U.S. Customs Service: Office of Investigations Case Management Problems
(Letter Report, 07/20/1999, GAO/GGD-99-121).

GAO reviewed whether the U.S. Customs Service Office of Investigations
follows its case management policies and procedures. GAO visited the
Special Agent in Charge Offices in New York and Chicago and found that
many agents were not entering statistics into the electronic management
database as required. Moreover, many first-line supervisors were not
providing evidence of investigative case file quarterly reviews. Most
agents were not completing opening reports of investigations within 10
days after an investigation was initiated, as required. Also, some
investigative files that GAO requested could not be located. Since 1995,
Customs' Office of Internal Affairs, Management Inspection Division has
repeatedly reported these same findings. However, the Division routinely
did not summarize the case management problems or recommend ways for the
Office of Investigations to correct the problems.

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

 REPORTNUM:  GGD-99-121
     TITLE:  U.S. Customs Service: Office of Investigations Case
	     Management Problems
      DATE:  07/20/1999
   SUBJECT:  Internal controls
	     Reporting requirements
	     Customs administration
	     Data bases
	     Federal records management

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    United States General Accounting Office GAO               Report
    to the Chairman, Subcommittee on Trade, Committee on Ways and
    Means, House of Representatives July 1999         U.S. CUSTOMS
    SERVICE Office of Investigations Case Management Problems Continue
    GAO/GGD-99-121 United States General Accounting Office
    General Government Division Washington, D.C.  20548 B-280367 July
    20, 1999 The Honorable Philip M. Crane Chairman, Subcommittee on
    Trade Committee on Ways and Means House of Representatives Dear
    Mr. Chairman: This report responds to your request of January 15,
    1998, that we determine whether the U.S. Customs Service's Office
    of Investigations (OI) follows its case management policies and
    procedures.  Specifically, for the two Special Agent in Charge
    (SAC) offices we visited in New York and Chicago, we determined
    whether *   agents were entering statistics in the case management
    database; *  first-line supervisors were reviewing investigative
    case files quarterly; *  agents completed reports documenting
    their opening reports of investigation on time; and *  the two SAC
    offices were maintaining and storing their case files
    appropriately. In the New York and Chicago SAC offices, many
    agents were not entering Results in Brief
    statistics, such as arrests, seizures, and convictions, in the
    electronic management database as required by Customs' policies
    and procedures. Further, many first-line supervisors were not
    providing evidence of investigative case file quarterly reviews.
    Most agents were not completing opening reports of investigation
    within 10 days after an investigation was initiated as required.
    Also, some investigative case files that we requested could not be
    located. Since 1995, Customs' Office of Internal Affairs,
    Management Inspection Division (MID) reported these same findings
    repeatedly in their reports examining individual offices.
    However, MID did not routinely summarize the case management
    problems or make recommendations on how OI should correct the
    problems agencywide and prevent them from happening in the future.
    We make a recommendation near the end of this report to address
    these concerns. Page 1                        GAO/GGD-99-121 OI
    Case Management Problems Continue B-280367 Customs' mission is to
    ensure that persons and goods entering and exiting Background
    the United States do so in accordance with U.S. laws and
    regulations.  In 1999, Customs was allocated over $2.1 billion in
    support of over 17,000 full- time positions.  Of the Custom's
    budget, OI was allocated over $628 million in support of about
    4,800 full-time positions.  OI is responsible for investigations
    and intelligence and has shared responsibility with the Office of
    Field Operations for antismuggling activities.  Most Customs
    employees work in the area of either field operations (64 percent)
    or investigations (23 percent).  OI's organizational structure
    includes 20 SAC offices, more than 100 smaller offices, 14 air
    branches, various marine interdiction units, and 23 foreign attach
    offices. OI's primary investigative programs include trade fraud,
    narcotics, outbound and strategic trade, financial and money
    laundering, and child pornography.  Internal case management
    policies and procedures provide the framework upon which these
    enforcement activities are to be built. MID's mission is to
    provide Customs' executive management with the independent
    information necessary to gauge the effectiveness and efficiency of
    managers, operations, priority programs, and special interest
    initiatives.  Management inspections are to accomplish this
    mission through (1) research and analysis of information, (2)
    comprehensive inspections, and (3) recommendations and assistance
    in correcting problems. Our review focused on the management of
    the investigative case files Objectives, Scope, and closed during
    the past 3 fiscal years-1996, 1997, and 1998.1  Using a data
    Methodology                      collection instrument, we
    compiled information from the hard-copy files to determine whether
    they contained the appropriate information, including evidence of
    supervisory reviews.  We also interviewed key officials and
    reviewed information from the electronic case management database,
    which is a part of the Treasury Enforcement Communications System.
