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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
August 2010:
Homeland Security:
US-VISIT Pilot Evaluations Offer Limited Understanding of Air Exit
Options:
GAO-10-860:
GAO Highlights:
Highlights of GAO-10-860, a report to congressional committees.
Why GAO Did This Study:
The Department of Homeland Security’s (DHS) U.S. Visitor and Immigrant
Status Indicator Technology (US-VISIT) program is to control and
monitor the entry and exit of foreign visitors by storing and
processing biometric and biographic information. The entry capability
has operated since 2006; an exit capability is not yet implemented. In
September 2008, the Consolidated Security, Disaster Assistance, and
Continuing Appropriations Act, 2009, directed DHS to pilot air exit
scenarios with the U.S. Customs and Border Protection (CBP) and
airlines, and to provide a report to congressional committees. DHS
conducted CBP and Transportation Security Administration (TSA) pilots
and issued its evaluation report in October 2009.
Pursuant to the act, GAO reviewed the evaluation report to determine
the extent to which (1) the report addressed statutory conditions and
legislative directions; (2) the report aligned with the scope and
approach in the pilot evaluation plan; (3) the pilots were conducted
in accordance with the evaluation plan; and (4) the evaluation plan
satisfied relevant guidance. To do so, GAO compared the report to
statutory conditions, the evaluation plan, and relevant guidance.
What GAO Found:
The evaluation report partially addressed statutory conditions and
legislative directions and expectations. Specifically, the report
addressed the statutory condition for CBP to collect biometric
information on exiting foreign nationals and four legislative
directions and expectations for conducting the pilots. However, DHS
was unable to address the statutory condition for an airline scenario
because no airline was willing to participate. Also, the report did
not meet a legislative expectation for gathering information on the
security of information collected from visitors subject to US-VISIT.
DHS officials told us that DHS did not view the expectation in the
House report as a requirement. Moreover, they said that security
requirements were tested prior to the pilots and there were no
reported security incidents. However, DHS did not supply documentation
that demonstrated the operational verification of pilot security
requirements.
The evaluation report generally aligned with the scope and approach in
the evaluation plan. Specifically, the objectives and operational
conditions described in the evaluation report were generally
consistent with the evaluation plan. However, the report did not fully
align with the evaluation plan because certain metrics, observations,
and costs (e.g., percentage of system downtime or inoperability, costs
for requirements analysis) were not reported as planned. Also, the
reported scope and approach of the pilots included limitations not
defined in the plan, such as suspending exit screening at departure
gates to avoid flight delays. Such divergence was due, in part, to a
desire to minimize the pilot’s impact on the airports, airlines, and
travelers.
The pilots were not conducted in accordance with the evaluation plan,
in that they did not meet the plan’s stated purpose of operationally
evaluating the air exit requirements. More specifically, about 30
percent of the requirements were not operationally tested, either as
part of the pilots or as part of another exit project. Rather, they
were tested, for example, prior to commencement of pilot operations or
as part of another exit project that has yet to complete operational
testing. DHS officials considered such testing of requirements to be
sufficient.
The evaluation plan did not satisfy relevant guidance, such as
defining standards for gauging the pilots’ performance, defining a
comprehensive methodology for selecting airports and flights, and
planning data analysis to ensure that the results of the evaluation
support air exit decision making. The evaluation plan diverged from
such guidelines, in part, because DHS viewed reporting on how the
pilot results would be used to be outside the scope of its report.
Collectively, the above limitations in scope, approach, and reporting
restrict the pilots’ ability to inform a decision for a long-term air
exit solution and point to the need for DHS to leverage compensating
sources of information on air exit’s operational impacts in making air
exit solution decisions.
What GAO Recommends:
GAO recommends that the Secretary of Homeland Security identify
additional sources of information beyond the pilots to inform a
strategic air exit solution decision. DHS agreed with the
recommendation.
View [hyperlink, http://www.gao.gov/products/GAO-10-860] or key
components. For more information, contact Randolph C. Hite, (202) 512-
3439, hiter@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Conclusions:
Recommendation for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Briefing to Staff of Congressional Committees:
Appendix II: Comments from the Department of Homeland Security:
Appendix III: GAO Contact and Staff Acknowledgments:
Abbreviations:
ADIS: Arrival and Departure Information System:
CBP: U.S. Customs and Border Protection:
DHS: Department of Homeland Security:
IDENT: Automated Biometric Identification System:
POE: port of entry:
RFID: radio frequency identification:
TSA: Transportation Security Administration:
US-VISIT: U.S. Visitor and Immigrant Status Indicator Technology:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
August 10, 2010:
The Honorable Frank R. Lautenberg:
Interim Chairman:
The Honorable George Voinovich:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
United States Senate:
The Honorable David E. Price:
Chairman:
The Honorable Harold Rogers:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
House of Representatives:
Congress and the executive branch have long sought to improve the
integrity and security of U.S. borders through better ways to record
and track the arrival and departure of foreign travelers through U.S.
air, sea, and land ports of entry (POE). Pursuant to a series of
statutory mandates, the Department of Homeland Security (DHS), in
coordination with the Department of State, established the U.S.
Visitor and Immigrant Status Indicator Technology (US-VISIT) program
to use biometric and biographic information to control and monitor the
pre-entry, entry, status, and exit of certain foreign visitors and
immigrants. This program is intended to enhance the security of U.S.
citizens and visitors, facilitate legitimate travel and trade, ensure
the integrity of the U.S. immigration system, and protect the privacy
of visitors to the United States.
Since 2006, DHS has been operating a US-VISIT entry capability at
about 300 air, sea, and land POEs, and has conducted evaluations and
proof-of-concept experiments to further define a US-VISIT exit
capability. In April 2008, DHS announced its intention to implement
biometric exit verification at air and sea POEs in a Notice of
Proposed Rule Making.[Footnote 1] Under this notice, commercial air
and sea carriers would be responsible for developing and deploying the
capability to collect the biometrics from departing travelers and
transmit them to DHS. DHS received comments on the notice and has yet
to publish a final rule. Subsequent to the rule making notice, on
September 30, 2008, the Consolidated Security, Disaster Assistance,
and Continuing Appropriations Act, 2009, was enacted, which directed
DHS to test two scenarios for an air exit solution.[Footnote 2] The
legislative history also provided accompanying direction to DHS in
carrying out the pilot tests of the air exit solution. The act also
required DHS to submit a report on the pilot tests and required that
we review this report.
The act prohibits DHS from obligating any US-VISIT funds provided in
the act for the implementation of an air exit solution until the
department provided a report to the Senate and House Committees on
Appropriations on pilot tests for the solution that addressed the two
scenarios: U.S. Customs and Border Protection (CBP) collects biometric
exit data at airport departure gates; and airlines collect and
transmit such data.
The explanatory statement[Footnote 3] that accompanied the act, and
the House Report[Footnote 4] incorporated by reference into the
explanatory statement, provided further legislative direction for the
conduct of the pilots. DHS issued its Air Exit Pilots Evaluation Plan
in May 2009 and operated two air exit pilots from May 2009 until July
2009. DHS submitted its Air Exit Pilots Evaluation Report to the House
and Senate Appropriations Subcommittees on Homeland Security in
October 2009. According to the US-VISIT Acting Deputy Program Director
and agency documentation, the pilot results are one of several sources
of information that are to be used to inform its decision about a long-
term air exit capability.
Pursuant to the act's requirement that we review DHS's US-VISIT pilot
evaluation report, we determined the extent to which (1) the
evaluation report addresses statutory conditions and legislative
directions; (2) the evaluation report aligns with the scope and
approach in the evaluation plan; (3) the pilots were conducted in
accordance with the evaluation plan; and (4) the evaluation plan
satisfies relevant guidance. To accomplish our objectives, we compared
(1) the evaluation report to applicable statutory conditions and
legislative directions specified in the DHS fiscal year 2009
appropriations act and the accompanying explanatory statement and
House report; (2) the evaluation's reported objectives, scope,
approach, and limitations with those found in the pilots' plan
(including its evaluation framework[Footnote 5]); (3) planned
evaluations and tests with pilot execution documentation, including
business and system requirement test results; and (4) the evaluation
plan to relevant guidance for evaluation planning that we had
previously identified during reviews of federal pilot projects.
[Footnote 6]
On June 10, 2010, we briefed your staffs on the results of our review.
This report summarizes and transmits the presentation slides we used
to brief the staff, which included a recommendation to the Secretary
of Homeland Security. The full briefing materials, including details
on our scope and methodology, are reprinted as appendix I.[Footnote 7]
We conducted this performance audit at US-VISIT program offices in
Arlington, Virginia, from November 2009 to August 2010 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.
Results in Brief:
The two US-VISIT Air Exit Pilots that DHS planned, executed, and
reported to the House and Senate Appropriations Committees were
limited in the information that they contributed toward the
department's understanding of an air exit solution's operational
impacts. Specifically,
* The evaluation report addressed one statutory requirement for a CBP
scenario to collect biometric information on exiting foreign
nationals, and four of the legislative directions and expectations for
conducting the pilots. However, DHS was unable to address the
statutory requirement for an airline scenario because no airline was
willing to participate. Also, the report did not meet a legislative
expectation for gathering information on the security of information
collected from visitors subject to US-VISIT during the pilots. DHS
officials told us that DHS did not view the expectation of the House
report as a requirement. Moreover, they said security requirements
were tested prior to the pilots and there were no reported security
incidents. However, DHS did not supply documentation that demonstrated
the operational verification of pilot security requirements.[Footnote
8]
* The objectives and operational conditions described in the
evaluation report were generally consistent with the evaluation plan.
However, the report did not fully align with the evaluation plan
because certain metrics, observations, and costs (e.g., percentage of
system downtime or inoperability, costs for requirements analysis)
were not reported as planned. Also, the reported scope and approach of
the pilots included limitations not defined in the plan, such as
suspending exit screening at departure gates to avoid flight delays.
Such divergence was due, in part, to a desire to minimize the pilots'
impact on airports, airlines, and travelers.
