
United States Department of Agriculture: 
Office of the Secretary: 
Washington, D. C. 20250: 

September 14 2012: 

Ms, Lisa Shames, Director: 
Natural Resources and Environment: 
United States Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Shames: 

The United States Department of Agriculture (USDA) has reviewed the 
Draft Report, "Homeland Security: Agriculture Inspection Program Has 
Made Some Improvements but Management Challenges Persist" (GAO-12-
885). As discussed below, USDA agrees with each Recommendation. USDA 
shares your beliefs that the actions taken to address the 
recommendations in the May 2006 report, "Homeland Security: Management 
and Coordination Problems Increase the Vulnerability of U.S. 
Agriculture to Foreign Pests and Disease" (06-644), have led to 
significant program improvements, but that challenges do still exist. 

GAO Recommendation: 

To help ensure the CBP and APHIS agricultural quarantine inspection 
program (AQI) protects U.S. agriculture from accidental or deliberate 
introduction of foreign pests and disease, we recommend that the 
Secretaries of Agriculture and Homeland Security work together to take 
the following action: Develop a strategic plan for the AQI program 
that lays out its joint mission and program goals. 

USDA Response: 

USDA agrees with this Recommendation. USDA will, in conjunction with 
CBP, develop a joint strategic plan. In 2912, USDA's Animal and Plant 
Health Inspection Service (APHIS) and CBP reengaged the Joint Agency 
Task Force, which will meet quarterly to develop a strategic plan by 
the summer of 2013. 

GAO Recommendation: 

To help ensure the CBP and APHIS agricultural quarantine inspection 
program protects U.S. agriculture from accidental or deliberate 
introduction of foreign pests and disease, we recommend that the 
Secretaries of Agriculture and Homeland Security work together to take 
the following action: Once the strategic plan is completed, as part of 
a coordinated strategic planning effort, identify corresponding 
meaningful performance measures for monitoring progress towards those 
goals. 

USDA Response: 

USDA agrees with this Recommendation. Once the strategic plan is 
completed, we will identify meaningful performance measures for 
monitoring progress towards our goals. We believe the existing 
performance measures go a long way in measuring success for a number 
of pathways, but agree that an effective strategic planning process 
will enhance the effectiveness of the joint AQI program. The Joint 
Agency Task Force will work to strategize new measures that strengthen 
the ability of CBP to measure its effectiveness in the AQI mission. In 
addition, APHIS hopes to automate its performance measure for the 
timeliness of urgent pest identification by the end of Fiscal Year 
2014. We are also working with CBP on development of a data analysis 
group to assess pest trends approaching the United States. This group 
will develop analytical tools to help measure our performance in 
excluding unwanted pests from the United States. We agree these goals 
and measures will help strengthen our program, and we will work with 
CBP to further refine these measures. 

GAO Recommendation: 

To help ensure the CBP and APHIS agricultural quarantine inspection 
program protects U.S. agricultural from accidental or deliberate 
introduction of foreign pests and disease, we recommend that the 
Secretaries of Agriculture and Homeland Security work together to take 
the following action: Continue taking steps to improve the reliability 
of AQI data on arrivals, inspections, and interceptions across ports, 
including reviewing the supervisory review policy and procedures to 
ensure the data are entered accurately. 

USDA Response: 

USDA agrees with this Recommendation. Various data are used to 
determine the effectiveness of inspections in identifying prohibited 
material. Data quality has been a point of emphasis since
the inception of the Government Performance Results Act (GPRA) and in 
implementation of GPRA measures for the AQI program. Quality control 
measures are built into the data collection and reporting system to 
minimize data entry errors. A monthly review and closeout of all data 
reported must be performed by a port supervisor to verify the accuracy 
and completeness of the data reported. Finally, a quarterly review of 
all data is performed at the headquarters level. Any missing data or 
apparent anomalies are identified and the port is contacted to 
determine if the data requires correction. 

The GAO Draft report states that "WADS captures data on the number of 
arrivals, inspections, and interceptions independently from one 
another and these data cannot be linked without extensive analysis." 
The Agriculture Quarantine Activity System (AQAS) contains numerous 
pre-defined reports to simplify analysis for users at the port, field 
office, regional office or headquarters level. CBP data systems (e.g., 
CSIS, ATS, 1004 and 1025) contain detailed information linking a 
specific arrival, inspection, and interception result. Pre-defined 
reports available in AQAS allow the user to see inspection results 
based on the number of positive inspections or based on the number of 
materials seized from one country of origin. The WADS
Program Guide contains a definition of Quarantine Material 
Interceptions. All ports consistently follow this definition when 
reporting data. A variation in the number of arrivals, inspections, 
and interceptions each year does not limit analysis of the 
effectiveness of the AQI program. 

