Customs Service: Information on the Design of the Self-Inspection Program
(Letter Report, 06/23/2000, GAO/GGD-00-151).

Pursuant to a congressional request, GAO reviewed the design and
implementation of the Customs Service's Self-Inspection Program (SIP),
focusing on: (1) SIP's principal features; (2) the basis for Customs'
design for SIP; (3) how SIP differs from Customs' previous management
inspection program; and (4) SIP design issues identified by Customs to
date and what Customs is doing to respond to them.

GAO noted that: (1) Customs' SIP provides a mechanism for management
oversight of programs and processes that is intended to build
accountability and foster integrity throughout the Customs Service; (2)
under SIP, all Customs supervisors and managers are responsible for
conducting a self-inspection every 6 months of the activities they
oversee, using uniform self-inspection worksheets that are designed to
evaluate financial vulnerability and corruption, mission performance and
resource utilization, and internal/external relationships; (3) in
designing SIP, Customs reviewed literature on program design and
contacted several organizations to learn about their programs; (4) from
this research, specific features were selected: (a) ownership of the
program at all levels; (b) scope that covers operational and
administrative areas; (c) use of an independent body to validate
self-assessments; (d) use of uniform worksheets that contain questions
about essential control points for managers; (e) funneling of results up
the chain of command; and (f) performance of self-inspections according
to a set schedule; (5) under Customs' previous management inspection
program, Management Inspections Division (MID) personnel were to perform
a review of each administrative and operational area of an activity
about once every 5 years; (6) these reviews took MID about 2 to 3 weeks
to complete at each location; (7) under SIP, all supervisors and
managers are to inspect, assess, and monitor their own activities every
6 months; (8) MID's independent reviews are to be less comprehensive
than those performed formerly and are expected to take about 5 days; (9)
based on the first SIP cycle, a major program design problem consisted
of confusing worksheet questions and directions; (10) to address the
problem, Customs revised the worksheets to include: (a) specific
directions about who should complete them; (b) detailed sampling
methodology and instructions; (c) citations to references for most
questions; and (d) reworded questions designed to be more specific and
less confusing; (11) two other program design issues have emerged: (a)
the lack of an automated system to analyze SIP results, which makes it
difficult to identify national trends or to track whether corrective
actions have been taken; and (b) the degree of discretion allowed for
offices to perform their self-inspections; and (12) the Assistant
Commissioner for the Office of Field Operations decided to complete half
the self-inspection worksheets every 6 months so that each worksheet
will be completed on a yearly basis.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-00-151
     TITLE:  Customs Service: Information on the Design of the
	     Self-Inspection Program
      DATE:  06/23/2000
   SUBJECT:  Internal controls
	     Accountability
	     Productivity in government
	     Performance measures
	     Program evaluation
	     Customs administration
IDENTIFIER:  Customs Service Self-Inspection Program
	     Customs Service Self-Inspection Reporting System

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GAO/GGD-00-151

United States General Accounting Office
GAO

Report to Congressional Committees

June 2000

GAO/GGD-00-151

CUSTOMS SERVICE
Information on the Design of the Self-Inspection

Program

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Contents
Page 121GAO/GGD-00-151 Customs Self-Inspection Program Design
Letter                                                                      1
                                                                             
Appendix I                                                                 14
Example of an Universal
Worksheet
                                                                             
Appendix II                                                                18
Example of an
Operational Worksheet
                                                                             
Appendix III                                                               22
Comments From the
Customs Service
                                                                             
Appendix IV                                                                24
GAO Contacts and Staff
Acknowledgments
                                                                             
Tables                     Table 1: How Customs' SIP Compared               7
                           With Other Self-Inspection Programs
                                                                             

Abbreviations

CMC       Customs Management Center
DEA       Drug Enforcement Administration
MID       Management Inspections Division
NYPD      New York Police Department
OFO       Office of Field Operations
SAIC      Special Agent-in-Charge
SIP       Self-Inspection Program
SIRS      Self-Inspection Reporting System

 B-284954

Page 6GAO/GGD-00-151 Customs Self-Inspection Progr
am Design
     B-284954

     June 23, 2000

The Honorable William V. Roth Jr.
Chairman
Committee on Finance
United States Senate
 
The Honorable Bill Archer
Chairman
Committee on Ways and Means
House of Representatives
 
The Honorable Philip M. Crane
Chairman
Subcommittee on Trade
Committee on Ways and Means
House of Representatives
 
 The Commissioner, U.S. Customs Service,
testified before the Senate Finance Committee in
May 1999 that he had made significant changes to
the Customs Service in an effort to improve
employees' performance and accountability.
Among these changes was the institution of a
Self-Inspection Program (SIP) whereby managers
are to self-assess how well their areas were
carrying out their responsibilities.