* The pilots were not conducted in accordance with the evaluation
plan's stated purpose of operationally evaluating the air exit
requirements. More specifically, about 30 percent of the requirements
were not operationally tested, either as part of the pilots or as part
of another exit project. Rather, they were tested, for example, prior
to commencement of pilot operations or as part of another exit project
that has yet to complete operational testing. DHS officials considered
such testing of requirements to be sufficient.
* The evaluation plan did not implement relevant pilot project
guidance, such as defining standards for gauging the pilots'
performance, defining a comprehensive methodology for selecting
airports and flights, and planning data analysis to ensure that the
results of the evaluation support air exit decision making. The
pilots' evaluation plan diverged from such guidelines, in part,
because DHS viewed reporting on how the pilot results would be used to
be outside the scope of its report.
Collectively, these limitations in the pilots' scope, approach, and
reporting restrict the pilots' ability to inform a decision for a long-
term air exit solution and highlight the need for compensating sources
of information on air exit's operational impacts.
Conclusions:
DHS has long been challenged in its ability to deliver the exit
portion of US-VISIT and thereby have a biometrically-based capability
for knowing the status of foreign nationals who have entered the
country. To help address these challenges, Congress directed DHS to
conduct two pilot tests so that the department might gain a better
understanding of the operational impact of implementing different exit
solutions at air ports of entry. However, the degree to which the
results of these pilots can inform DHS's future decisions was limited
because the department was unable to test one scenario and did not
meet a congressional expectation. Further, it was limited in the
extent to which it followed defined pilot plans and reported all
expected results in the evaluation report. Moreover, the scope and
approach defined in the plans that governed the pilots' execution were
also limited by conditions disclosed in the plan and the report, as
well as by the extent and timing of requirements testing. DHS
officials attributed key limitations to schedule constraints and
decisions to intentionally limit the pilots' scope and impacts on
travelers, air carriers, and airports. However, the collective result
is that the pilots cannot alone adequately inform future DHS decisions
on an exit solution for air ports of entry. If these limitations in
the pilots are not otherwise compensated with other information
sources on operational impacts of implementing an air exit solution,
such as comments on the Notice of Proposed Rule Making, then the
department will continue to be challenged in its ability to deliver US-
VISIT exit capabilities in airports.
Recommendation for Executive Action:
To the extent that the limitations in the Air Exit Pilots are not
addressed through other information sources, we recommend that the
Secretary of Homeland Security direct the Under Secretary for National
Protection and Programs to have the US-VISIT Program Director identify
additional sources for the operational impacts of air exit not
addressed in the pilots' evaluation and to incorporate these sources
into its air exit decision making and planning.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, signed by the Director,
Departmental GAO/OIG Liaison Office and reprinted in appendix II, DHS
concurred with our recommendation and clarified its statements
regarding a congressional report expectation. DHS also provided
technical comments and suggested corrections, which we have
incorporated into the report as appropriate.
We are sending copies of this report to the Secretary of Homeland
Security, appropriate congressional committees, and other interested
parties. In addition, the report is available at no charge on the GAO
Web site at [hyperlink, http://www.gao.gov].
Should you or your staffs have questions on matters discussed in this
report, please contact me at (202) 512-3439 or hiter@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 that made
major contributions to this report are listed in appendix III.
Signed by:
Randolph C. Hite:
Director, Information Technology Architecture and System Issues:
[End of section]
Appendix I: Briefing to Staff of Congressional Committees:
Homeland Security: US-VISIT Pilot Evaluations Offer Limited
Understanding of Air Exit Options:
Briefing for staff members of the Subcommittees on Homeland Security:
Senate and House Committees on Appropriations:
June 10, 2010[A]:
[A] Slides 31, 64, 67 and 69 of this briefing were amended after the
date it was provided to the committees to make a technical correction
to reflect updated information.
Briefing Overview:
Introduction;
Objectives;
Results in Brief;
Background
Results;
* Objective 1;
* Objective 2;
* Objective 3;
* Objective 4;
Conclusions;
Recommendation for Executive Action;
Agency Comments and Our Evaluation.
Attachment 1: Objectives, Scope, and Methodology;
Attachment 2: Detailed US-VISIT Processes and Systems;
Attachment 3: Detailed Description of Air Exit Pilots;
Attachment 4: Limitations in Pilot Data Collection.
Introduction:
Congress and the executive branch have long sought to improve the
integrity and security of U.S. borders through better ways to record
and track the arrival and departure of foreign travelers through U.S.
air, sea, and land ports of entry (POE).
Pursuant to a series of statutory mandates, the Department of Homeland
Security (DHS), in coordination with the Department of State,
established the U.S. Visitor and Immigrant Status Indicator Technology
(US-VISIT) program to use biometric and biographic information to
control and monitor the pre-entry, entry, status, and exit of certain
foreign visitors and immigrants. This program is intended to:
* enhance the security of U.S. citizens and visitors,
* facilitate legitimate travel and trade,
* ensure the integrity of the U.S. immigration system, and,
* protect the privacy of visitors to the United States.
Since 2006, DHS has been operating a US-VISIT entry capability at
about 300 air, sea, and land POEs, and has conducted evaluations and
proof-of-concept experiments to further define a US-VISIT exit
capability.
In April 2008, DHS announced its intention to implement biometric exit
verification at air and sea POEs in a Notice of Proposed Rule Making.
[Footnote 9] Under this notice, commercial air and sea carriers would
be responsible for developing and deploying the capability to collect
the biometrics from departing travelers and transmit them to DHS. DHS
received comments on the notice and has yet to publish a final rule.
Subsequent to the rule making notice, on September 30, 2008, the
Consolidated Security, Disaster Assistance, and Continuing
Appropriations Act, 2009, was enacted, which directed DHS to test two
scenarios for an air exit solution.[Footnote 10] The legislative
history also provided accompanying direction to DHS in carrying out
the pilot tests of the air exit solution. The act also required DHS to
submit a report on the pilot tests and required that we review this
report.
The act prohibits DHS from obligating any US-VISIT funds provided in
the act for the implementation of an air exit solution until the
department provided a report to the Senate and House Committees on
Appropriations on pilot tests for the solution that addressed the two
scenarios:
* U.S. Customs and Border Protection (CBP) collects biometric exit
data at airport departure gates; and;
* airlines collect and transmit such data.
The explanatory statement[Footnote 11] that accompanied the act, and
the House Report[Footnote 12] incorporated by reference into the
explanatory statement, provided further legislative direction for the
conduct of the pilots.
DHS issued its Air Exit Pilots Evaluation Plan in May 2009 and
operated two air exit pilots from May 28, 2009, until July 2, 2009.
DHS submitted its Air Exit Pilots Evaluation Report to the House and
Senate Appropriations Subcommittees on Homeland Security on October
26, 2009. According to the US-VISIT Acting Deputy Program Director and
agency documentation, the pilot results are one of several sources of
information that are to be used to inform its decision about a long-
term air exit capability.
[End of section]
Objectives:
As agreed, our objectives were to determine the extent to which (1)
the evaluation report addresses the statutory condition and
legislative directions; (2) the evaluation report aligns with the
scope and approach in the evaluation plan; (3) the pilots were
conducted in accordance with the evaluation plan; and (4) the
evaluation plan satisfies relevant guidance.
To accomplish our objectives, we compared (1) the evaluation report to
applicable statutory conditions and legislative directions specified
in the DHS fiscal year 2009 appropriations act and the accompanying
explanatory statement and House report; (2) the evaluation's reported
objectives, scope, approach, and limitations with those found in the
pilots' plan (including its evaluation framework[Footnote 13]); (3)
planned evaluations and tests with pilot execution documentation,
including business and system requirement test results; and (4) the
evaluation plan to relevant guidance for evaluation planning that we
had previously identified during reviews of federal pilot
projects.[Footnote 14] Details of our scope and methodology are
described in attachment 1.
We conducted this performance audit at US-VISIT program offices in
Arlington, Virginia, from November 2009 to June 2010 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]
Results in Brief:
The two US-VISIT Air Exit Pilots that DHS planned, executed, and
reported to the House and Senate Appropriations Committees were
limited in the information that they contributed toward the
department's understanding of an air exit solution's operational
impacts. Specifically,
* The pilots addressed one statutory requirement for a CBP scenario to
collect information on exiting foreign nationals, and four of the
legislative directions and expectations for conducting the pilots.
However, DHS was unable to address the statutory requirement for an
airline scenario because no airline was willing to participate. Also,
the pilots did not meet a legislative expectation for gathering
information on the security of information collected from visitors
subject to US-VISIT during the pilots.
* The objectives and operational conditions described in the
evaluation report were generally consistent with the evaluation plan.
However, the report did not fully align with the evaluation plan
because certain metrics, observations, and costs (e.g., percentage of
system downtime or inoperability, costs for requirements analysis)
were not reported as planned. Also, the reported scope and approach of
the pilots included limitations not defined in the plan, such as
suspending exit screening at departure gates to avoid flight delays.
Such divergence was due, in part, to a desire to minimize the pilots'
impact on airports, airlines, and travelers.
* The pilots were not conducted in accordance with the evaluation
plan's stated purpose of operationally evaluating the air exit
requirements. More specifically, about 30 percent of the requirements
were not operationally tested, either as part of the pilots or as part
of another exit project. Rather, they were tested, for example, prior
to commencement of pilot operations or as part of another exit project
that has yet to complete operational testing. DHS officials considered
such testing of requirements to be sufficient.
* The evaluation plan did not implement relevant pilot project
guidance, such as defining standards for gauging the Air Exit Pilots'
performance, defining a comprehensive methodology for selecting
airports and flights, and planning data analysis to ensure that the
results of the evaluation support air exit decision making. The Air
Exit Pilots' evaluation plan diverged from such guidelines, in part,
because DHS viewed the use of pilot results to be outside the scope of
its report.
Collectively, these limitations curtail the pilots' ability to inform
a decision for a long-term air exit solution and point to the need for
compensating sources of information on air exit's operational impacts.
Accordingly, we are making a recommendation to the Secretary of
Homeland Security aimed at identifying and leveraging other sources of
information, such as comments from the Notice of Proposed Rule Making,
to better inform a strategic air exit solution decision.