    We reviewed a random sample of hard-copy investigative case files
    at the SAC offices located in New York and Chicago.  We selected
    these two offices because they were two of OI's largest field
    offices.  We also reviewed excerpts on case management from MID
    reports on offices nationwide that were issued between October
    1995 and September 1998.  Our objectives, scope, and methodology
    are discussed in more detail in appendix I. We performed our work
    between June 1998 and June 1999 in accordance with generally
    accepted government auditing standards.  We requested 1We reviewed
    case files closed between October 1, 1995, and July 14, 1998. Page
    2                                                   GAO/GGD-99-121
    OI Case Management Problems Continue B-280367 comments on a draft
    of this report from the Secretary of the Treasury or his
    designees.  On July 13, 1999, Customs' Director, Office of
    Planning, forwarded to us written responses to this letter from
    Customs' Assistant Commissioners for (1) OI and (2) the Office of
    Internal Affairs.  Their comments are discussed near the end of
    this letter and reprinted in appendix II. Case enforcement
    statistics include initial and final statistics, which are Agents
    Did Not Enter               activities and incidents that are
    attributable to a specific case.  Initial Statistics Into the Case
    statistics are to include arrests, indictments, seizures, and
    penalties issued. Final statistics are to provide the disposition
    of initial statistics.  Final Management Database statistics are
    to include convictions; court-imposed fines; acquittals;
    dismissals; nolle pros;2 forfeited, destroyed, or returned
    seizures; and collected penalties or duties. According to Customs'
    policies and procedures, case agents are responsible for the
    accurate and timely entry of both the initial and final statistics
    in the case management database.  First-line supervisors are to
    ensure that the personnel they supervise adhere to the policy on
    statistics through case file reviews.  The electronic case
    management system was designed to prohibit agents from closing
    cases until final enforcement statistics were reported for all
    initial enforcement statistics.  However, a Customs' official told
    us that agents sometimes circumvented the system and closed cases
    without entering the required final statistics. Of the 81 randomly
    selected closed cases we reviewed in New York and Chicago, 20
    should have had statistics reported in the case management
    database.  As shown in table 1, 19 cases were missing either
    initial or final statistics or both initial and final statistics,
    and only 1 case had complete initial and final statistics.  On the
    basis of our sample data, we estimate that for the combined cases
    closed in New York and Chicago from 1996 to 1998, the statistics
    were incomplete in at least 80 percent of the cases that should
    have had statistics reported in the electronic case management
    database.  In other words, we estimate that for the combined cases
    closed in New York and Chicago from 1996 to 1998, the statistics
    were incomplete in at least 519 of the approximate 649 cases that
    should have had statistics reported in the electronic case
    management database.3 2For the purposes of the electronic case
    management system, nolle pros is a final legal disposition for a
    defendant where the prosecutor has, at the government's request,
    decided to discontinue the prosecution. 3A description of our
    estimation procedures and the confidence intervals are found in
    appendix I. Page 3
    GAO/GGD-99-121 OI Case Management Problems Continue B-280367 Table
    1: Number of Cases With
    Number of cases Incomplete Statistics
    That should
    Missing have had
    both initial         With statistics Missing initial
    Missing final          and final complete SAC office
    reported statistics only statistics only                statistics
    statistics New York                         9                  1
    6                 2            0 Chicago                        11
    0                    7                 3            1 Total
    20                   1                   13                 5
    1 Source:  GAO review of hard-copy case files and the electronic
    case management database. We found that 19 cases had incomplete
    statistics when we checked the hard-copy files to the electronic
    case management database.  Arrests and their final dispositions
    were missing from the case management database. From the
    information entered into the electronic case management database,
    it is impossible to determine (1) that 4 arrests were made; (2)
    whether 12 arrests and 1 indictment resulted in convictions,
    court-imposed fines, acquittals, dismissals, or nolle pros; and
    (3) that 3 arrests were made and what their final dispositions
    were (see table 2). Table 2:  Arrests and Their Final