     In your October 12, 1999, letter, you
requested that we review the design and
implementation of Customs' SIP.  As agreed with
your offices, we are addressing these issues in
two reports.  This report discusses (1) SIP's
principal features, (2) the basis for Customs'
design for SIP, (3) how SIP differs from Customs'
previous management inspection program, and (4)
SIP design issues identified by Customs to date
and what Customs is doing to respond to them.

Our work on the second issue-program
implementation-will begin during summer 2000,
after Customs has had a full year to implement and
analyze the program.

Results in Brief
     Customs' SIP provides a mechanism for
management oversight of programs and processes
that is intended to build accountability and
foster integrity throughout the Customs Service.
Under SIP, all Customs supervisors and managers
are responsible for conducting a self-inspection
every 6 months of the activities they oversee,
using uniform self-inspection worksheets that are
designed to evaluate financial vulnerability and
corruption, mission performance and resource
utilization, and internal/external relationships.
Any worksheet that identifies an area in need of
improvement must also include an addendum stating
the corrective actions to be taken and the time
frame for taking them.

In designing SIP, Customs reviewed literature on
program design and contacted several organizations
to learn about their programs.  From this
research, specific features were selected that the
program director thought could work within the
Customs environment.  These features, which were
endorsed by the Commissioner and the executive
staff, included

ï¿½    ownership of the program at all levels,
ï¿½    scope that covers operational and
administrative areas,
ï¿½    use of an independent body to validate self-
assessments,
ï¿½    use of uniform worksheets that contain
questions about essential control points for
managers,
ï¿½    funneling of results up the chain of command,
and
ï¿½    performance of  self-inspections according to
a set schedule.

Under Customs' previous management inspection
program, Management Inspections Division (MID)
personnel were to perform comprehensive reviews of
each administrative and operational area of an
activity (e.g., port of entry) about once every 5
years.  These reviews took MID about 2 to 3 weeks
to complete at each location.  Under SIP, all
supervisors and managers are to inspect, assess,
and monitor their own activities every 6 months,
with MID providing independent verification and
validation on a 2-year cycle.  MID's independent
verification and validation reviews are to be less
comprehensive than those performed formerly and
are expected to take about 5 days compared with 2
or 3 weeks.  MID is to send a follow-up memorandum
between 6 months to a year after the inspection
requesting information on the status of any
corrective actions.

     Based on the first SIP cycle, a major program
design problem identified by Customs consisted of
worksheet questions and directions that were often
perceived by users to be subjective, unclear, and
confusing.  To address these and other issues,
Customs revised the worksheets to include (1)
specific directions about who should complete
them, (2) detailed sampling methodology and
instructions, (3) citations to references for most
questions, and (4) reworded questions designed to
be more specific and less confusing.

Two other program design issues have emerged.  The
first issue, identified by Customs, involves the
lack of an automated system to analyze SIP
results. Without an automated system, which is
under development, Customs has had difficulty
manually tracking voluminous SIP results to
identify national trends or to track whether
corrective actions have been taken. The second
issue, noted in our review, involves the degree of
discretion allowed for offices to perform their
self-inspections. A 6-month interval was expected
to be the standard with some discretion allowed.
The Assistant Commissioner for the Office of Field
Operations (OFO)-the largest Customs office--
decided to exercise this discretion by completing
half the self-inspection worksheets every 6 months
so that each worksheet will be completed on a
yearly basis.  Although a deviation from the
original plan, a yearly self-inspection cycle is
similar to those used by other organizations we
looked at.

It remains to be seen what effect these
developments will have on the program's ability to
promptly identify and resolve problems.  We plan
to follow up on these issues in our second report.

Background
     The U.S. Customs Service has a diverse
mission spanning a large geographic area.
Customs' responsibilities include (1) collecting
revenue from imports and enforcing Customs and
other U.S. laws and regulations; (2) preventing
the smuggling of drugs into the country; and (3)
overseeing export compliance and money-laundering
issues.  Customs' workforce totals almost 20,000
employees at its headquarters, 20 Customs
Management Centers (CMC), 20 Special Agent-in-
Charge (SAIC) offices, 301 U.S. ports of entry, 5
strategic trade centers, and over 25 international
offices.