In oral comments on a draft of this briefing, DHS officials agreed
with our recommendation, but did not agree with our point that the
evaluation report omitted a number of planned evaluation metrics and
observations. In this regard, the officials cited information in the
report and provided oral explanations for some, but not all, of these
omissions to counter our position that the metrics and observations,
as defined in the evaluation plan, were missing from the report. While
we acknowledge that most of the citations and explanations provide
information that was related to the missing metric or observation, in
no instance was this information sufficient to satisfy the planned
metric or observation. To clarify the basis for our finding about
these results, we have added an example to the briefing that describes
how the citations and explanations that were provided by DHS officials
fall short of actually reporting results as planned.
DHS officials also provided a range of other comments, including
providing additional information about the testing of the air exit
requirements that were applicable to the pilots and emphasizing that
the scope of the pilots was intentionally limited in order to respond
to the timeframes specified in legislative direction. We have
incorporated these comments into the briefing, as appropriate.
[End of section]
Background: US-VISIT Purpose and Goals:
The purpose of US-VISIT is to provide biometric (e.g., fingerprint)
identification—through the collection, maintenance, and sharing of
biometric and selected biographic data—to authorized DHS and other
federal agencies. In this regard, US-VISIT supports a series of
homeland security-related mission processes that cover hundreds of
millions of foreign national travelers who enter and leave the United
States at about 300 air, sea, and land POEs.[Footnote 15] An overview
of these five processes is depicted in figure 1; the processes are
described in attachment 2.
Figure 1: Mission Processes Supported by US-VISIT:
[Refer to PDF for image: illustration]
Analysis;
Pre-entry;
Entry;
Status;
Exit.
Sources: GAO analysis of US-VISIT data, Nova Development Corp.
(images).
[End of figure]
The US-VISIT program's goals[Footnote 16] are to (1) enhance the
security of U.S. citizens and visitors, (2) facilitate legitimate
travel and trade, (3) ensure the integrity of the U.S. immigration
system, and (4) protect the privacy of visitors. The program is to
achieve these goals by:
* collecting, maintaining, and sharing information on certain foreign
nationals who enter and exit the United States;
* identifying foreign nationals who (1) have overstayed or violated
the terms of their visit; (2) can receive, extend, or adjust their
immigration status; or (3) should be apprehended or detained by law
enforcement officials;
* detecting fraudulent travel documents, verifying visitor identity,
and determining visitor admissibility through the use of biometrics
(digital fingerprints and a digital photograph); and;
* facilitating information sharing and coordination within the
immigration and border management community.
Background: Prior DHS Efforts to Evaluate Exit Solutions:
Since 2004, DHS has evaluated options for recording the exit of
travelers in the air, sea, and land environments by means of several
initiatives.
* January 2004 to May 2007. DHS operated biometric exit pilots at 14
U.S. air and sea POEs to evaluate three technology solutions: self-
service kiosk, mobile device, and a combination of the two. The pilots
established the technical feasibility of a biometric exit solution at
air and sea POEs and identified issues that limited the operational
effectiveness of the solution (e.g., low traveler compliance rates).
* August 2005 to November 2006. DHS operated land entry/exit proof-of-
concept demonstrations at five ports of entry to examine the
feasibility of using passive radio frequency identification (RFID)
technology[Footnote 17] for recording travelers' entry and exit via
RFID tags embedded in the Form 1-94 and to provide CBP officers in
pedestrian lanes with biographic, biometric, and watch list data. The
demonstrations showed that RFID technology was too immature to meet
the requirements of a land exit solution.
Background: Overview of Air Exit Pilots:
The Air Exit Pilots are one component of a larger US-VISIT project
known as Comprehensive Exit, which is to, in part, plan, develop, and
deploy an air and sea exit capability.[Footnote 18]
According to DHS, the purpose of the Air Exit Pilots was to evaluate
the impact on airport exit operations of identifying, verifying, and
collecting information from passengers who were subject to US-VISIT
and leaving the United States.
To accomplish this, the pilots were to:
* evaluate identity verification and exit-recording capabilities when
used with existing POE operations and infrastructure;
* biometrically and biographically verify the identity of in-scope
travelers departing the United States at the pilot locations; and;
* record the exit of, and update the IDENT and Arrival and Departure
Information System (ADIS) records for, each subject traveler.
DHS conducted two pilots from May 2009 until July 2009:
* a CBP pilot at Detroit Metropolitan Wayne County Airport and;
* a Transportation Security Administration (TSA) pilot at Hartsfield-
Jackson Atlanta International Airport.
The pilots utilized two types of portable biometric collection
devices, as described in table 1. For a detailed description of the
pilots, see attachment 3.
Table 1: Devices Used by Air Exit Pilots:
Type of Device: Mobile;
Description: Hand-held device that scanned information on travel
documents and collected biometrics one fingerprint at a time
Pilot Location(s): Detroit, Atlanta[A].
Type of Device: Portable;
Description: Small suitcase that contained a laptop computer, document
scanning device, and a biometric scanner that collected a four-print
slap;
Pilot Location(s): Detroit
Source: DHS.
[A] According to a TSA operations official, only the mobile device was
used in Atlanta because of the limited space available within the
checkpoint area.
[End of table]
According to US-VISIT officials and the Air Exit Pilots documents,
pilot results were to be one of several sources of information to
inform rule making and decisions for a long-term air and sea exit
capability. In this regard, the US-VISIT director also stated that the
scope of the pilots was intentionally limited in order to respond to
the timeframes specified in legislative direction.
Background: GAO Reports on Prior US-VISIT Exit Efforts:
Over the past several years, we have identified a range of broad
management challenges and issues associated with DHS's prior efforts
to develop and deploy an air exit solution.
* In August 2007,[Footnote 19] we reported that US-VISIT had not
developed a complete schedule for biometric exit implementation.
* In February 2008,[Footnote 20] we reported that the Comprehensive
Exit project had not been adequately defined, citing a lack of
analytical basis for high-level project milestones.
* In September 2008,[Footnote 21] we reported that DHS was unlikely to
meet its timeline for implementing an air exit system with biometric
indicators, such as fingerprints, by July 1, 2009, due to several
unresolved issues, such as opposition to the department's published
plan by the airline industry.
* In December 2008,[Footnote 22] we reported that DHS still had not
developed a schedule for the full implementation of a comprehensive
exit solution.
* Most recently, in November 2009,[Footnote 23] we reported that DHS
had not developed a master schedule for Comprehensive Exit that was
integrated or derived in accordance with relevant guidance.
In each of these reports, we made recommendations to ensure that US-
VISIT exit was planned, designed, developed, and implemented in an
effective and efficient manner. DHS generally agreed with our
recommendations.
[End of section]
Objective 1 - Results:
Evaluation Report Satisfied Most, but Not All, Statutory Conditions
and Legislative Directions and Expectations:
The act required the department to provide a report to the Committees
on Appropriations that addressed a test of two scenarios, in which:
(1) CBP collects biometric exit data at airport departure gates; and
(2) airlines collect and transmit such data. To DHS's credit, its
evaluation report addresses the results of the first scenario.
However, the report does not provide results for the second scenario.
As the report states, and the US-VISIT Program Director and airline
officials confirmed, no airlines agreed to participate in the pilots,
thus precluding DHS from testing the second scenario.
In lieu of this second scenario, DHS pilot tested a third scenario in
which TSA collected biometric exit data at a security checkpoint.
According to the pilots' evaluation report, this scenario was added
because it had already been examined as an exit alternative in the
Notice of Proposed Rule Making and because TSA was part of the
traveler departure process.
Notwithstanding the addition of this third scenario, because DHS was
unable to test a scenario where airlines collect and transmit traveler
biometric data, the department's understanding of the impact of this
previously-proposed air exit solution is limited.
Satisfaction of Legislative Directions and Expectations:
The explanatory statement and House report that accompanied the act
provided six legislative directions and expectations for the conduct
of the pilots. In summary, the evaluation report met four and
partially met one of these directions and expectations, and did not
meet the remaining one (see table 2).
Table 2: Air Exit Pilots' Satisfaction of Legislative Directions and
Expectations:
Legislative Directions and Expectations: The pilots shall be completed
not later than January 31, 2009;
Not met.
Legislative Directions and Expectations: The pilots should be
conducted over a time period of not less than 30 days;
Met.
Legislative Directions and Expectations: The pilots are expected to
gather: workload information;
Met.
Legislative Directions and Expectations: The pilots are expected to
gather: cost data;
Met.
Legislative Directions and Expectations: The pilots are expected to
gather: information on the impact on passenger processing time;
Met.
The pilots are expected to gather: data related to the quality and
security of traveler information collected;
Partially met.
Source: GAO analysis of DHS data.
Notes: "Met" means that DHS fully satisfied the direction or
expectation. "Partially met" means that DHS satisfied some, but not
all, aspects of the direction or expectation. "Not met" means that DHS
did not satisfy any aspect of the direction or expectation. Our
assessment of the data gathered by the pilots was based on whether the
evaluation report presented metrics or observations related to each
information category.
[End of table]
More specifically, the pilots operated for a period of 36 days (longer
than the minimum legislatively-directed duration) and while in
operation, collected most of the types of data. The evaluation report
presented:
* workload information, such as average wait times for the pilots and
total field collector and non-field support staff hours needed to
operate the pilots;
* cost data, such as pre-deployment costs, operational support costs,
and CBP and TSA labor and expenses;
* information on the impact of passenger processing time, such as
comparing pilot to baseline wait and processing times for both CBP and
TSA; and;
* data on the quality of traveler information collected, such as
fingerprint quality scores.
However, the pilots were completed on July 2, 2009, about 5 months
after the deadline. The Air Exit Pilots project manager told us that
the January 31, 2009, deadline, which allowed US-VISIT 4 months to
complete the pilots,[Footnote 24] was not enough time for the pilots
to be executed in accordance with the US-VISIT life cycle methodology.
Further, while the House report expected the pilots to gather data
related to the security of traveler information collected, the
evaluation report only stated that all pilot-specific security
requirements were fully met and did not present any data on the
security of the information collected during pilot operations.