    Number of arrests Dispositions Were Missing From the
    Missing from final Electronic Case Management Database
    statistics only Missing          (e.g., convictions,
    Missing from from initial            acquittals, and         both
    initial and SAC office                            statistics only
    dismissals)           final statistics New York
    4                            7                      0 Chicago
    0                           5a                      3 Total
    4                           12                      3 aThe final
    disposition for one indictment was also missing. Source: GAO
    review of hard-copy case files and the electronic case management
    database. Additionally, for these same 19 cases, it is impossible
    to determine from the electronic case management database whether
    the following seized items were forfeited, destroyed, or returned:
    17 vehicles; about $1.5 million; over 3 pounds of heroin; 5,070
    pounds of cocaine; a semiautomatic weapon; a paging device; over
    250,000 crack pipes; over 800 pounds of marijuana; archival
    pottery; and plastic resin valued at over $150,000. Further, it is
    impossible to determine from the electronic case management
    database that the following items were seized and whether they
    were forfeited, destroyed, or returned:  office files; one
    automobile; over $50,000 in cash; almost 1 pound of heroin;  pound
    of cocaine, and 1,500 pounds of marijuana.  (See table 3.) Page 4
    GAO/GGD-99-121 OI Case Management Problems Continue B-280367 Table
    3:  Seized Items and Their Final
    Seizures Dispositions Were Missing From the
    Missing from both Electronic Case Management Database
    Missing from final                             initial and final
    Missing                               statistics only (e.g.,
    statistics (e.g., from initial                          forfeited,
    destroyed, or forfeited, destroyed, SAC office
    statistics only                       returned)
    or returned) New York                         None
    3 cars                                         Office files
    $1,489,335                                     1 car 3.25 pounds
    of heroin 5,070 pounds of cocaine 1 semiautomatic weapon Paging
    device 253,800 crack pipes Chicago                          None
    0.4 pounds of heroin                           $50,098 868 pounds
    of                                  0.8 pounds of heroin marijuana
    0.5 pounds of cocaine 14 cars
    1,500 pounds of Archival pottery
    marijuana 109 pounds of plastic resin valued at $151,000 Source:
    GAO review of hard-copy case files and the electronic case
    management database. According to Customs' polices and procedures,
    the accuracy of the information contained in the electronic case
    management database is critical.  Reports that incorporate case
    enforcement statistics include Customs' Annual and Strategic
    Plans, the Annual Accountability Report, the annual budget, and
    other reports prepared in response to requirements of the
    Government Performance and Results Act of 1993. The Assistant
    Commissioner for Investigations told us that enforcement
    statistics, such as the number of arrests, persons indicted,
    convictions, and seizures; the amount of fines and penalties
    collected; and the quantity of narcotics seized, are used
    collectively to evaluate office performance.  As a basis for
    evaluating the effectiveness of individual offices, a system for
    defining the magnitude of threat, or potential for enforcement
    results, that exists for each office has been developed.4  OI
    management believes that informed decisions pertaining to planning
    and resource allocation and day- to-day decisions can be made more
    efficiently when all factors, including program priorities, threat
    levels, and performance, are considered. 4Enforcement statistics
    play a major role in defining the magnitude of threat that exists
    for each OI office. Page 5
    GAO/GGD-99-121 OI Case Management Problems Continue B-280367
    Individual case statistics are used by local managers to supervise
    cases and to assess progress.  Summary statistics are used to
    conduct overall program and productivity analyses. OI management
    has proposed the following actions to improve the accuracy of
    statistics in the case management database: *  management
    oversight reviews, *  program changes in the database to make it
    more difficult to close cases without final statistics, *
    development of a new automated case review function, and *
    additional staff training on case management. According to
    Customs' policies and procedures, first-line supervisors must
    Supervisors Did Not                       review open
    investigative cases at least every 3 months.  To document Provide
    Evidence of                       their reviews, first-line
    supervisors are to sign and date the hard-copy case files and
    provide narrative comments, recommendations, and/or Case File