Sampling of a pathway using Agriculture Quarantine Inspection and 
Monitoring procedures will detect any changes in the agricultural risk 
of the pathway. Statistical sampling minimizes the impact of changes 
in arrivals, inspections, interceptions due to external factors such 
as weather economic and political factors. Program effectiveness is 
easily assessed by comparing inspection results to statistical 
estimates of the approaching risk each year. 

GAO Recommendation: 

In addition, GAO recommends that the Secretary of the Department of 
Homeland Security, in consultation with USDA, take actions related to 
the agriculture canine program and the AQI staffing model that 
assesses the risk of potential fiscal constraints. 

USDA Response: 

USDA will work in consultation with the Department of Homeland 
Security on issues related to the agricultural canine program and AQI 
staffing model. For example, APHIS and CBP have formed a Joint Canine 
Implementation Team to improve CRP's implementation of their canine 
teams. The group will analyze what data should be used to evaluate the 
performance and training requirements, as well as assess how potential 
fiscal constraints will be addressed for the development of AQI 
staffing models and canine teams. The recent transfer of the 
agriculture canine program back into the CBP Agriculture Policy and 
Trade Liaison group will allow CBP to exercise complete control in 
allocating the sixty-seven percent of user fees it receives to areas 
such as, employing additional canine teams, strengthen technology 
infrastructure, and to further assist in the integration of the 
agriculture canines teams into the rest of the AQI program. 

Also, in 2012, USDA contracted with Grant Thornton to perform an 
evaluation of AQI user fees for the purpose of identifying additional 
revenues to support processes for improvements in both the canine 
teams and AQI staffing. This evaluation is in the early stages and the 
expected completion date has not been determined. 

Sincerely, 

Signed by: 

Edward Avalos: 
Under Secretary: 
Marketing and Regulatory Programs: 

[End of section] 

Appendix IV: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20525: 

September 12, 2012: 

Ms. Lisa Shames: 
Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Re: Draft Report, GAO-12-885 "Homeland Security: Agriculture 
Inspection Program Has Made Some Improvements but Management 
Challenges Persist" 

Dear Ms. Shames: 

Thank you for the opportunity to review and comment on this draft 
report. The U.S. Department of Homeland Security (DHS) appreciates the 
U.S. Government Accountability Office's (GAO's) work in planning and 
conducting its review and issuing this report. 

The Department is pleased to note GAO's positive recognition of 
Customs and Border Protection's (CBP's) efforts to improve information 
sharing, undertake a full review of DHS's financial management system 
for the Agricultural Quarantine Inspection (AQI) program, and remove 
barriers to timely and accurate AQI user fee transfers from the U.S. 
Department of Agriculture (USDA) to DHS. GAO also noted that CBP has 
increased staffing levels, increased canine training requirements, 
expanded management oversight, and, through a joint task force with 
the USDA Animal and Plant Health Inspection Service (APHIS), expanded 
performance measures. 

The draft report contains six recommendations with which the 
Department concurs. Specifically, GAO recommends that the Secretaries 
of Agriculture and Homeland Security work together to: 

Recommendation 1: Develop a strategic plan for the AQI program that 
lays out its joint mission and program goals. 

Response: Concur. CBP's Agriculture Programs & Trade Liaison (APTL) 
and USDA's APHIS have reconvened the Joint Agency Task Force to 
continue discussions to create and formulate a joint strategic plan. 
The plan would highlight the joint APTL/APHIS agriculture mission and 
program goals. Estimated Completion Date (ECD): August 23, 2013. 

Recommendation 2: Once the strategic plan is completed, as part of a 
coordinated strategic planning effort, identify corresponding 
meaningful performance measures for monitoring progress towards those 
goals. 

Response: Concur. APTL and APHIS have convened the Joint Agency Task 
Force and will discuss next steps on the joint agency performance 
measures action plan. APTL will identify corresponding meaningful 
performance measures for monitoring progress toward the agency goals 
to take corrective action and make improvements. ECD: August 23, 2013. 

Recommendation 3: Continue taking steps to improve the reliability of 
AQI data on arrivals, inspections, and interceptions across ports, 
including reviewing the supervisory review policy and procedures to 
ensure the data are entered accurately. 

Response: Concur. APTL and APHIS have engaged the Joint Agency Task 
Force and will discuss next steps on the joint agency information 
management action plan to improve the reliability and oversight of 
agriculture data. ECD: August 23, 2013. 

