Recommendation: The Commissioner of CBP should ensure that the Office of Field Operations, in consultation with the Office of Trade, develops a plan for managing its increased workload. (Recommendation 1)

Agency: Department of Homeland Security: United States Customs and Border Protection: Office of the Commissioner
Status: Open

Comments: CBP concurred with this recommendation. According to CBP, the new ACE drawback module provides the capability to extract data for workload management. Further enhanced reporting capabilities for drawback claims are under development. CBP's Office of Field Operations and Office of Trade continue to collaborate on a plan to employ risk management principles and automation to resolve the drawback claims backlog and lay the foundation for processing current drawback claims workload. They estimate the completion of this workload management system by October 31, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade assesses the feasibility of flagging excessive export submissions across multiple claims and takes cost-effective steps, based on the assessment, to prevent over claiming. (Recommendation 2)

Agency: Department of Homeland Security: United States Customs and Border Protection: Office of the Commissioner
Status: Open

Comments: CBP concurred with this recommendation. According to CBP, the Office of Trade is exploring alternatives to track and automatically flag duplicate exports across multiple drawback claims. CBP expects to complete their assessment and plan for implementation by December 31, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade develops a plan, with time frames, to establish a reliable system of record for proof of export. (Recommendation 3)

Agency: Department of Homeland Security: United States Customs and Border Protection: Office of the Commissioner
Status: Open

Comments: CBP concurred with this recommendation. According to CBP, the Office of Trade will work to develop a plan for the use of the Automated Export System (and possibly other systems) for electronic proof of export in the future. They expect this to be complete by September 30, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade turns the claim selection feature in ACE back on and finalizes and implements procedures to target claims for review that were accepted into ACE during the period in which the selection feature was disabled. (Recommendation 4)

Agency: Department of Homeland Security: United States Customs and Border Protection: Office of the Commissioner
Status: Open

Comments: CBP concurred with our recommendation. According to CBP, the Office of Trade, in collaboration with the Office of Information Technology, will automate updates that turn the claim selection feature on in ACE. The Office of Trade plans to retroactively identify drawback claims accepted during the lapse period, and is working to implement a solution by December 31, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade analyzes the results of its targeting of claims for review and designs responses to mitigate identified risks. (Recommendation 5)

Agency: Department of Homeland Security: United States Customs and Border Protection: Office of the Commissioner
Status: Open

Comments: CBP concurred with this recommendation. According to CBP, on March 25, 2020, the Office of Trade initiated an analysis to improve automation and targeting on an ongoing basis. Based on the results of this analysis, the Office of Trade will make any needed adjustments to policy and procedures to assist with data quality, by September 30, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade prioritizes developing a plan to conduct an ex post analysis of the impact on industry and government of key changes to the drawback program, including time frames and methodology. (Recommendation 6)

Agency: Department of Homeland Security: United States Customs and Border Protection: Office of the Commissioner
Status: Open

Comments: CBP concurs with this recommendation. According to CBP, the Office of Trade is finalizing a plan to conduct an ex post analysis of the impact on industry and government of key changes to the drawback program. CBP's analytical plan will include a timeline and methodology for assessing changes to the program. They expect to complete this by November 30, 2020.

Recommendation: To better ensure that CBP's Office of Field Operations' (OFO) staffing processes are transparent and to help ensure CBP can demonstrate that these resource decisions have effectively addressed CBP's mission needs, the Commissioner of CBP should document the methodology and process OFO uses to allocate staff to land ports of entry on the southwest border, including the rationales and factors considered in making these decisions.

Agency: Department of Homeland Security: United States Customs and Border Protection
Status: Open

Comments: In May 2017, CBP's Office of Field Operations began working with a contractor to develop a comprehensive CBP position allocation methodology and tool. According to CBP officials, the purpose of this tool was to ensure a data driven, transparent process for allocating CBP resources--including staff--to land ports of entry on the southwest border. CBP officials stated that the contractor completed the tool in January 2018, CBP tested the tool in fiscal year 2018, and CBP planned to implement the tool in fiscal year 2019. However, CBP officials told us in September 2020 that a subsequent reorganization of the Office of Field Operations rendered the tool unusable without further modification. As a result, they used a manual method to allocate staff in fiscal year 2020 and plan to do the same in fiscal year 2021. As of September 2020, CBP officials planned to document the methodology and process they are now using to allocate staff to land ports of entry, including rationales and factors considered, by November 2020. This recommendation remains open.

Recommendation: To ensure that the performance measures used to evaluate the TAA for Firms program demonstrate program results and to help ensure that EDA can comprehensively evaluate the effectiveness of the program, the Secretary of Commerce should broaden the program's evaluation approach, for instance, by developing additional quantifiable outcome-oriented performance goals and measures for key program areas and conducting further analysis of the data to isolate the impact of the TAA for Firms program from other influences, such as economic trends.

Agency: Department of Commerce
Status: Open
Priority recommendation

Comments: Commerce concurred with our findings and recommendations. As of August 2020, EDA is taking actions to implement our recommendation. In 2012, EDA commissioned a study to inform the development of performance metrics and evaluation methods for the TAA for Firms program. Issued in October 2014, the study provided recommendations to EDA on potential performance metrics, tested the metrics by conducting a statistical analysis of TAA for Firms clients against a control group as well as a survey, and suggested data sources for conducting future evaluations of the TAA for Firms program. According to EDA officials, the study would help provide a foundation for more robust longitudinal performance measurement and enhanced policy analysis, thereby enabling EDA to more comprehensively evaluate the program. These officials noted that, in April 2017, the authors of the study finalized an operational toolkit containing recommended metrics and protocols for data collection and impact evaluation methods. In June 2017, EDA began to pilot test these recommended metrics and evaluation methods to improve program evaluation. EDA formed a working group in December 2017 to further refine the new evaluation system and metrics based on the results of the pilot tests. In May 2018, EDA's working group concluded the refinement of the metrics. In August 2018, EDA continued to collect data on these metrics from its grantees using a pilot survey and refined the metrics as EDA received additional responses and feedback about the pilot survey from grantees. As of August 2020, EDA had developed new data collection instruments that will gather data and information on the TAA for Firms program's outputs and outcomes. EDA intends to use the information collected from the new instruments to conduct program evaluations to better understand how program performance compares with performance goals and the impact of the TAA for Firms program, according to EDA officials. EDA is in the process of developing software to administer the instruments and an internal working group is guiding the implementation of the new data collection system. EDA expects to implement the new system in fiscal year 2020, according to EDA officials. We will continue to monitor Commerce's efforts to implement our recommendation.

Recommendation: To improve the data available to manage and evaluate the TAA for Firms program, the Secretary of Commerce should develop a data system to consistently collect, maintain, and analyze sufficiently reliable and up-to-date data on program operations and participant firms.

Agency: Department of Commerce
Status: Open
Priority recommendation

Comments: Commerce concurred with our findings and recommendations. As of August 2020, EDA is taking actions to implement our recommendation. According to EDA officials, in fiscal year 2017, EDA had developed an improvement plan for its agency-wide data system for collecting data on program operations. As of August 2020, EDA is working with a contractor to implement a new data system to assist in administering and managing the TAA for Firms program. For example, EDA officials expect the new data system to allow TAA Centers to submit participant firms' petitions for certification and adjustment proposals to EDA electronically for review and approval. In addition, these officials noted that the new data system will facilitate EDA's analysis of program performance. EDA anticipates that the new data system for the TAA for Firms program will be operational in fiscal year 2021. We will continue to monitor Commerce's efforts to implement our recommendation.