    Reviews                         investigative objectives that will
    provide the agent with clear guidance and direction regarding how
    best to proceed with the investigation. Of the 81 cases that we
    reviewed, 36 were open for more than 90 days. About one-third of
    the cases that were open for more than 90 days lacked any evidence
    of supervisory review.  (See table 4.)  On the basis of the 81
    cases, we estimate that at least 20 percent of the combined cases
    in New York and Chicago closed between fiscal years 1996 and 1998
    lacked evidence of supervisory review. Table 4: Number of Cases
    That Lacked
    Cases open for more than 90 days Evidence of Supervisory Review
    Lacking    Contained evidence of evidence of Total cases
    Number supervisory supervisory SAC office
    reviewed       of cases        review       review New York
    34         13              4              9 Chicago
    47         23              9          14 Total
    81         36             13          23 Source: GAO review of
    hard-copy case files. In the remaining two-thirds of the cases
    open for more than 90 days, most (43 of 55) of the supervisory
    reviews that occurred were not conducted every 3 months as
    required by OI policy.  (See table 5.)  When supervisors reviewed
    cases open for at least 90 days, we estimate that at least 69
    percent of the reviews were not performed in a timely manner in
    the Page 6                             GAO/GGD-99-121 OI Case
    Management Problems Continue B-280367 combined cases for New York
    and Chicago during the time frame we reviewed. Table 5: Number of
    Supervisory
    Supervisory reviews Reviews Not Completed in a Timely
    Conducted in a timely manner? Manner
    SAC office
    Total                                  No
    Yes New York
    28                                 22
    6 Chicago
    27                                 21
    6 Total
    55                                 43
    12 Source:  GAO review of hard-copy case files. According to
    Customs' policies and procedures, it is the responsibility of the
    first-line supervisor to ensure that enforcement personnel under
    their supervision are conducting investigations in compliance with
    applicable policies and procedures.  The first-line supervisor is
    in the best position to monitor agent activities to ensure
    adherence to policies and procedures. A report of investigation is
    used to document investigative activities and Agents Did Not
    results of an investigation and to send and report on collateral
    requests to Complete Opening                          and from
    other offices.  According to Customs' policies and procedures,
    agents are to complete opening reports of investigation within 10
    calendar Reports of                                days after an
    investigation is initiated.5 Investigation on Time In the 81 cases
    that we reviewed, 64 of the opening reports of investigation were
    not prepared on time.  (See table 6.)  The median time period to
    complete the opening reports of investigation for the cases that
    we reviewed was 39 days.  Of the combined cases closed in New York
    and Chicago from fiscal years 1996 to 1998, we estimate that at
    least 70 percent of the opening reports of investigation were not
    prepared on time. Table 6: Number of Reports of
    Number of opening reports of investigation Investigation Not
    Prepared in a Timely
    In the cases                    Not prepared
    Prepared Manner                                    SAC office
    we reviewed                               on time
    on time New York
    34                               26                          8
    Chicago
    47                               38                          9
    Total
    81                               64                        17
    Source:  GAO review of hard-copy case files and the electronic
    case management database. 5Customs' policies and procedures also
    note that time constraints imposed upon enforcement personnel by
    investigative activities could adversely impact agents' ability to
    write reports in a timely manner.  It is the primary
    responsibility of the first-line supervisor to ensure that this
    balance is properly maintained. Page 7
    GAO/GGD-99-121 OI Case Management Problems Continue B-280367
    According to Customs' policies and procedures, investigation
    activities are to be properly documented in reports of
    investigation while the event is clear in the mind of the writer.
    Well-written reports are critical to the success of
    investigations.  If investigations are not properly documented, it
    is likely to be more difficult to prosecute cases successfully.
    According to Customs' policies and procedures, case files should
    be kept New York SAC Did Not for 5 years after each case has been
    closed.  Subsequent to the 5-year Maintain Files
    period, the files should be transferred to the Federal Records
    Center, where they should be retained for a period of 25 years.