GAO also recommends that the Secretary of Homeland Security, in 
consultation with USDA where appropriate, should: 

Recommendation 4: Take steps to ensure the agriculture canine program 
has reliable and meaningful data, including instituting a timely and 
consistent review process at CBP field offices and, evaluate the 
relevance of data collected for the agriculture canine program. 

Response: Concur. CBP and APHIS will develop an evaluation method for 
reporting, collecting, and analyzing data to assist with risk-based 
decision making to enhance the program. APTL acquired Agriculture 
Canine program in August 2012 and will be working with APHIS to 
evaluate the existing program. Initial discussions are planned for 
September 2012. ECD: August 23, 2013. 

Recommendation 5: Develop a plan or strategy for implementing the 
forthcoming AQI staffing model that assesses the risk of potential 
fiscal constraints and determines what actions should be taken to 
mitigate that risk by considering the fiscal resources that may 
realistically be available to ensure that agriculture staffing levels 
at each port are sufficient. 

Response: Concur. APTL has been progressing through the Agriculture 
Specialist Resource Allocation Model sole source contract approval 
process. In conjunction with the completion/vetting of the model and 
based on the results, APTL will determine a strategy for 
implementation. This will include assessing the risk of potential 
fiscal constraints and determining what actions should be taken to 
mitigate that risk by considering the fiscal resources that may 
realistically be available. Coordination with APHIS will continue to 
transpire throughout the process. ECD: August 23, 2013. 

Recommendation 6: Identify any agriculture canine supervisors that do 
not have canine training or experience and work with port directors to 
overcome any barriers to providing formal training. 

Response: Concur. APTL will identify and determine agriculture canine 
supervisor training needs and coordinate with the field office/port to 
overcome potential barriers. APTL, acquired Agriculture Canine program 
in August 2012 and will be working with APHIS to evaluate the existing 
program. Initial discussions planned for September 2012. ECD: August 
23, 2013. 

Thank you for the opportunity to review and comment on this draft 
report. Technical comments have been provided under separate cover. We 
look forward to working with you in the future. 

Sincerely, 

Signed by: 

[Illegible] for: 

Jim H. Crumpacker: 
Director: 
Departmental GAO-OIG Liaison Office: 

[End of section] 

Appendix V: GAO Contacts and Staff Acknowledgments: 

GAO Contact: 

Lisa Shames (202) 512-3841 or shamesl@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Mary Denigan-Macauley 
(Assistant Director), Adam Anguiano, Carl Barden, Michelle Cooper, 
N'Kenge Gibson, Amanda Harris, Stuart Kaufman, Kirsten Lauber, Alison 
O'Neill, and Kiki Theodoropoulos made key contributions to this 
report. Important contributions were also made by Kevin Bray, Joyce 
Evans, and Jena Sinkfield. 

[End of section] 

Footnotes: 

[1] GAO, Homeland Security: Actions Needed to Improve Response to 
Potential Terrorist Attacks and Natural Disasters Affecting Food and 
Agriculture, [hyperlink, http://www.gao.gov/products/GAO-11-652] 
(Washington, D.C.: Aug. 19, 2011). 

[2] GAO, Agricultural Inspection: Improvements Needed to Minimize 
Threat of Foreign Pests and Diseases, [hyperlink, 
http://www.gao.gov/products/GAO/RCED-97-102] (Washington, D.C.: May 5, 
1997). 

[3] GAO, Homeland Security: Management and Coordination Problems 
Increase the Vulnerability of U.S. Agriculture to Foreign Pests and 
Disease, [hyperlink, http://www.gao.gov/products/GAO-06-644] 
(Washington, D.C.: May 19, 2006). 

[4] GAO, Homeland Security: Agriculture Specialists' Views of Their 
Work Experiences after Transfer to DHS, [hyperlink, 
http://www.gao.gov/products/GAO-07-209R] (Washington, D.C.: Nov. 14, 
2006). 

[5] Pub. L. No. 107-296, 116 Stat. 2135. 

[6] Pub. L. No. 101-624 § 2509, 104 Stat. 3359 (codified as amended at 
21 U.S.C. § 136a). These fees are credited to USDA accounts that incur 
the costs associated with the AQI services. The fees remain available 
until expended, without fiscal year limitation. 

[7] GAO, Federal User Fees: Substantive Reviews Needed to Align Port-
Related Fees with the Programs They Support, [hyperlink, 
http://www.gao.gov/products/GAO-08-321] (Washington, D.C.: Feb. 22, 
2008); and Federal User Fees: Key Aspects of International Air 
Passenger Inspection Fees Should Be Addressed Regardless of Whether 
Fees Are Consolidated, [hyperlink, 
http://www.gao.gov/products/GAO-07-1131] (Washington, D.C.: Sept. 24, 
2007). 