     Because of Customs' diverse responsibilities
and geographic dispersion, the Commissioner wanted
a new program that placed the primary
responsibility for reviewing operations and
identifying corrective actions on the supervisors
and managers overseeing the activities.  In
addition, the Commissioner wanted MID to
independently verify and validate the self-
inspections and to increase its assessment
frequency from about every 5 years to about every
2 years.

Scope and Methodology
     To identify (1) the principal features of
Customs' SIP, (2) how SIP differs from Customs'
previous management inspection program, and (3)
SIP design issues identified by Customs to date
and what Customs is doing to respond to them, we
interviewed officials from several Customs
activities, including MID, which oversees SIP and
is within the Office of Internal Affairs.  In
addition to MID, we interviewed officials from OFO
and the Office of Investigations because these are
geographically dispersed components with the
responsibility for completing a large number of
self-inspection worksheets.  We also reviewed
relevant agency documents, including reports from
Customs' previous management inspection program.

     To obtain information on the basis for
Customs' design for SIP, we contacted officials
from the organizations that Customs used as
models-the Drug Enforcement Administration (DEA),
New York Police Department (NYPD), and Xerox's
North American Services Group.  We also contacted
officials from Motorola.1  In addition, we
analyzed how Customs' program compares and
contrasts with these organizations' self-
inspection programs.

     Our work was performed at Customs'
headquarters in Washington, D.C., and at field
offices in the Los Angeles and New York areas.  We
performed our work between October 1999 and May
2000 in accordance with generally accepted
government auditing standards.  We requested
comments on a draft of this report from the
Customs Commissioner or his designees.  Customs'
written comments are discussed near the end of
this letter and reprinted in appendix III.

Principal Features of SIP
     Customs' SIP provides a mechanism for
management oversight of programs and processes, to
build accountability and to foster integrity
throughout the Customs Service.  As its name
denotes, SIP emphasizes self-assessment, rather
than an assessment performed by a different
Customs' component.  Under SIP, every supervisor
and manager in Customs is responsible for
conducting a self-inspection of the activities
they oversee, using uniform core area self-
inspection worksheets to evaluate each major area.
The intent of the worksheet is to identify the key
internal control points for evaluation in a
particular program or process.  The worksheets
allow supervisors and managers to assess their
mission/program accomplishments while helping them
to better define their priorities and identify
areas needing improvement.  The focus is to be on

ï¿½    financial vulnerability and corruption,
ï¿½    mission performance and resource utilization,
and
ï¿½    internal/external relationships.

There are two categories of self-inspection
worksheets: universal and operational.  Universal
worksheets pertain to all Customs' offices and
contain questions about administrative areas such
as labor and employee relations, including sick-
leave usage within the activity (see app. I).
Every Customs activity (e.g., port of entry) is
responsible for completing the universal
worksheets.  Operational worksheets contain
questions about controls over specific activities.
For example, SAIC offices would complete a
worksheet on the handling of seized currency (see
app. II).

Customs' activities are to conduct self-
inspections every 6 months, which are referred to
as self-inspection cycles.  During the self-
inspection cycles, supervisors and managers are to
complete worksheets for all areas and activities
under their control.  This involves assessing
their operations and answering questions on the
worksheets as "yes," "no," or "N/A" (not initially
defined, but subsequently changed to "No Activity"
and "Never Applies").  They are to then rate their
areas of responsibility as either "acceptable" or
"needs improvement."

During the first SIP cycle (covering the period of
October 1998 to March 1999), any question on a
worksheet that had a "no" response was to be
automatically rated on the worksheet as "needs
improvement."  Any worksheet that had a "needs
improvement" rating was required to include an
addendum stating the corrective actions to be
taken and the time frame for taking them.

Self-inspection results are to be funneled up the
chain of command.  For example, ports of entry are
to send results to the CMC, which in turn is to
send results to the cognizant assistant
commissioner.  The assistant commissioners are to
report to MID ensuring that self-inspection
worksheets have been completed, are accurate, and
have been analyzed; key issues have been
identified; corrective actions have been
determined; and time frames for completion of
corrective actions have been established.