    Appropriately While Customs provided all of the case files that we
    asked to review in Chicago, it was unable to locate seven cases we
    initially requested in New York.  Of the seven case files that
    could not be located, four involved drug smuggling; two involved
    fraud; and one involved munitions control.  Table 7 shows the
    other information that we could determine from the case file
    numbers of the lost case files. Table 7: Information on the Seven
    Case Files That Could Not Be Located in New York Case
    Investigative          Investigative            Source of
    Year case    Location (SAC) SAC office        number     category
    subcategory              origin                     opened
    case opened New York            (1)      Drug smuggling
    Cocaine                  Inspection and control      1996
    San Juan (2)      Drug smuggling         Marijuana
    Inspection and control      1997        Atlanta (3)      Drug
    smuggling         Heroin                   State/Local enforcement
    1994        New York (4)      Drug smuggling         Heroin
    OI                          1995        New York (5)      Fraud
    Quota (Textiles-         OI                          1993
    New York Transhipment) (6)      Fraud
    Intellectual property    Other Customs               1995
    New York rights                   component (7)      Munitions
    control      Other                    OI
    1994        New York Source:  GAO review of assigned case file
    numbers. According to Customs' policies and procedures, the proper
    storage of case files is a critical factor in maintaining the
    integrity of cases and the viability of subsequent actions within
    the criminal justice system.  Any document in the case folder may
    be used as evidence during judicial proceedings.  The contents of
    case files may ultimately be disclosed to the defense.  If the
    contents of the case file have been lost, altered, or otherwise
    handled inappropriately, the entire case may be dismissed. In a
    combined annual report for fiscal years 1994 and 1995, and in Our
    Findings Are                          management inspection and
    follow-up reports on 62 OI offices that were Similar to Those
    completed between fiscal years 1995 and 1998, MID reported case
    Reported by MID Page 8                              GAO/GGD-99-121
    OI Case Management Problems Continue B-280367 management problems
    similar to the ones we identified at the Chicago and New York
    offices. MID found that *  quarterly supervisory reviews were not
    consistently performed or documented, *  case files were missing
    or in disarray, *  reports of investigation were not prepared in a
    timely manner, and *  statistics were missing from the management
    database or were entered inaccurately. In October 1995, MID
    published a combined annual report for fiscal years 1994 and
    1995.6  Regarding OI case management, the report indicated that
    SAC offices were "not complying" with Customs' policies and
    procedures. The report presented the following summary of findings
    from its inspections of five SAC offices, one regional office, and
    six district offices during those 2 years:7 *  Investigative cases
    were not being managed from either an operational or
    administrative perspective. *  Quarterly supervisory case reviews
    were not consistently performed and/or documented. *  Case files
    were incomplete. *  Insufficient and inconsistent supervision
    resulted in erosion of the mission focus and inattention to case
    management, including the equitable distribution of case
    assignments. In the combined annual report, MID also said that the
    case management problems occurred, for the most part, because
    supervisors viewed the case management system as (1) unwieldy and
    (2) duplicative of records and requirements that had been
    automated.  Although MID concluded that OI should focus on the
    problems raised by chronic noncompliance, it made no formal
    recommendations to OI regarding the case management system and
    OI's oversight of SAC compliance with requirements. Between fiscal
    years 1995 and 1998, MID issued 62 management inspection reports
    on various OI offices around the world.  Our review of sections of
    these reports showed that MID found case management problems at 35
    of the offices, which are similar to our findings. 6MID officials
    told us that they also conducted a trend analysis of their 1996
    management inspections; however, they were unable to locate a copy
    of the report. 7On October 1, 1995, Customs closed its 7 regional
    and 42 district offices and replaced them with 20 Customs
    Management Centers. Page 9
    GAO/GGD-99-121 OI Case Management Problems Continue B-280367 *
    Case files lacked quarterly supervisory review in 31 offices. *
    Case files were missing or in disarray or file documents were
    missing in seven offices. *  Reports of investigation were not
    timely in 14 offices. *  Problems with accurate and timely
    statistics existed in eight offices. Generally, MID attributed the
    case management problems to agents and first- and second-line
    supervisors.  In several of the previously mentioned reports, MID
    concluded the following: *  The proper compilation of all
    documents that constitute a complete case file record is essential
    in anticipation of legal action that may result from any
    investigation. *  The failure to follow OI policy could result in
    a number of problems, including the possibility of inadmissibility
    or challenge by defense attorneys when cases are presented in
    criminal or civil proceedings. *  Inclusion of inappropriate