According to the US-VISIT director, DHS was not required to fulfill
the expectations of the House report. The US-VISIT Privacy Officer
told us that security requirements were tested prior to the pilots and
that there were no reported security incidents. However, we have yet
to receive any documentation demonstrating the operational
verification of security requirements. As a result, DHS's
understanding of the effectiveness and impact of operational security
controls on air exit processing is limited.
[End of section]
Objective 2 - Results:
Pilot Evaluation Report Was Aligned with Key Aspects of the Evaluation
Plan, but Important Differences Highlight Pilot Limitations:
The evaluation plan defined the pilots' scope, approach, objectives,
and conditions and defined an evaluation framework that included
quantitative metrics, qualitative observations, and cost elements for
which results were expected to be gathered during the pilots.
To DHS's credit, the pilots' three objectives[Footnote 25] were
consistently described in the plan and report. Further, the
operational conditions (e.g., airport locations, passenger screening
locations, biometric collection devices, and duration of the pilots)
described in the plan and report were generally consistent. In
addition, the majority of metrics, observations, and cost elements
that the plan defined for data collection and reporting were addressed
in the report. Specifically, 79 percent of the metrics, 79 percent of
the observations, and 71 percent of the cost elements defined in the
plan were represented in the evaluation report.
Evaluation Report Aligned with Some Aspects of Plans:
Nevertheless, the planned metrics, observations, and cost elements
that were omitted from the report were significant in that each
offered potential insights into the operational impact of the air exit
solution options. Examples of these missing evaluation results include:
* percentage of system downtime or inoperability,
* time needed to address device problems,
* cost for requirements analysis,
* cost for development of IDENT and ADIS reports,
* time needed to instruct travelers,
* effectiveness of airport signs,
* depth and clarity of collector training sessions, and
* percentage of collectors trained during the pilot.
The report did not explain why these cost elements, metrics, and
observations were not captured and reported as planned, other than to
state that planned metrics were revised due to operational constraints
or unavailable data. DHS officials attributed certain differences
between planned and reported metrics and observations to errors in the
evaluation framework. They also explained that certain cost elements
were not reported as planned because they were too small to identify
or applied to items that were not procured as planned.
For some, but not all, of the missing metrics and observations, DHS
officials provided citations in the report and oral explanations that
they viewed as addressing the omissions. However, in each case the
information provided did not satisfy the planned metric or
observation. For example, regarding the metric "percentage of
collectors trained during the pilots," a DHS official referred us to
the reported results for a different metric in the plan entitled
"percentage of collectors trained prior to the pilots" and stated that
because this latter metric was reported and because they knew that 100
percent of officers were trained prior to operating any pilot devices,
then the omitted metric could be derived.
However, the oral information needed to derive the metric was,
nevertheless, not verifiable and the derivation could not be arrived
at based on the information in the report. Moreover, the oral
explanation conflicted with a statement in the report that CBP and TSA
each had an officer who performed biometric processing without
completing a formal training class.
These omissions limit the ability of the reported results of the
pilots to fully inform DHS's understanding of the operational impacts
and costs of implementing an air exit solution.
Reported Limitations Were Not Specified in Evaluation Plans:
In addition to specifying aspects of the pilots' scope and approach,
the evaluation plan also identified a variety of associated
limitations that were expected to affect the execution and results of
the pilots, and these limitations were reiterated in the evaluation
report. For example, both documents disclosed that the pilots were not
intended to fully assess existing systems or biometric devices.
However, the report also identified scope and approach limitations
that were not specified in the plan. For example, TSA did not:
* collect identification from all in-scope travelers ages 14 to
18,[Footnote 26]
* collect flight information from in-scope travelers, or;
* perform biometric collection during the main security checkpoint's
peak period.
Additionally, TSA and CBP suspended exit processing to address
situations that could have negatively impacted travelers or flights.
See attachment 4 for greater detail on these and other reported
limitations.
While the report appropriately disclosed these additional limitations,
it did not address their operational impacts. Moreover, it shows that
the pilot was even more limited than planned. For example, the report
did not:
* describe the operational impacts or costs to TSA operations
associated with a recognized need for automated collection of flight
information from in-scope travelers at TSA security checkpoints;
* discuss the implications of the project's decisions to abort
biometric data collection when potential airline and passenger delays
became apparent or its conclusion that the pilots had "no conclusive
impact on flight delays, delay durations, boarding times or number of
passengers who missed flights;"
* explain how the implied deficiencies in IDENT and ADIS matching and
overstay identification capabilities affected reported matching and
overstay pilot results; and;
* explain how the reported percentages of biometrically-processed
travelers or total flow times would be affected if TSA and CBP had
selected other screening periods, including periods during peak
operations.
According to the evaluation report, some of the additional limitations
were the result of DHS's desire to minimize the impact of the pilots
on airlines, airports, and travelers. The Air Exit Pilots project
manager stated that the impact of these decisions on the evaluation
results was not addressed in the report because the pilots were to
only document discovered limitations, not to extrapolate data based on
them.
Collectively, the limitations cited in the plan and report restrict
the pilots' ability to fully inform DHS's understanding of the
operational impact of implementing an air exit solution.
[End of section]
Objective 3 - Results:
Pilots Were Not Conducted in Accordance With Key Aspect of the
Evaluation Plan:
A key aspect of the pilots' scope, as defined in the evaluation plan,
was that 7 metrics[Footnote 27] to be analyzed during the pilots were
linked to 99 air exit business requirements[Footnote 28] (i.e.,
operational requirements). Of the 99 requirements, the project office
designated 84 as being applicable to the pilots.
DHS tested 54 of the 84 requirements in the pilots' operational
settings as part of operational readiness testing (41 requirements) or
in conjunction with the deployment of a US-VISIT exit-related
reporting capability (13 requirements). However, 25 requirements that
were applicable to the pilots were not tested in the operational
setting associated with the pilots, as provided for in the plan (6
security requirements and 19 requirements assigned to another exit
project). Testing for the remaining 5 requirements was either not
performed (1 requirement) or DHS reported successful testing but has
yet to provide documentation to reflect this (4 requirements).
Pilots Deviated From Key Aspect of Evaluation Plan:
As a result, the impact of 26 requirements on pilot operations and
pilot results was neither evaluated nor reported. The testing status
of these 84 in-scope requirements is summarized in table 3 and
described in greater detail following the table.
Table 3: In-scope Requirements Testing Status:
Designated test environment: Tested with pilots;
Requirements testing status:
Operationally tested: 41;
Not operationally tested: 6;
Not tested: 1;
No documentation: 4.
Designated test environment: Tested with other projects;
Requirements testing status:
Operationally tested: 13;
Not operationally tested: 19;
Not tested: 0;
No documentation: 0.
Designated test environment: Total requirements;
Requirements testing status:
Operationally tested: 54;
Not operationally tested: 25;
Not tested: 1;
No documentation: 4.
Source: GAO analysis of DNS data.
[End of table]
Six security requirements were not part of the pilots' final
operational readiness test. Rather, these six were tested several
weeks prior to the final operational readiness test as part of
security testing, which was not performed in the pilots' operational
environment. As a result, the legislative expectation to gather
information on the security of traveler data, as discussed earlier,
was not met.
For 32 requirements, testing was conducted in conjunction with other
exit projects related to exit record processing and reporting.
According to air exit project officials, since the capabilities
associated with these requirements were delivered by projects other
than the pilots, they relied on the testing results from those
projects as verification of the requirement. However, while one of
these two projects was operationally tested, we have previously
reported[Footnote 29] that the processing capability associated with
the other project has yet to be deployed and will not be completely
tested until data from US-VISIT's long-term air/sea exit solution are
available. Further, program officials also previously told us that
this processing capability was not used by the pilots because the
required technology infrastructure was not in place at the pilot
locations. As a result, 19 of the 32 pilot-related requirements that
were tested as part of other projects were not operationally tested.
Four additional requirements were reportedly tested, but we have yet
to receive verifiable test results to confirm this. Further, the
project office has acknowledged that one additional requirement was
not part of any phase of the pilot testing process.[Footnote 30]
Collectively, this means that about 30 percent of in-scope
requirements were not operationally tested. The Air Exit Pilots
project manager told us that given that the focus of the pilots'
operational evaluation was the impact of air exit on agency operations
and traveler processing, the testing that was performed to demonstrate
satisfaction of the 7 metrics and applicable requirements was
considered sufficient. Nevertheless, the evaluation report states that
100 percent of the operational requirements that were relevant to the
pilots were met. It does not disclose the number of requirements that
were not tested in the pilots' operational setting, and it does not
cite the associated limitations of not doing so.
In light of these requirements that were not operationally tested, the
extent to which the pilots provide a full understanding of DHS's air
exit operational impact is diminished.
[End of section]
Objective 4 - Results:
Evaluation Plan Did Not Reflect Key Aspects of Relevant Guidance:
As we have previously reported,[Footnote 31] a key to effectively
conducting pilot projects is having a well-defined evaluation plan.
Among other things, such a plan should:
* define performance standards,
* describe a comprehensive methodology for conducting the pilot, and,
* specify required data analysis.
The Air Exit Pilots' evaluation plan, which was intended to direct the
evaluation of all aspects of the pilots, did not satisfy these key
aspects of relevant guidance. Supporting project documents also did
not fully address these key aspects. Specifically, they did not define
standards against which pilot performance could be assessed; describe
the basis for selecting airports and flights; or specify the analysis
needed to determine pilot effectiveness and inform decision making.
The air exit project manager stated that, in general, DHS used the air
exit Notice of Proposed Rule Making,[Footnote 32] congressional
direction, and US-VISIT's project life cycle methodology for guidance
in planning the evaluation.
Performance standards. Although the air exit requirements discussed
earlier included performance requirements—-such as the requirement to
transmit traveler data within 24 hours-—these requirements were not
specified in the evaluation plan as standards against which to gauge
pilot performance. Moreover, certain planned metrics that could have
provided performance standards by measuring baseline operational data
(e.g., pre-pilot average boarding time) were not identified as bases
for determining whether the pilots met operational needs. The
evaluation report did cite one performance standard that was not met
(TSA's service goal to check documents within 10 seconds), but this
standard was not defined as an air exit pilots requirement.