MID is responsible for overseeing SIP, overseeing
the development of the worksheets, and managing
the program.  MID is also responsible for
publicizing the program implementation strategy
and developing the marketing plan.  In addition,
MID is to conduct independent verifications and
validations of the completed self-inspection
worksheets to ensure that they are correct and
accurate.  MID has developed a schedule to verify
and validate a portion of each major Customs
activity every 2 years and plans to analyze areas
needing improvement in order to identify trends.

MID is to brief the Commissioner on the findings
of its analysis.  A report is then to be issued
and distributed throughout Customs detailing the
results of the self-inspections.  MID is to
conduct a follow-up 6 months to a year after the
inspections to ascertain whether corrective
actions have been taken.

SIP Design and How It Compares With Other Self-
inspection Programs
Customs officials used two steps in designing the
self-inspection program.  First, MID officials
searched for and reviewed literature on program
design.  MID relied heavily on a book entitled
Control Self-Assessment: Making the Choice2 by
Glenda Jordan and published by the Institute of
Internal Auditors for guidance on self-inspection
program features and parameters.

Second, Customs contacted several organizations to
learn about their programs. During 2 weeks in the
fall of 1998, MID contacted 22 organizations: 17
public; 5 private.  Of the 15 organizations that
responded, 5 had self-inspection programs: DEA,
NYPD, Trans-Maritime Administration, the U.S.
Army, and Xerox's North American Services Group.
MID officials visited three of these organizations
that they thought had established viable programs
to learn more about them: DEA, NYPD, and Xerox.

According to the MID Director, SIP incorporated
the features from the literature and these
programs that would work within Customs'
environment and were endorsed by the Commissioner
and the executive staff.  The features borrowed
from DEA's, NYPD's, and Xerox's self-inspection
programs were

ï¿½    ownership at all levels,
ï¿½    scope that covers operational and
administrative areas, and
ï¿½    use of independent body doing checking.

In addition, Customs incorporated the following
features from the DEA and Xerox programs:

ï¿½    uniform worksheets,
ï¿½    self-inspection results to be funneled up the
chain of command, and
ï¿½    self-inspections to be conducted according to
a set schedule.
     Customs' design was somewhat different from
NYPD's program design, however.  It also differed
from Motorola's program design, which Customs did
not consider but which we reviewed for comparison
purposes.  As shown in table 1, one difference was
that NYPD and Motorola allowed their activities
(e.g., NYPD police precinct and Motorola's
accounts payable department) to develop their own
self-inspection worksheets instead of requiring
uniform worksheets for all activities.

Table 1: How Customs' SIP Compared With Other Self-
Inspection Programs
Description  Customs       DEA          NYPD          Xerox         Motorola
Year self-   1999          1994         mid-1980s     1993          1979
inspection
program
started
Uniform      Yes           Yes          No            Yes           No
worksheets?
Are results  Yes           Yes          No            Yes           No
sent up the
chain of
command?
Who conducts Lowest-level  Assistant    Lowest-level  First-line    Determined
self-        supervisor    SAIC         supervisor    manager of    by each
inspection?  or manager                or manager    the process   activity
            who oversees              who oversees
            the activity              the activity
Are self-    Yes, every 6  Yes, every   No            Yes, every    Yes, every
inspections  months        year                      year          year
done on a
set
schedule?
How often    Partial       Every 2      Partial       Every 3-4     Every 3 to 5
verified and review every  years        review every  years         years
validated by 2 years                   3 months
outside
entity?
Are          Yesa          Yes          No             Yes, 2-week  Yes
inspection                                         notice
visits
announced in
advance?
aMID has the authority to do unannounced
inspections but has done so on five occasions and
only regarding the seized property program.
Source: GAO analysis of Customs' and other
organizations' data.

Comparison of SIP With MID's Previous Inspection
Program
SIP differs from Customs' previous management
inspection program.  Prior to SIP, the program
involved an Office of Finance component and a MID
component.  Under the Office of Finance component,
managers were to use checklists to assess their
own internal controls, but these checklists were
not widely implemented, according to Customs
officials.  Under the MID component, MID personnel
were to visit an activity, such as a SAIC office,
about once every 5 years to perform a
comprehensive review that was to examine
administrative and operational aspects of the
activity.  For example, a comprehensive review of
a SAIC office was to include mission performance,
resource utilization, general management,
internal/external relationships, case management,
source development, undercover operations, and
other areas.  In addition, MID was to inspect
these areas at all the Resident Agent in Charge
offices that reported to the SAIC.  According to
the MID Director, these comprehensive reviews
could take about 2 to 3 weeks to perform.

