Justice and Law Enforcement:
CBP Could Improve Its Estimation of Funding Needed for New Border Patrol Agents
GAO-09-542R: Published: Jun 15, 2009. Publicly Released: Jun 15, 2009.
The U.S. Border Patrol, a component within the Department of Homeland Security's (DHS) U.S. Customs and Border Protection (CBP), is responsible for patrolling 8,000 miles of the land and coastal borders of the United States to detect and prevent the illegal entry of aliens and contraband, including terrorists and weapons of mass destruction. To strengthen control of the U.S. borders, CBP increased the number of Border Patrol agents from about 12,300 in September 2006 to 18,875 in April 2009, an unprecedented 53 percent increase in about 2.5 years. The Border Patrol plans to add additional agents during the remaining months of fiscal year 2009, increasing its onboard strength to about 19,700 agents by the end of September 2009. To support the President's yearly budget request for funding for additional Border Patrol agents, Customs and Border Protection (CBP) first identifies a list of cost items associated with the recruiting, hiring, training, equipping, and deploying of a new Border Patrol agent. These cost items include, for example, recruiting functions: background checks and medical exams to determine an applicant's fitness for the Border Patrol; salary and benefits; training at the Border Patrol's training academy in Artesia, NM; and equipment such as night-vision goggles, mobile radios, and uniforms. All of these cost items are then added together to arrive at what CBP refers to as the Position Cost Model (PCM), the incremental dollar amount needed to recruit, hire, train, equip, and deploy one additional Border Patrol agent. CBP then multiplies the PCM amount by the number of additional Border Patrol agents CBP expects to hire in a particular fiscal year to estimate the funding needed for these additional agents. This budget estimate is then incorporated into the President's overall budget request for CBP. In total, the PCM used to support the President's 2009 budget request for additional Border Patrol agents contained 93 individual cost items totaling $159,642; that is, CBP estimated it would need $159,642 for each additional agent hired in fiscal year 2009 (see enc. I for a list of all 93 cost items). As a result, for fiscal year 2009 the President requested an additional $362.5 million over the Border Patrol's fiscal year 2008 funding level to increase the Border Patrol agent workforce by 2,200 agents. Of this amount, $351.2 million was generated by the PCM estimate ($159,642 x 2,200) and the remaining $11.3 million was for additional support staff, vehicles, and equipment not included in the PCM estimate. The accuracy of estimates for the individual cost items that constitute the PCM is crucial to CBP developing a reliable budget request for new agents. To assist the Congress in reviewing the Border Patrol's funding for new agents, you asked that we assess the reliability of the estimates generated by the PCM. In prior work we identified best practices for agencies to use in developing cost estimates, which are to be comprehensive (e.g., they are reasonably complete, cover pertinent costs in sufficient detail, and ensure that key cost items are neither omitted nor double-counted), accurate (e.g., calculations are correct; there are few, if any, minor mistakes; estimates are not overly conservative or optimistic; and are adjusted properly for inflation), and well-documented (e.g., all calculations are provided, the assumptions are justified, and supporting sources of data are provided). We have also issued standards for internal control in the federal government that outline requirements for effective management control over program operations. This report addresses the extent to which CBP used best practices and internal controls when developing the PCM cost estimates for the President's fiscal year 2009 CBP budget request.
CBP's PCM for the President's fiscal year 2009 budget request was comprehensive and met cost estimating best practice guidelines for developing 16 of the 28 cost items, but did not meet best practice guidelines for developing 12 other cost items, and CBP also did not provide program guidance as required by internal control standards. Specifically, consistent with cost estimating best practices, the fiscal year 2009 PCM was comprehensive in that it reasonably complete, covering 93 pertinent cost items related to recruiting, hiring, training, equipping, and deploying a new Border Patrol agent, and contained both large and small dollar cost items. In addition, the PCM contained cost items both directly related to the hiring of a new agent, such as the agent's salary, and indirectly related, such as the additional rent and utility costs associated with hiring new agents. For 16 of the 28 cost items (which accounted for 49 percent of the total fiscal year 2009 PCM dollar amount), CBP used relevant historical cost data, applied approved ratios and inflation factors to help ensure that specific cost item estimates were accurate and retained appropriate documentation, consistent with best practices. We validated the PCM cost estimate for these 16 items using the documentation and formulas CBP provided, arriving at the same amount or within $20 of the PCM amount. However, for 12 of the 28 cost items, CBP did not meet one or more best practices or follow internal control standards. Best practices state that cost estimates are considered valid if they are well documented so they can be easily replicated or updated and can be traced to original sources through auditing. Similarly, internal control standards require that all transactions and other significant events be clearly documented and the documentation should be readily available for examination. However, we could not replicate the fiscal year 2009 PCM estimate based upon the documentation CBP provided for four of the cost items, CBP could not provide documentation for five other cost items, and CBP did not use relevant cost data that would have provided a more precise cost estimate, document the assumptions used, or apply inflation factors for three cost items. As a result, we could not determine the reliability of these 12 cost items, which accounted for 43 percent ($152 million) of CBP's $351.2 million budget estimate for recruiting, hiring, training, equipping, and deploying an additional 2,200 Border Patrol agents in fiscal year 2009. These deficiencies occurred, in part, because CBP did not provide detailed guidance to CBP offices involved in developing PCM cost item estimates on, for example, who is responsible for developing the various cost items, how PCM estimates are to be calculated, and what documentation requirements are to be applied. CBP's Office of Budget Formulation recognizes that additional rigor needs to be incorporated into the estimating process to improve the reliability of the PCM estimate. Standards for internal control require that agencies document policies and procedures for enforcing management directives, such as developing the PCM, and best practices state that agencies should provide guidance on how cost items are to be calculated and supported. With such guidance, CBP could strengthen its position to help ensure that management's directives for the PCM development process are carried out as intended and consistently result in a reliable cost estimate.
Recommendation for Executive Action
Status: Closed - Implemented
Comments: In February 2010, the Assistant Commissioner, Office of Administration, U.S. Customs and Border Protection (CBP) issued a revised Position Model Development Process that describes the Position Cost Model development process. The Assistant Commissioner also issued draft Position Cost Model Guidelines that identify (1) the roles and responsibilities of CBP offices involved in developing position cost models, (2) policies on methodologies used to determine costs, and (3) best practices for record keeping. The guidelines also establish guidelines on proper auditable documentation. In addition, the Assistant Commissioner issued modular cost standards that detail the methodology to be used for calculating the position cost for a Border Patrol agent. He also issued similar modular cost standards for 9 other CBP positions including, CBP officer, CBP pilot, and import specialist. These actions are consistent with our recommendation.
Recommendation: To strengthen CBP's process for calculating the PCM and to follow cost estimating best practices and internal control standards, the CBP Commissioner should develop written directives or guidelines describing, at a minimum, the PCM development process, the roles and responsibilities of each CBP office with respect to the PCM, how PCM cost items are to be developed, and how such documentation should be maintained for updating and audit purposes.
Agency Affected: Department of Homeland Security: Directorate of Border and Transportation Security: Bureau of Customs and Border Protection