DHS officials said that they did not include performance standards in
their evaluation planning because they expected to use the pilot
results to set new performance standards. However, they acknowledged
that the report should have discussed how well the pilot met existing
performance requirements, such as the 24 hour data transmission
requirement.
By not clearly defining performance standards in the pilots'
evaluation plan, the pilots were limited in the extent to which they
could definitively determine the operational impacts and results of
each air exit scenario.
Comprehensive methodology. The evaluation plan and supporting
documents did not explain key aspects of the methodology for
conducting the pilots. Specifically, the methodology for selecting
pilot airports and flights from their respective populations was not
adequately defined.
According to a DHS official, TSA and CBP were each allowed to select a
pilot airport from the 12 airports listed in the Notice of Proposed
Rule Making.[Footnote 33] To select the specific airport, CBP and TSA
considered such factors as airport size and flight destinations (a mix
of international and domestic flights). However, the initial
constraint of 12 airports was not documented in the evaluation plan,
and neither agency fully documented the selection factors or criteria
to be used in making their eventual airport choice, as described below.
* A TSA official told us that TSA sought to pilot an airport from the
Notice of Proposed Rule Making list with a medium-size checkpoint (5-
10 lanes), a strong mix of domestic and international air carriers
(90:10 ratio), and at least one U.S. and one international carrier.
However, TSA then used the number of airport security checkpoints as a
basis for changing its airport selection from Chicago to Atlanta.
[Footnote 34] Moreover, this basis for selection is contradicted by
information in the evaluation report, which stated that Atlanta had
three checkpoints, and that 32 percent of travelers originating in
Atlanta went through alternate checkpoints and thus were not processed
by the pilot.
*CBP documented two factors as the basis for airport selection, namely
carrier diversity and inbound-outbound scheduling flexibility.
However, the agency did not document how it would apply these factors
for each airport or how airports would be selected or eliminated based
on these factors.
In addition, CBP did not fully document the selection factors or
criteria to be used in choosing flights for air exit screening.
* CBP documentation specified the air carriers that would be subject
to the pilot, but did not explain why these carriers were chosen.
Regarding flight selection, the evaluation plan stated an assumption
that CBP would use a "risk selection factor" derived from a flight's
number of visa waiver participants and other criteria. However, the
plan did not specify the other criteria or how these criteria would
contribute to making a flight selection decision. For example, while
the evaluation report stated that CBP chose 91 flights based on their
volume of travelers subject to US-VISIT, neither the evaluation plan
nor CBP's documentation specified the volume threshold that was used
to trigger flight selection, and neither specified whether other
criteria, such as destination,[Footnote 35] was relevant to selection.
Also, while the evaluation report stated that the 91 flights
represented 14.6 percent of all the international flights departing
from the Detroit airport during pilot hours, neither the plan nor
related pilot documents explained why this sample size was sufficient
for understanding air exit's operational impacts on flights.
Without a comprehensive methodology that includes explicit criteria
for selecting the pilots' airports and flights, DHS lacks sufficient
assurance that the scope of its pilots provided a meaningful
understanding of air exit operational impacts.
Data analysis. The evaluation plan did not specify how data would be
analyzed to determine pilot effectiveness and determine how the
results would inform decision making.
Although the evaluation plan stated that both the plan and the
evaluation report would describe how pilot results would inform air
exit decision making, neither addressed how to analyze the collected
data to produce inputs for such decision making. The evaluation report
concluded that the pilot data provided insight into traveler impacts,
biometric capture procedures, traveler compliance, and staffing needs,
and would support further economic analysis for an air exit solution
decision, but did not identify the framework elements or analysis of
pilot results needed to support the economic analysis. The report also
stated that the results of the pilots would be combined with a review
of public comments on the proposed air exit rule to inform the
solution decision, but did not identify which pilot results were
needed for this effort, or the analysis required to compensate for the
known limitations of the pilots. Figure 2, from the pilots' evaluation
report, illustrates DHS's view of the pilots in relation to follow-on
air exit activities.
Figure 2: DHS's Air Exit Next Steps Roadmap:
[Refer to PDF for image: illustration]
2008 Regulatory Impact Analysis (RIA):
Notice of Proposed Rulemaking (NPRM):
Next steps:
D-102: Economic Analysis:
Final Rule:
(1) Confirm NPRM; or:
(2) Revise NPRM; or:
(3) Other options.
Implementation Approach Strategy:
* Technology
* Full Process (e.g. Outreach, training, facilities).
Source: DHS.
[End of figure]
A DHS official told us that specifying how the pilots' results would
be used was beyond the scope of the pilots and declined to describe
the relationship of the pilot evaluation to air exit decision making.
By not specifying the data analysis required to clearly link the
evaluation results to their intended use, DHS was limited in its
ability to measure the pilots' effectiveness, and thus ensure that
they provided the requisite basis for informing a final air exit
solution decision.
[End of section]
Conclusions:
DHS has long been challenged in its ability to deliver the exit
portion of US-VISIT, and thereby have a biometrically-based capability
for knowing the status of foreign nationals who have entered the
country. To help address these challenges, Congress directed DHS to
conduct two pilot tests so that the department might gain a better
understanding of the operational impact of implementing different exit
solutions at air ports of entry. However, the degree to which the
results of these pilots can inform DHS's future decisions was limited
because the department was unable to test one scenario and did not
meet a key congressional expectation. Further, it was limited in the
extent to which it followed defined pilot plans and reported all
expected results in the evaluation report. Moreover, the scope and
approach defined in the plans that governed the pilots' execution were
also limited by conditions disclosed in the plan and the report, as
well as by the extent and timing of requirements testing. DHS
officials attributed key limitations to schedule constraints and
decisions to intentionally limit the pilots' scope and impacts on
travelers, air carriers, and airports. However, the collective result
is that the pilots cannot alone adequately inform future DHS decisions
on an exit solution for air ports of entry. If these limitations in
the pilots are not otherwise compensated with other information
sources on operational impacts of implementing an air exit solution,
such as comments on the Notice of Proposed Rule Making, then the
department will continue to be challenged in its ability to deliver US-
VISIT exit capabilities in airports.
[End of section]
Recommendation for Executive Action:
To the extent that the limitations in the Air Exit Pilots are not
addressed through other information sources, we recommend that the
Secretary of Homeland Security direct the Under Secretary for National
Protection and Programs to have the US-VISIT Program Director identify
additional sources for the operational impacts of air exit not
addressed in the pilots' evaluation and to incorporate these sources
into its air exit decision making and planning.
[End of section]
Agency Comments and Our Evaluation:
We provided a draft of this briefing to DHS officials, including the
US-VISIT director and the Air Exit Pilots project manager, for review
and comment. In their oral comments, the officials agreed with our
recommendation. However, they took issue with our finding that the
reported pilot results omitted a number of planned metrics and
observations. Specifically, they cited information in the report and
provided explanations that they said addressed the metrics and
observations in question. We reviewed each of these citations and
explanations and acknowledge that while most of this information is
related to the omitted metrics or observations, it did not supply the
missing evaluation results as defined in the plan. To clarify the
basis for our finding about these results, we have added an example to
the briefing that describes how the information that DHS provided
falls short of actually reporting all results as planned.
DHS officials also provided a range of other comments, to include
providing additional information about the testing of the air exit
requirements that were applicable to the pilots and emphasizing that
the scope of the pilots was intentionally limited in order to be
responsive to the timeframes specified in legislative direction. We
have incorporated these comments into the briefing, as appropriate.
[End of section]
Attachment 1: Objectives, Scope, and Methodology:
Our objectives were to determine the extent to which (1) the
evaluation report addresses the statutory condition and legislative
directions, (2) the evaluation report aligns with the scope and
approach in the evaluation plan, (3) the pilots were conducted in
accordance with the evaluation plan, and (4) the evaluation plan
satisfies relevant guidance.
We focused our review on the Air Exit Pilots Evaluation Plan,
published by the United States Visitor and Immigrant Status Indicator
Technology (US-VISIT) program on May 14, 2009, and the US-VISIT Air
Exit Pilots Evaluation Report, submitted to Congress on October 26,
2009. We supplemented these documents with other pilot project plans
and records provided by the Department of Homeland Security (DHS),
including documentation and interviews we obtained from our prior
review of the US-VISIT Comprehensive Exit project.[Footnote 36]
To accomplish the first objective, we compared the information
provided in the evaluation report with the applicable statutory
condition in the Department of Homeland Security Appropriations Act,
2009,[Footnote 37] and the legislative directions and expectations
specified in the explanatory statement[Footnote 38] that accompanied
the act and the House report[Footnote 39] incorporated by reference
into the explanatory statement, and determined the extent to which the
report addressed all aspects of each applicable condition, direction,
or expectation. We then characterized each condition, direction, and
expectation as satisfied, partially satisfied, or not satisfied
[Footnote 40] and interviewed DHS officials about their reasons for
not fully satisfying the condition, direction, or expectation.
To accomplish the second objective, we compared the pilots' reported
objectives, scope and limitations, and the evaluation approach
described in the pilots' evaluation framework[Footnote 41] with the
equivalent components defined in the evaluation plan to identify any
differences. We also compared reported pilot data with the evaluation
framework components specified in the plan to determine whether all
planned results were presented. We then interviewed program officials
to determine the reasons for identified variations, and categorized
the identified differences as either reporting omissions or
limitations not specified in the plan. With the assistance of US-VISIT
officials and contractors, we also performed a walk through of the
files used to compile and aggregate pilot results in order to
understand how the reported results were derived from the raw data
collected for the pilots and to confirm that the reported results
corresponded to aggregate data.[Footnote 42]
To accomplish our third objective, we identified aspects of pilot
execution that were not otherwise reviewed for the second objective.