In addition to these comprehensive reviews, MID
also performed spot-checks that focused on limited
areas, such as controls over the imprest fund.
Follow-up reviews were generally conducted 1 to 2
years after comprehensive reviews were performed
to determine whether corrective actions had been
taken.

Under SIP, the responsibility for reviewing the
activities and identifying corrective actions was
placed on the supervisors and managers themselves.
These individuals are to use uniform self-
inspection worksheets to inspect, assess, and
monitor their activities.  MID is to visit major
activity locations at least every 2 years, for
about 5 days, to verify and validate the self-
inspection worksheet results.  MID is to send a
follow-up memo between 6 months to a year after
the inspection to get a status of corrective
actions under way.  While MID is to visit every
major activity location more frequently than under
the previous program, it does not plan to visit
every subordinate location.  However, MID plans to
review the reports for those locations it does not
visit.  For example, under the CMC Tucson, AZ, are
the Ports of San Luis and Lukeville.  MID visited
the CMC Tucson and the Port of San Luis but did
not visit the Port of Lukeville.  However,
according to MID officials, they did conduct a
document review of the Port of Lukeville, which
consisted of obtaining and reviewing the self-
inspection worksheets.

After the first SIP cycle, according to the MID
Director, its visits consisted of reviewing
worksheets, verifying self-inspections, and
providing feedback on how well self-inspections
were performed.  After the second SIP cycle
(covering April 1999 to December 1999), MID's
focus shifted to moving beyond mostly verifying
what managers and supervisors did to actually
conducting additional review work on its own.  MID
reviewers had the option of adding interviews and
surveys of employees working at the activities
under review and were also to conduct an in-depth
review of a selected number of core areas.  In
addition to the mandatory core areas, each
inspection team can, at their discretion, review
additional core areas.  These additional core
areas may be suggestions from administrative
program areas, requests from local and
headquarters management, or random selections from
MID.  The reviews were also to include assessments
of resource utilization and internal and external
relations and were also slated to last 5 days.

Customs Is Addressing Design Issues
According to MID and other Customs officials, a
major design issue with the first SIP cycle was
that worksheets were perceived to have subjective,
unclear, and confusing questions or directions.
For example, a question on the imprest fund
worksheet asked, "Are prohibited items being
purchased?"  The directions on the worksheet
instructed that a "no" response had to have an
addendum attached stating what corrective actions
would be taken and the time frames for taking
them.  In addition, a "no" response would
immediately give the imprest fund worksheet a
"needs improvement" rating.  However, in this
case, the desirable answer was a "no" response.
In addition to the unclear questions, other issues
with the worksheets Customs identified included
unspecified sampling methodologies and a lack of
criteria, such as applicable regulations.

MID extended the second SIP cycle by 3 months to
allow time to revise the worksheets.  The new
worksheets contain many changes, including
directions on who should complete the worksheet,
methodology instructions (e.g., specifying what
size sample to take and how to take it), citations
to references for most questions, and reworded
questions designed to be more specific and less
confusing.  For example, the above "prohibited
item" question was reworded as, "Are only
allowable items purchased?"

Another design issue was that the worksheet
ratings were not meaningful.  During the first SIP
cycle, MID directed that a single "no" answer on a
worksheet would result in a "needs improvement"
rating for the entire worksheet.  This resulted in
officials being unable to determine whether a
"needs improvement" in an area indicated a major
problem or a minor issue.  To make the ratings
more meaningful, MID developed a "qualified"
acceptable rating.  If a top-level manager, such
as a port director, determined that a "needs
improvement" rating is for minor issues, he/she
could amend that rating to a "qualified"
acceptable rating.  However, the official must
explain the reasoning for overriding the original
rating.

Customs CMC and SAIC officials we spoke with
stated that the second SIP cycle was much easier
to implement and less burdensome.  They stated
that the worksheet questions were much easier to
understand and answer and that they liked the
"qualified" acceptable rating.  However, several
of these officials stated that some of these
questions could still be improved.

Two other program design issues have emerged.  The
first issue, identified by Customs, involves the
lack of an automated system to analyze SIP
results.  The second issue, noted in our review,
involves the degree of discretion allowed for
offices to perform their self-inspections.

Without an automated system, which is under
development, it has been difficult for Customs
officials to manually track self-inspection
results to identify national trends or to track
whether corrective actions have been taken.
According to MID and OFO officials, the results
from the first SIP cycle resulted in a large
amount of data, which made manual analysis
difficult.

