Customs Revenue:

Customs and Border Protection Needs to Improve Workforce Planning and Accountability

GAO-07-529: Published: Apr 12, 2007. Publicly Released: Apr 12, 2007.

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In forming the Department of Homeland Security (DHS), there was concern that moving the U.S. Customs Service into the new DHS would diminish attention given to collection of customs revenue. In recognition of that concern, Congress required that DHS's Customs Border Protection (CBP) not reduce the staff or resources for customs revenue functions. In March 2003, CBP reported a baseline of 2,263 staff in nine customs revenue positions, and 1,006 staff in associated support positions. The SAFE Port Act required GAO to report on changes related to customs revenue functions since the formation of DHS. This report discusses staff resources, strategic workforce planning, and CBP's public reporting on customs revenue functions. GAO analyzed the number of customs revenue staff, legislatively required staffing levels, and strategic plans and annual performance reports.

Staff resources contributing to customs revenue functions have generally declined since the creation of DHS due, in part, to department priorities and recruiting and retention problems. First, the number of staff in the nine designated customs revenue positions was below the mandated level for much of the time since DHS was formed, but recent efforts increased the number of staff to the mandated levels for most of these positions. Second, the number of support staff associated with customs revenue positions has declined. Lastly, other DHS staff contribute to customs revenue functions, but their contributions have declined. For example, the number of auditors in the Office of the Inspector General reviewing customs issues declined significantly, and they have not performed any customs revenue related performance audits since 2003, as they have primarily focused on security. CBP lacks a strategic workforce plan to guide its performance of customs revenue functions, but has taken some recent steps to improve its human capital management amid challenges. CBP has not determined the critical skills its workforce needs, nor has it developed a strategic workforce plan to inform and guide its future human capital efforts related to customs revenue functions because it has focused on filling open positions. CBP has recently taken some steps to improve its human capital planning such as developing resource allocation models, but gaps in its efforts remain. Additionally, challenges such as a growing workload heighten the importance of such strategic workforce planning. Despite being the second largest revenue generator for the U.S. government, CBP does not publicly report on its performance of customs revenue functions, thus failing to help ensure accountability. CBP's strategic planning documents establish a strategic objective and performance measure related to customs revenue functions. However, CBP does not publicly report on customs revenue functions in its annual plans and performance reports. According to a CBP official, customs revenue measures are not reported in annual performance reports because these functions do not directly address the long-term goal of facilitating trade.

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: The CBP Commissioner should develop a strategic workforce plan that aligns its human capital efforts with its objectives related to performing customs revenue functions. Such a strategic workforce plan should address five principles: (1) involve top management, employees, and other stakeholders, (2) determine critical skills and competencies needed to achieve current and future programmatic goals, (3) develop strategies tailored to address gaps in the number, deployment, and alignment of human capital approaches, (4) build the capability needed to address administrative, educational, and other requirements for supporting workforce planning strategies, and (5) monitor and evaluate the agency's progress toward human capital goals and the contribution of human capital results to achieving programmatic results.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Bureau of Customs and Border Protection

    Status: Closed - Implemented

    Comments: Customs and Border Protection (CBP) has adopted several documents in response to GAO?s recommendation that together contain the elements of a strategic workforce plan. In 2009 CBP issued a Resource Optimization Model that it said assists management in determining the optimal level of staff to meet the performance outcomes and goals for the agency?s trade mission. CBP also issued its Human Capital Strategy for Revenue Positions FY 2010- 2011 and CBP Trade Strategy FY 2009-2013, both of which address the principles outlined in GAO?s recommendation for a strategic workforce plan. In addition, CBP officials told us that they discuss quarterly updates on the status of customs revenue staffing to evaluate progress toward human capital goals.

    Recommendation: In order to employ good management practices and link customs revenue performance measures with agency strategic goals and objectives, the CBP Commissioner should work with the Office of Management and Budget to establish specific customs revenue performance measures and targets as well as evaluate, track, and report performance measures in annual agency Performance and Accountability Reports for congressional and public oversight of customs revenue functions.

    Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Bureau of Customs and Border Protection

    Status: Closed - Implemented

    Comments: In response, CBP developed two new measures in fiscal year 2009 for the Department of Homeland Security's fiscal year 2010-2011 Annual Performance Plan: (1) percent of estimated revenue losses due to non-compliance with trade laws, regulations, and agreements, and (2) estimated revenue losses due to non-compliance with trade laws, regulations, and agreements (in millions). According to CBP, these two measures are currently being tracked and monitored in the DHS Future Years Homeland Security Program database system and were submitted for inclusion in the FY2011 Congressional Budget Justification.

    Recommendation: In order to improve oversight over the performance of customs revenue functions, the Inspector General of the Department of Homeland Security, while developing its annual performance plan, should identify whether areas of high risk related to customs revenue functions exist and consider initiating performance audits to explore and mitigate those risks.

    Agency Affected: Department of Homeland Security: Office of Inspector General

    Status: Closed - Implemented

    Comments: As a result of the recommendation, the DHS OIG began a broad survey of customs revenue functions to determine whether areas of high risk related to exist. In May, the OIG initiated "survey work" to identify areas of high risk that they should examine. Based on its survey work, the OIG identified processes and functions related to customs revenue and categorized them as high, medium, or low risk. Based on its work to date, OIG managers indicated they have identified potential audits they could conduct. They also stated that the OIG has already initiated a review of the operation and integration of CBP's Strategic Trade Centers. This work will focus on the functions, roles, and responsibilities of each of the Strategic Trade Centers and how their work is coordinated to meet CBP goals. The survey team is also recommending that another customs revenue audit related to cash collections be included in the fiscal year 2008 audit plan.

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