Based on this determination, we identified the Air Exit Pilots'
requirements testing and execution as the focus of this objective. We
compared the pilots' evaluation report and supporting project test
reports with supporting project execution plans—such as pilot business
and system requirements—to determine the extent to which business and
system requirements were incorporated into the pilot as planned. We
also determined whether testing of those requirements was performed as
planned, including the time frames for testing and the extent to which
testing was successfully completed.[Footnote 43] Based on this
analysis, we categorized the discrepancies we identified according to
whether they related to the pre-operational testing or operational
verification of pilot system capabilities. We then interviewed DHS
officials to understand the projects' approach to pilot requirements
verification, and to clarify and correct the discrepancies, where
appropriate.
To accomplish our fourth objective, we identified key evaluation plan
components based on our previous reviews of federal pilot projects.
[Footnote 44] We then analyzed the contents of the Air Exit Pilots'
evaluation plan with respect to the key components in order to
determine the extent to which the plan addressed the components. For
components not fully addressed in the plan, we reviewed the evaluation
report and the pilots' project documents—such as the project's
management plan and tailoring plan—to determine the extent to which
these components were addressed outside the plan. We also interviewed
DHS officials about the guidance they used to develop the pilots
evaluation plan and the reasons for the weaknesses we identified.
For each of our objectives, we assessed the reliability of the data we
analyzed by reviewing existing documentation related to the data
sources and interviewing knowledgeable agency officials about the data
that we used. We found the data sufficiently reliable for the purposes
of this review.
We conducted this performance audit at the US-VISIT program offices in
Arlington, Virginia, from November 2009 to June 2010 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]
Attachment 2: Detailed US-VISIT Processes and Systems:
The United States Visitor and Immigrant Status Indicator Technology
(US-VISIT) program provides biometric (e.g., fingerprint)
identification—through the collection, maintenance, and sharing of
biometric and selected biographic data—to, among others, authorized
Department of Homeland Security (DHS) and other federal agencies, such
as U.S. Customs and Border Protection, U.S. Citizenship and
Immigration Services, U.S. Coast Guard, Department of Defense,
Department of State, Department of Justice, Transportation Security
Administration, and the intelligence community. In fulfilling its
mission, US-VISIT supports a series of homeland security-related
mission processes that cover hundreds of millions of foreign national
travelers who enter and leave the United States. An overview of these
five processes is depicted in figure 3 and described following the
figure.
Figure 3: Mission Processes Supported by US-VISIT:
[Refer to PDF for image: illustration]
Analysis;
Pre-entry;
Entry;
Status;
Exit.
Sources: GAO analysis of US-VISIT data, Nova Development Corp.
(images).
[End of figure]
* Pre-entry: the process of evaluating a traveler's eligibility for
required travel documents, enrolling travelers in automated inspection
programs, and prescreening travelers entering the United States.
* Entry: the process of determining a traveler's admissibility into
the United States at air, sea, or land ports of entry.
* Status management: the process of managing and monitoring the
changes and extensions of the visits of lawfully admitted nonimmigrant
foreign nationals to ensure that they adhere to the terms of their
admission and that they notify appropriate government entities when
they do not.
* Exit: the process of collecting information on travelers departing
the United States.
* Analysis: the process of continuously screening against watch lists
of individuals enrolled in US-VISIT for appropriate reporting and
action and by matching information on arrival and departure and change
or adjustment of status to identify individuals who have overstayed
the terms of their admission.[Footnote 45]
To support these processes, data must be exchanged among a variety of
systems owned by several agencies. Two key US-VISIT systems are:
* The Automated Biometric Identification System (I DENT), which
collects and stores biometric data about foreign visitors, including
information from the Federal Bureau of Investigation, U.S. Immigration
and Customs Enforcement information on deported felons and sexual
offender registrants, and DHS information on previous criminal
histories and previous IDENT enrollments.
* The Arrival and Departure Information System, which stores
noncitizen traveler arrival and departure biographic data received
from air and sea carrier manifests. It matches entry, immigration
status updates, and departure data to provide immigration status,
including whether the individual has overstayed his or her authorized
period of stay. This system contributes information used to support
the analysis mission process described above.
[End of section]
Attachment 3: Detailed Description of Air Exit Pilots:
As we have previously reported,[Footnote 46] the Air Exit Pilots are
one component of a larger United States Visitor and Immigrant Status
Indicator Technology (US-VISIT) project known as Comprehensive Exit,
which is to plan, develop, and deploy an air, sea, and land exit
capability.[Footnote 47]
The purpose of the Air Exit Pilots was to evaluate the impact on
airport exit operations of identifying, verifying, and collecting
information from passengers who were subject to US-VISIT and leaving
the United States. To accomplish this, the pilots were to:
* evaluate identity verification and exit-recording capabilities when
used with existing port operations and infrastructure;
* biometrically and biographically verify the identity of travelers
subject to US-VISIT departing the United States at the pilot
locations; and;
* record the exit of, and update the Automated Biometric
Identification System (IDENT) and Arrival and Departure Information
System (ADIS) records of, each subject traveler.
DHS conducted two pilot scenarios from May 2009 until July 2009:
* a U.S. Customs and Border Protection (CBP) pilot at Detroit
Metropolitan Wayne County Airport, and;
* a Transportation Security Administration (TSA) pilot at Hartsfield-
Jackson Atlanta International Airport.
The Air Exit Pilots used two types of portable biometric collection
devices:
* a hand-held device ("mobile device") that scanned information on
travel documents and collected biometrics one fingerprint at a time,
and;
* a small suitcase ("portable device") that contained a laptop
computer, document scanning device, and a biometric scanner that
collected a four-print slap.
The CBP pilot in Detroit used both devices. According to a TSA
operations official, only the mobile device was used in Atlanta
because of the limited space available within the checkpoint area.
The pilot process consisted of four phases:
1. Identification. For the CBP pilot, CBP officers prescreened
passengers after they provided their boarding passes to airline
employees to identify passengers who were subject to US-VISIT and to
then direct them to a CBP processing station in the jetway. For the
TSA pilot, a TSA Ticket Document Checker prescreened every passenger
entering the checkpoint to identify subject passengers who were
escorted to a processing station manned by Transportation Security
Officers equipped with mobile devices.
2. Collection. Both CBP and TSA officers scanned a machine-readable
travel document presented by a passenger to collect biographic data.
If the document did not scan correctly, the officers were instructed
to enter the biographic data manually into the device. The officers
then used the mobile or portable device to collect an index and middle
fingerprint or a four-print image, respectively.
3. Processing. Once the device indicated that the collected prints
were of sufficient quality, the CBP and TSA officers directed the
passenger to continue onto the departing aircraft or through the
normal checkpoint security screening.
4. Transmission. US-VISIT staff uploaded the information from the
devices to a dedicated workstation and transmitted the data to IDENT
via a secure network connection. Once transmitted, the data were
matched to existing records.
Figure 4 depicts the relationships of the equipment and systems used
in phases 2, 3, and 4 of the pilot process.
Figure 4: Illustration of Air Exit Pilots Biometric Data Collection
and Transmission Process:
[Refer to PDF for image: illustration]
Mobile and portable devices:
Detroit air exit pilot (CBP officer):
US-VISIT staff; Dedicated workstation.
Mobile device:
Atlanta air exit pilot (Transportation Security Officer);
US-VISIT staff; Dedicated workstation.
Secure computer connection:
IDENT.
Source: GAO analysis of agency data.
[End of figure]
CBP Pilot Operations. As reported by DHS, CBP pilot operations were
conducted at departure gates of selected international flights and
usually occurred in the jetway between the air carrier boarding pass
collector and the aircraft itself. The CBP pilot also tested several
biometric collection configurations in the terminal itself, directly
outside the jetway. CBP pilot operations generally consisted of four
steps.
* CBP officers, who were designated as "sorters," inspected travel
documents.
* Sorters directed travelers not subject to US-VISIT to bypass the
biometric collection area and to board the aircraft.
* If travelers were identified as subject to US-VISIT, the sorters
directed them to one of the four or five CBP officer collectors.
* Collectors gathered biographic and biometric information and then
directed the travelers to board the aircraft.
In cases where less physical space was available, CBP used a different
configuration where the sorters were located just inside the doorway
of the boarding area. The CBP data collectors then positioned
themselves behind the sorters along the far wall of the boarding area.
Once travelers were processed, they were directed to the jetway.
TSA Pilot Operations. TSA pilot operations were conducted at the
Atlanta airport's main security checkpoint. TSA operations generally
consisted of five steps.
* TSA Travel Document Checkers reviewed travel documents and
interviewed travelers about their final destination.
* The Travel Document Checkers directed travelers not subject to US-
VISIT to proceed to security screening.
* If travelers were identified as subject to US-VISIT, the Travel
Document Checkers called for a Control Transportation Security Officer
escort.
* The Control Transportation Security Officers then escorted these
travelers to one of three biometric collection areas where Biometric
Collection Transportation Security Officers collected biographic and
biometric information.
* Once traveler biometric and biographic data collection was complete,
travelers were directed to the metal detector queues where they
completed the security screening process.
DHS reported several constraints on TSA's traveler processing for the
pilot.
* Air exit pilot operations were not conducted at the other two
security checkpoints in the Atlanta airport.
* TSA did not process travelers who flew into the Atlanta airport and
then departed on an international flight without leaving the airport's
sterile area.
* TSA pilot did not process all travelers ages 14 to 18. Although
travelers in this age group may be subject to US-VISIT, TSA policy
does not require travelers under the age of 18 to present photo
identification.[Footnote 48]
In its Air Exit Pilots Evaluation Report, DHS presented a variety of
information that characterized the CBP and TSA pilots. Elements of
that information that help to understand the scope and context of the
pilots are presented in table 4.
Table 4: DHS-reported Information on the Air Exit Pilots:
Pilot Characteristic: Airport;
CBP: Detroit Metropolitan Wayne County Airport;
TSA: Hartsfield-Jackson Atlanta International Airport.
Pilot Characteristic: Physical location;
CBP: Departure gates for selected flights at McNamara and North
Terminals;
TSA: Main TSA security checkpoint.
Pilot Characteristic: Operational time frame;
CBP: 05/28/2009 — 07/02/2009;
TSA: 05/28/2009 — 07/02/2009.