MID is currently working on an automated system
called the Self-Inspection Reporting System (SIRS)
that should make it easier to analyze data and
track corrective actions.  According to the MID
Director, portions of SIRS should be operational
by Summer 2000, including automating the worksheet
questions.  By January 2001, supervisors and
managers should be able to input the worksheet
data directly into SIRS.  The Customs Office of
Information and Technology officials responsible
for developing SIRS stated that it would not be
fully operational until about December 2001.  The
component that will take the additional time is
intended to allow MID staff to compare SIP data
with MID's inspection data to track whether
corrective actions have been taken.  In the
meantime, OFO-the largest Customs office-has
developed an Excel spreadsheet that may be used to
record and analyze self-inspection results.

During the second SIP cycle the OFO Assistant
Commissioner decided that it was too cumbersome
for each of his activities to complete all of the
worksheets every 6 months.  The Assistant
Commissioner developed a schedule so that about
half the worksheets would be completed every 6
months so that each worksheet would be completed
yearly, rather than every 6 months.  Although a
deviation from the original plan, a yearly self-
inspection cycle is similar to those used by other
organizations we looked at.

According to the MID Director, the program can
permit this discretion.  The Director stated that
assistant commissioners are ultimately held
accountable for the performance of the self-
inspections of their activities, so they were
given the latitude to make the worksheets-and
consequently the self-inspections
themselves-mandatory or discretionary.  South
Pacific and New York CMC-activities within
OFO-officials we spoke with after the second SIP
cycle stated that it was less disruptive to their
operations to complete fewer worksheets.  As of
April 2000, other major Customs offices besides
OFO (e.g., Office of Investigations, Internal
Affairs, Strategic Trade), had completed all of
their worksheets for the second SIP cycle,
according to the MID Director.

It remains to be seen what effects these
developments will have on the program's ability to
promptly identify and resolve problems.  MID
officials noted that SIP is a program under
continuous change and improvement and that such
developments described above are and will continue
to be necessary.  We plan to follow up on these
issues in our second report.

Agency Comments
We requested comments on a draft of this report
from the Commissioner of Customs or his designee.
On May 31, 2000, the Director, Office of Planning,
provided us with written comments, which are
reprinted in appendix III.  The Director said that
most of Customs' concerns had been addressed
through discussions with our audit team during the
assignment.  His letter also provided additional
perspective on the progress of the program.

As agreed with your offices, unless you publicly
announce its contents earlier, we plan no
additional distribution of this report until 10
days from its issue date.  At that time, we will
send copies of this report to Senator Daniel
Patrick Moynihan, Ranking Minority Member of the
Committee on Finance; Representative Charles
Rangel, Ranking Minority Member of the Ways and
Means Committee; and Representative Sander Levin,
Ranking Minority Member of the Ways and Means
Subcommittee on Trade.  In addition, we are
providing copies to the Honorable Lawrence
Summers, the Secretary of the Treasury; the
Honorable Raymond W. Kelly, the Commissioner of
Customs; and other interested parties.  Copies of
this report also will be made available to others
upon request.

The major contributors to this report are
acknowledged in appendix IV.  If you or your staff
have any questions about the information in this
report, please contact me on (202) 512-8777 or
Darryl Dutton, Assistant Director, on (213) 830-
1000.

Richard M. Stana
Associate Director, Administration
 of Justice Issues
_______________________________
1 While Customs did not use Motorola's self-
inspection program as a model, we contacted it
because Motorola testified about its self-
inspection program before the Senate Finance
Committee during the spring of 1999.
2 Control Self-Assessment: Making the Choice,
Glenda S. Jordan, Institute of Internal Auditors,
1995.

Appendix I
Example of an Universal Worksheet
Page 15GAO/GGD-00-151 Customs Self-Inspection Prog
ram Design

Appendix II
Example of an Operational Worksheet
Page 21GAO/GGD-00-151 Customs Self-Inspection Prog
ram Design

Appendix III
Comments From the Customs Service
Page 23GAO/GGD-00-151 Customs Self-Inspection Prog
ram Design

Appendix IV
GAO Contacts and Staff Acknowledgments
Page 24GAO/GGD-00-151 Customs Self-Inspection Prog
ram Design
GAO Contacts
Richard M. Stana, (202) 512-8777
Darryl W. Dutton, (213) 830-1000

Acknowledgments
     Samuel S. Van Wagner
Cheryl L. Gordon

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