[8] [hyperlink, http://www.gao.gov/products/GAO-06-644]. 

[9] The 95 percent confidence interval surrounding the estimate of 83 
percent of agriculture specialists and supervisors at CBP believing 
information regarding agriculture regulatory changes was delivered in 
a timely manner either always or most of the time ranges from 78.8 to 
87.3. 

[10] The 95 percent confidence interval surrounding the estimate of 4 
percent of agriculture specialists and supervisors at CBP believing 
that the timeliness of information provided to agriculture specialists 
is a very major challenge ranges from 2.1 percent to 7.3 percent, and 
the 95 percent confidence interval surrounding the estimate of 57 
percent of agriculture specialists and supervisors at CBP believing 
that it is a minor challenge or not a challenge ranges from 51.5 
percent to 62.6 percent. 

[11] [hyperlink, http://www.gao.gov/products/GAO-06-644]. 

[12] [hyperlink, http://www.gao.gov/products/GAO-06-644]. 

[13] [hyperlink, http://www.gao.gov/products/GAO-06-644]. 

[14] GAO, Agency Performance Plans: Examples of Practices That Can 
Improve Usefulness to Decisionmakers, [hyperlink, 
http://www.gao.gov/products/GAO/GGD/AIMD-99-69] (Washington, D.C.: 
Feb. 26, 1999). 

[15] Pub. L., No. 103-62, 107 Stat. 285, amended by GPRA Modernization 
Act of 2010, Pub. L. No. 111-352, 142 Stat. 3866. 

[16] For example, see GAO, Environmental Justice: EPA Needs to Take 
Additional Actions to Help Ensure Effective Implementation, 
[hyperlink, http://www.gao.gov/products/GAO-12-77] (Washington, D.C.: 
Oct. 6, 2011). 

[17] [hyperlink, http://www.gao.gov/products/GAO-06-644]. 

[18] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: Nov. 1999). 

[19] [hyperlink, http://www.gao.gov/products/GAO-06-644]. 

[20] [hyperlink, http://www.gao.gov/products/GAO-06-644]. 

[21] The 95 percent confidence interval surrounding the estimate that 
35 percent of agriculture canine specialists at CBP believe that their 
supervisor did not have adequate agriculture canine expertise to 
advise them on any work-related concerns in the past year ranges from 
26.6 percent to 43.4 percent. 

[22] GAO, Human Capital: A Guide for Assessing Strategic Training and 
Development Efforts in the Federal Government, [hyperlink, 
http://www.gao.gov/products/GAO-04-546G] (Washington, D.C.: March 
2004). 

[23] [hyperlink, http://www.gao.gov/products/GAO-06-644]. 

[24] [hyperlink, http://www.gao.gov/products/GAO-07-1131]. 

[25] GAO, Agencies' Annual Performance Plans under the Results Act: An 
Assessment Guide to Facilitate Congressional Decisionmaking, 
[hyperlink, http://www.gao.gov/products/GAO/GGD/AIMD-10.1.18] 
(Washington, D.C.: February 1998). 

[26] For the purposes of this report, we did not assess the 
reliability of the numbers presented in the contractor's analysis. 

[27] The 95 percent confidence intervals surrounding the estimates of 
76 percent and 51 percent of agriculture specialists and supervisors 
at CBP range from 66.6 percent to 83.0 percent for those hired before 
the merger and from 44.6 percent to 58.3 percent for those hired after 
the merger. 

[28] The 95 percent confidence intervals surrounding the estimates of 
58 percent and 36 percent of agriculture specialists and supervisors 
at CBP range from 52.4 percent to 62.6 percent for those hired before 
the merger and from 28.2 percent to 44.3 percent for those hired after 
the merger. 

[29] The 95 percent confidence interval surrounding the estimate for 
the 28 percent of agriculture specialists and supervisors at CBP 
believing that the sufficiency of training is not a challenge to 
conducting agriculture duties at their port ranges from 23.2 percent 
to 33.1 percent, and the 95 percent confidence interval surrounding 
the estimate for the 29 percent ranges from 23.9 percent to 34.1 
percent. 

[30] The 95 percent confidence interval surrounding the estimate of 36 
percent of agriculture specialists and supervisors at CBP believing 
that information on agriculture regulatory changes is always delivered 
in a timely manner ranges from 30.2 percent to 40.8 percent, and the 
95 percent confidence interval surrounding the estimate of 48 percent 
ranges from 42.3 percent to 53.4 percent. 