Pilot Characteristic: Technologies used;
CBP: Mobile and portable collection devices;
TSA: Mobile collection device.
Pilot Characteristic: Flights inspected;
CBP: 2-4 international flights per day (excluding flights to Canada
and Mexico, pre-cleared and chartered flights);
TSA: Unreported, as TSA did not record individuals' flight departure
information.
Pilot Characteristic: Number of affected flights;
CBP: 91;
TSA: Unreported, as TSA did not record individuals' flight departure
information.
Pilot Characteristic: Number of passengers checked for biometric
collection eligibility:
CBP: 27,111;
TSA: 476,168.
Pilot Characteristic: Number of passengers processed by pilots;
CBP: 9,448;
TSA: 20,296.
Pilot Characteristic: Number of passengers that refused to provide
biometric data;
CBP: 0;
TSA: 1.
Pilot Characteristic: Average impact to boarding flow time (CBP) or
security check flow time (TSA), per passenger;
CBP: None;
TSA: 2 min. 8 sec. for travelers subject to US-VISIT; 17 sec. for
travelers not subject to US-VISIT.
Pilot Characteristic: Biographic and biometric data collection times;
CBP: 49 sec. for mobile device; 30 sec. for portable device;
TSA: 68 sec. for mobile device (portable device not used).
Pilot Characteristic: Labor hours over 35-day operations;
CBP: 1,292 hours;
TSA: 6,423 hours.
Pilot Characteristic: Labor costs and expenses over 35-day operations;
CBP: $77,501;
TSA: $393,410.
Pilot Characteristic: Number of watchlist hits[A];
CBP: 44;
TSA: 131.
Pilot Characteristic: Number of suspected overstays[B];
CBP: 60;
TSA: 90.
Source: DHS.
[A] DHS reported CBP reviewed each of these watchlist hits and
immediately demoted 145. Further review by CBP concluded that none of
the 175 hits would have resulted in prevention of departure.
[B] DHS reported that these system-generated results are overstated
due to system limitations related to instances where ADIS records did
not reflect up-to-date traveler status due to recent changes or
extensions of status. Further, the report noted that the biometric and
biographic data reconciliation between IDENT and ADIS needed to be
enhanced to improve record matching.
[End of table]
The evaluation plan specified a variety of limitations that were
expected to affect the execution of the pilots. For example, the
pilots were not intended to fully assess existing systems or biometric
devices, would minimize interference with air carrier boarding
processes, and would rely on subject matter experts for cost data not
available during the pilot, and these limitations were generally
reiterated in the evaluation report. However, the report also
identified other limitations not called out in the plan, as identified
in table 5.
Table 5: Selected Limitations in Pilot Data Collection:
Limitation Area: Data from travelers subject to United States Visitor
and Immigrant Status Indicator Technology (US-VISIT);
Evaluation Report Examples: Transportation Security Administration
(TSA) did not collect identification from all travelers subject to US-
VISIT ages 14 to 18;[A]
Impact on Pilot Results: Metrics and observations did not reflect all
travelers subject to US-VISIT.
Limitation Area: Data from travelers subject to United States Visitor
and Immigrant Status Indicator Technology (US-VISIT);
Evaluation Report Examples: TSA did not collect flight information
from travelers subject to US-VISIT;
Required data on travelers subject to US-VISIT was not collected.
Impact on Pilot Results: Report stated that automation would be
required to collect flight information, but operational impact of the
automation was not described.
Limitation Area: Data from travelers subject to United States Visitor
and Immigrant Status Indicator Technology (US-VISIT);
Evaluation Report Examples: U.S. Customs and Border Protection (CBP)
did not regularly collect identification from airline crew members
subject to US-VISIT who
boarded their plane prior to the start of CBP exit processing at the
departure gates;
Impact on Pilot Results: Metrics and observations did not reflect all
airline crew members subject to US-VISIT.
Limitation Area: Impact on travelers and flights:
Evaluation Report Examples: TSA suspended exit processing to address
queues at other TSA posts unrelated to the pilot. CBP suspended
processing and data collection from boarding passengers and crew when
such collection would have delayed flight departures;
Impact on Pilot Results: Report stated that the pilots were designed
to avoid impact on air carrier and airport operations and had no
conclusive impact on flight delays, delay durations, boarding times,
or number of passengers who missed flights.
Limitation Area: Facility and infrastructure needs;
Evaluation Report Examples: No data was reported on the costs of
airport electricity, device storage, or network circuits for the
pilots;
Impact on Pilot Results: Upgrade and recurring costs of exit
processing for airports and Department of Homeland Security (DHS)
telecommunications were not described.
Limitation Area: Acquisition and development;
Evaluation Report Examples: The costs for design, development, and
testing were not individually measured, but were derived by evenly
dividing a single reported value three ways;
Impact on Pilot Results: Accurate costs for product design,
development, and test planning and execution activities were not
reported.
Limitation Area: Acquisition and development;
Evaluation Report Examples: Arrival and Departure Information System
and Automated Biometric Identification System need to be enhanced to
match biometric and biographic data;
Impact on Pilot Results: Shortcomings of biometric and biographic
matching were not described. Needed improvements and their operational
impacts were not described.
Limitation Area: Acquisition and development;
Evaluation Report Examples: Overstay results did not reflect recent
changes to or extensions of traveler status;
Impact on Pilot Results: Report stated that more analysis would be
required to confirm the system-generated overstay results, but did not
describe the analysis or its results.
Limitation Area: Acquisition and development;
Evaluation Report Examples: Mobile device did not report finger scan
quality score to collectors;
Impact on Pilot Results: Pilot could not assess how operational
conditions affected fingerprint quality.
Source: GAO analysis of DNS data.
[A] The evaluation report stated that visibility into the US-VISIT
traveler status of travelers ages 14 to 18 was limited because of
conflicting TSA and US-VISIT policies. According to a TSA official,
data were collected on these travelers only when they were with in-
scope adults.
[End of table]
[End of Briefing Slides]
Appendix II: Comments from the Department of Homeland Security:
U.S Department of Homeland Security:
Washington, DC 20528:
July 27, 2010:
Mr. Randolph C. Hite:
Director, Information Technology Architecture and System Issues:
441 G Street, NW:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Mr. Hite:
Re: Draft Report GA0-10-860, Homeland Security: US-VISIT Pilot
Evaluations Offer Limited Understanding of Air Exit Options
(Engagement 310688):
The Department of Homeland Security (DHS/Department) appreciates the
opportunity to review and comment on the U.S. Government
Accountability Office's (GAO) draft report referenced above. GAO made
one recommendation regarding the evaluation report of the air exit
pilots that the United States Visitor and Immigrant Status Indicator
Technology (US-VISIT) Program submitted to Congress in October 2009.
That recommendation reads as follows:
To the extent that the limitations in the Air Exit Pilots are not
addressed through other information sources, we recommend that the
Secretary of Homeland Security direct the Under Secretary for National
Protection and Programs to have the US-VISIT Program Director identify
additional sources for the operational impacts of air exit not
addressed in the pilots' evaluation and to incorporate these sources
into its air exit decision making and planning.
DHS readily concurs with GAO's recommendation. The pilots that US-
VISIT conducted from May to July 2009 were never intended to be the
sole source of information for the Department to consider in making a
decision on a final air exit solution, but rather are only one source
of information that DHS has taken into account.
While we separately are providing a comment matrix that addresses
several technical points and suggested corrections that the Department
wishes to share with GAO, one minor clarification is worth
highlighting here. The report states that "DHS officials told us that
DHS did not view the expectation in the House report as a
requirement." DHS certainly takes seriously, and endeavors to comply
with, the guidance provided by Congress in committee reports; however,
the point of the Department's statements on this matter was merely
that congressional reports do not, technically speaking, have the
force of law. See, e.g., Hein v. Freedom From Religion Foundation,
Inc., 551 U.S. 587, 608 n.7 (2007) ("Indicia in committee reports and
other legislative history as to how the funds should or are expected
to be spent do not establish any legal requirements on the agency").
Thank you for the opportunity to comment on this Draft Report and we
look forward to working with you on future homeland security issues.
Sincerely,
Signed by:
Jerald E. Levine:
Director:
Departmental GAO/01G Liaison Office:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Randolph C. Hite, (202) 512-3439 or hiter@gao.gov:
Staff Acknowledgments:
In addition to the contact name above, individuals making
contributions to this report included Paula Moore (Assistant
Director), Neil Doherty, Rebecca Eyler, Claudia Fletcher, Dave
Hinchman, and Daniel Swartz.
[End of section]
Footnotes:
[1] 73 Fed. Reg. 22065 (Apr. 24, 2008).
[2] Pub. L. No. 110-329, 122 Stat. 3574, 3668-70 (Sept. 30, 2008).
[3] See Explanatory Statement, 154 Cong. Rec. H9427, H9802 (daily ed.
Sept. 24, 2008) and the Consolidated Security, Disaster Assistance,
and Continuing Appropriations Act, 2009, Pub. L. No. 110-329, Div. D,
Department of Homeland Security Appropriations Act, 2009 (Sept. 30,
2008). Section 4 of Pub. L. No. 110-329 provides that the explanatory
statement shall have the same effect with respect to the allocation of
funds and the implementation of the act as if it were a joint
explanatory statement of a committee of conference.
[4] H.R. Rep. No. 110-862, at 103 (2008).
[5] The Air Exit Pilots' evaluation framework consisted of metrics,
observations, and cost elements; associated data sources; and other
data collection specifications.
[6] GAO, Tax Administration: IRS Needs to Strengthen Its Approach for
Evaluating the SRFMI Data-Sharing Pilot Program, [hyperlink,
http://www.gao.gov/products/GAO-09-45] (Washington, D.C.: Nov. 7,
2008) and Transportation Worker Identification Credential: Progress
Made in Enrolling Workers and Activating Credentials but Evaluation
Plan Needed to Help Inform the Implementation of Card Readers,
[hyperlink, http://www.gao.gov/products/GAO-10-43] (Washington, D.C.:
Nov. 18, 2009).