[31] The 95 percent confidence interval surrounding the estimate from 
2006 of 17 percent of agriculture specialists and supervisors at CBP 
believing such information was always delivered in a timely manner 
ranged from 14.3 percent to 21.0 percent, and the 95 percent 
confidence interval surrounding the estimate of 38 percent ranged from 
33.4 percent to 41.9 percent. The way the questions were asked varied 
slightly from 2006 to 2012. 

[32] The 95 percent confidence interval surrounding the estimate in 
2006 of 21 percent of agriculture specialists and supervisors at CBP 
believing they always receive information on urgent alerts, pest 
alerts, and updated pages for agriculture regulatory manual in a 
timely manner ranged from 17.8 percent to 24.9 percent. In 2012, the 
95 percent confidence interval surrounding the 34 percent estimate 
ranges from 28.9 percent to 39.4 percent. The 95 percent confidence 
interval surrounding the estimate in 2006 of 19 percent ranged from 
16.0 percent to 22.9 percent. In 2012, the 95 percent confidence 
interval surrounding the 33 percent estimate ranges from 28.1 percent 
to 38.6 percent. The 95 percent confidence interval surrounding the 
estimate in 2006 of 18 percent ranged from 14.8 percent to 21.7 
percent. In 2012, the 95 percent confidence interval surrounding the 
37 percent estimate ranges from 31.4 percent to 42.1 percent. 

[33] The 95 percent confidence interval surrounding the estimate of 57 
percent ranges from 51.5 percent to 62.6 percent. 

[34] The 95 percent confidence interval surrounding the estimate of 30 
percent of agriculture specialists and supervisors at CBP remaining 
concerned about CBP's chain of command ranges from 24.4 percent to 
34.7 percent, and the 95 percent confidence interval surrounding the 
estimate of 23 percent ranges from 17.9 percent to 27.4 percent. 

[35] The 95 percent confidence interval surrounding the estimate of 39 
percent of agriculture specialists and supervisors at CBP identifying 
the priority given to the agriculture mission is a very major 
challenge ranges from 34.0 percent to 44.9 percent, and the 95 percent 
confidence interval surrounding the estimate of 23 percent ranges from 
18.5 percent to 28.0 percent. 

[36] The 95 percent confidence interval surrounding the 2006 estimate 
of 42 percent of agriculture specialists and supervisors at CBP 
believing their work is definitely not respected by CBP management 
ranged from 37.5 percent to 46.2 percent; the 95 percent confidence 
interval surrounding the 2012 estimate of 43 percent ranges from 37.7 
percent to 48.8 percent. The 95 percent confidence interval 
surrounding the 2006 estimate of 35 percent of agriculture specialists 
and supervisors at CBP believing their work is definitely not 
respected by CBP management ranged from 31.3 percent to 39.6 percent; 
the 95 percent confidence interval surrounding the 2012 estimate of 28 
percent ranges from 22.5 percent to 32.6 percent. 

[37] The 95 percent confidence interval surrounding the estimate of 50 
percent of agriculture specialists and supervisors at CBP believing 
that their port definitely does not have enough agriculture 
specialists to carry out agriculture duties ranges from 44.4 percent 
to 55.6 percent, and the 95 percent confidence interval surrounding 
the estimate of 21 percent ranges from 16.2 percent to 25.4 percent. 

[38] The 95 percent confidence interval surrounding the 2006 estimate 
of 42 percent of agriculture specialists and supervisors at CBP 
believing that their port definitely does not have enough agriculture 
specialists to carry out agriculture duties ranged from 37.5 percent 
to 46.0 percent, and the 95 percent confidence interval surrounding 
the 2006 estimate of 21 percent ranged from 17.6 percent to 25.1 
percent. 

[39] The 95 percent confidence interval surrounding the estimate of 31 
percent of agriculture specialists and supervisors at CBP believing 
that staffing levels of agriculture specialists is a very major 
challenge ranges from 25.8 percent to 36.3 percent, and the 95 percent 
confidence interval surrounding the estimate of 24 percent ranges from 
19.6 percent to 29.3 percent. 

[40] GAO, Homeland Security: Management and Coordination Problems 
Increase the Vulnerability of U.S. Agriculture to Foreign Pests and 
Disease, [hyperlink, http://www.gao.gov/products/GAO-06-644] 
(Washington, D.C.: May 19, 2006). 

[41] For example, see GAO, Environmental Justice: EPA Needs to Take 
Additional Actions to Help Ensure Effective Implementation, 
[hyperlink, http://www.gao.gov/products/GAO-12-77] (Washington, D.C.: 
Oct. 6, 2011). 

[42] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[End of section] 

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