[7] The briefing in appendix I contains a minor change from the
version provided to the committees on June 10, 2010, to recognize that
TSA collected data from certain passengers ages 14 to 18.
[8] This summary clarifies our findings for the first objective by
using "evaluation report" and "report" in place of "pilots," the term
used in the corresponding paragraph of the briefing in appendix I.
[9] 73 Fed. Reg. 22065 (Apr. 24, 2008).
[10] Pub. L No. 110-329, 122 Stat. 3574, 3668-70 (Sept. 30, 2008).
[11] See Explanatory Statement, 154 Cong. Rec. H9427, H9802 (daily ed.
Sept. 24, 2008) and the Consolidated Security, Disaster Assistance,
and Continuing Appropriations Act, 2009, Pub. L. No. 110-329, Div. D,
Department of Homeland Security Appropriations Act, 2009 (Sept. 30,
2008). Section 4 of Pub. L. No. 110-329 provides that the Explanatory
Statement shall have the same effect with respect to the allocation of
funds and the implementation of the act as if it were a joint
explanatory statement of a committee of conference.
[12] H.R. Rep. No. 110-862, at 103 (2008).
[13] The Air Exit Pilots' evaluation framework consisted of metrics,
observations, and cost elements; associated data sources; and other
data collection specifications.
[14] GAO, Tax Administration: IRS Needs to Strengthen Its Approach for
Evaluating the SRFMI Data-Sharing Pilot Program, [hyperlink,
http://www.gao.gov/products/GAO-09-45] (Washington, D.C.: Nov. 7,
2008) and Transportation Worker Identification Credential: Progress
Made in Enrolling Workers and Activating Credentials but Evaluation
Plan Needed to Help Inform the Implementation of Card Readers,
[hyperlink, http://www.gao.gov/products/GAO-10-43] (Washington, D.C.:
Nov. 18, 2009).
[15] US-VISIT currently applies to a certain group of foreign
nationals—nonimmigrants from countries whose residents are required to
obtain nonimmigrant visas before entering the United States and
residents of certain countries who are exempt from U.S. visa
requirements when they apply for admission to the United States for up
to 90 days for tourism or business purposes under the Visa Waiver
Program. US-VISIT also applies to (1) lawful permanent residents; (2)
Mexican nonimmigrants traveling with a Border Crossing Card, who wish
to remain in the United States longer than 30 days, or who declare
that they intend to travel more than 25 miles into the country from
the border; and (3) Canadians traveling to the United States for
certain specialized reasons. See 8 C.F.R. § 235.1(f).
[16] US-VISIT program documentation now refers to these as
"principles."
[17] Radio frequency technology relies on proximity cards and card
readers. Radio frequency devices read the information contained on the
card when the card is passed near the device. The information can
contain personal identification of the cardholder.
[18] Other Comprehensive Exit projects include modification of IDENT
to collect, validate, and store biometric and biographic data for
travelers exiting the United States; enhancement of IDENT's reporting
capabilities to support the analysis and evaluation of the Air Exit
Pilot results; and recording the departure of certain temporary
agricultural and nonagricultural workers at two Arizona land POEs.
[19] Homeland Security: U.S. Visitor and Immigrant Status Program's
Long-standing Lack of Strategic Direction and Management Controls
Needs to Be Addressed, [hyperlink,
http://www.gao.gov/products/GAO-07-1065] (Washington, D.C.: Aug. 31,
2007).
[20] GAO, Homeland Security: Strategic Solution for US-VISIT Program
Needs to Be Better Defined, Justified, and Coordinated, [hyperlink,
http://www.gao.gov/products/GAO-08-361] (Washington, D.C.: Feb. 29,
2008).
[21] GAO, Visa Waiver Program: Actions Are Needed to Improve
Management of the Expansion Process, and to Assess and Mitigate
Program Risks, [hyperlink, http://www.gao.gov/products/GAO-08-967]
(Washington, D.C.: Sept. 15, 2008).
[22] GAO, Homeland Security: U.S. Visitor and Immigrant Status
Indicator Technology Program Planning and Execution Improvements
Needed, [hyperlink, http://www.gao.gov/products/GAO-09-96]
(Washington, D.C.: Dec. 12, 2008).
[23] GAO, Homeland Security: Key US-VISIT Components at Varying Stages
of Completion, but Integrated and Reliable Schedule Needed,
[hyperlink, http://www.gao.gov/products/GAO-10-13] (Washington, D.C.:
Nov. 19, 2009).
[24] This date was included in the explanatory statement that
accompanied the Department of Homeland Security Appropriations Act,
2009, which was enacted on September 30, 2008.
[25] The pilots were to (1) evaluate identity verification and exit-
recording capabilities when used with existing POE operations and
infrastructure; (2) biometrically and biographically verify the
identity of in-scope travelers departing the United States at the
pilot locations; and (3) record the exit of, and update the IDENT and
ADIS records for, each subject traveler.
[26] The evaluation report stated that visibility into the US-VISIT
traveler status of travelers ages 14 to 18 was limited because of
conflicting TSA and US-VISIT policies. According to a TSA official,
data were collected on these travelers only when they were with in-
scope adults.
[27] These metrics corresponded to the business requirement categories
of data capture, transmission, data linkage, search and match,
reporting, interoperability, and non-technical.
[28] One of the business requirements applied only to the CBP pilot—
that the air exit solution shall operate with existing CBP policies,
processes, and systems.
[29] [hyperlink, http://www.gao.gov/products/GA0-10-13].
[30] This operational requirement is to be able to generate a report
on attempts of unauthorized access or requests of US-VISIT systems or
data. According to the program office, this requirement was not tested
because the pilot was scoped to only allow certain individuals to log
into the system. In our view, this does not alleviate the need to test
whether persons other than those allowed attempted to access the
systems or data.
[31] [hyperlink, http://www.gao.gov/products/GA0-09-45] and
[hyperlink, http://www.gao.gov/products/GAO-10-43].
[32] 73 Fed. Reg. 22065 (Apr. 24, 2008).
[33] These airports were: 1) Baltimore-Washington Thurgood Marshall
International; 2) Chicago O'Hare International; 3) Denver
International, 4) Dallas Fort Worth International, 5) San Juan Luis
Munoz Marin International, 6) Detroit Metropolitan Wayne County
(McNamara Terminal), 7) Newark Liberty International, 8) San Francisco
International, 9) Hartsfield-Jackson Atlanta International, 10)
Philadelphia International, 11) Fort Lauderdale/Hollywood
International, and 12) Seattle-Tacoma International.
[34] TSA told us that Atlanta was selected because it had a single
security checkpoint for international travelers, resulting in a 100
percent probability of capturing exit data from travelers subject to
US-VISIT who originated in Atlanta. In contrast, Chicago had two
checkpoints, thus providing a 50 percent probability of processing the
exiting international travelers who originated there.
[35] Flights to English-speaking countries, or countries with positive
relations with the United States, are examples of characteristics that
might influence how quickly travelers move through the data collection
process. CBP documentation did state that flights to Canada would be
excluded because they primarily consisted of travelers not subject to
US-VISIT processing.
[36] GAO, Homeland Security: Key US-VISIT Components at Varying Stages
of Completion, but Integrated and Reliable Schedule Needed,
[hyperlink, http://www.gao.gov/products/GAO-10-13] (Washington, D.C.:
Nov. 19, 2009).
[37] Consolidated Security, Disaster Assistance, and Continuing
Appropriations Act, 2009, Pub. L. No. 110-329, 122 Stat. 3574, 3668-70
(Sept. 30, 2008).
[38] See Explanatory Statement, 154 Cong. Rec. H9427, H9802 (daily ed.
Sept. 24, 2008) and the Consolidated Security, Disaster Assistance,
and Continuing Appropriations Act, 2009, Pub. L. No. 110-329, Div. D,
Department of Homeland Security Appropriations Act, 2009 (Sept. 30,
2008). Section 4 of Pub. L. No. 110-329 provides that the Explanatory
Statement shall have the same effect with respect to the allocation of
funds and the implementation of the act as if it were a joint
explanatory statement of a committee of conference.
[39] H.R. Rep. No. 110-862, at 103 (2008).
[40] "Satisfied" means that the report met all aspects of the
direction or expectation. "Partially satisfied" means that the report
met some, but not all, aspects of the direction or expectation. "Not
satisfied" means that the report did not satisfy any aspects of the
direction or expectation.
[41] The air exit pilots evaluation framework consisted of metrics,
observations, and cost elements; associated data sources; and other
data collection and analysis specifications.
[42] We did not verify that all raw data and analyses supported the
aggregate data that we reviewed.
[43] We did not verify whether the planned tests or test results were
sufficient to demonstrate satisfaction of pilot requirements.
[44] GAO, Tax Administration: IRS Needs to Strengthen Its Approach for
Evaluating the SRFMI Data-Sharing Pilot Program, [hyperlink,
http://www.gao.gov/products/GAO-09-45] (Washington, D.C.: Nov. 7,
2008) and Transportation Worker Identification Credential: Progress
Made in Enrolling Workers and Activating Credentials but Evaluation
Plan Needed to Help Inform the Implementation of Card Readers, GAO-10-
43 (Washington, D.C.: Nov. 18, 2009).
[45] Travelers who remain in the country beyond their authorized
period of stay are referred to as "overstays."
[46] GA0, Homeland Security: Key US-VISIT Components at Varying Stages
of Completion, but Integrated and Reliable Schedule Needed,
[hyperlink, http://www.gao.gov/products/GAO-10-13] (Washington, D.C.:
Nov. 19, 2009).
[47] Other Comprehensive Exit projects include the modification of
IDENT to collect, validate, and store biometric and biographic data
for travelers exiting the United States; enhancement of IDENT's
reporting capabilities to support the analysis and evaluation of the
Air Exit Pilot results; and recording the departure of certain
temporary agricultural and nonagricultural workers at two Arizona land
POEs.
[48] The evaluation report stated that visibility into the US-VISIT
traveler status of travelers ages 14 to 18 was limited because of
conflicting TSA and US-VISIT policies. According to a TSA official,
data were collected on these travelers only when they were with in-
scope adults.
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