    enforcement statistics adversely affected operational and
    managerial assessments on the local and national level. *
    Incomplete enforcement statistics had a negative impact on
    productivity ratios. *  The overall progress of (1) an individual
    investigation or (2) an investigative program could not be
    assessed because of case management problems. *  Incomplete
    investigative case files and statistical information might
    adversely impact staffing and budget considerations. In reports
    issued to specific SACs, MID recommended that they improve
    supervisory reviews, ensure compliance with Customs' policies and
    procedures, and improve the timeliness and completeness of reports
    of investigation. When combined with MID reports since 1994, our
    findings at the Chicago Conclusions      and New York SAC offices
    suggest that case management problems have existed in OI for some
    time.  Although we did not determine whether the problems at the
    two offices adversely affected the outcome of investigations, we
    agree with MID's conclusions regarding the potential harm that
    inattention to these details could cause. We believe that MID is
    uniquely situated to identify systemic problems occurring across
    individual SAC offices or in ports of entry, strategic trade
    centers, or other Customs units.  A formal summary of the results
    of MID inspections could provide a valuable tool to help heads of
    the major offices Page 10                      GAO/GGD-99-121 OI
    Case Management Problems Continue B-280367 and divisions within
    Customs ensure that their individual units are performing as they
    should. We recommend that the Commissioner of Customs direct MID
    to routinely Recommendation                 summarize its findings
    relating to major organizational units within Customs to identify
    systemic problems and make appropriate recommendations to correct
    them. In commenting for the Department of the Treasury, Customs'
    Director, Agency Comments and Office of Planning, generally agreed
    with our recommendation and said Our Evaluation
    that Customs has taken steps to address our findings. OI agreed
    with our findings, conclusions, and recommendations.  In response
    to our finding that enforcement statistics were missing from the
    case management database, OI said that it had taken or plans to
    take the following actions: *  develop and implement a computer-
    generated procedure for recording the final disposition of
    seizures in the OI case management system; *  direct all field
    offices to ensure that all initial and final statistics are
    included in the case management system for all cases closed
    between fiscal years 1996 and 1998; *  establish a new management
    oversight position, which will report directly to the Assistant
    Commissioner, in an effort to ensure greater accountability from
    field managers; *  revise the case management policies and
    procedures; *  complete the development of a "data warehouse" by
    the end of the year; and *  increase the emphasis on case
    management procedures in future training programs. In response to
    our finding that supervisors did not provide evidence of case file
    reviews, OI said it plans to automate a procedure in the fall that
    would automatically notify supervisors every 90 days of their need
    to review and approve case files as required.  OI also plans to
    automate other aspects of case management, including the form that
    supervisors are currently required to use to document supervisory
    reviews.  These actions appear to be good first steps to correct
    the problems that we noted. In its comments, OI also said that the
    importance of some of the discrepancies that we noted was
    overstated.  Although OI agreed that the data were missing, it
    said that the lack of this information in the case management
    database did not affect the accuracy of the statistics it used
    Page 11                        GAO/GGD-99-121 OI Case Management
    Problems Continue B-280367 for internal planning, productivity,
    and resource allocation decisions.  We did not determine as part
    of this review whether the incomplete statistics affected any OI
    planning or resource allocation decisions.  However, to the extent
    OI relies on field-reported data to plan operations, assess
    performance, and make resource allocation decisions, we believe it
    should have complete, accurate data.  We are encouraged by the
    steps OI outlined to improve these data. Customs' Office of
    Internal Affairs said that MID has initiated a self- inspection
    program, which should provide a comprehensive mechanism for
    management oversight of programs and processes, including case
    management.  According to the Office of Internal Affairs, MID
    plans to report the findings of the first self inspection to
    Customs executive management by October 1, 1999.  (See app. II.)
    We are providing copies of this report to the Honorable Sander M.
    Levin, Ranking Minority Member of the House Subcommittee on Trade;
    the Honorable Lawrence Summers, the Secretary of the Treasury; the
    Honorable Raymond W. Kelly, Commissioner of Customs; and other
    interested parties.  Copies also will be made available to others
    upon request. The major contributors to this report are
    acknowledged in appendix III.  If you or your staff have any
    questions about the information in this report, please contact me
    on (202) 512-8777 or Brenda Bridges, Assistant Director, on (202)
    512-5081. Sincerely yours, Norman J. Rabkin Director,
    Administration of Justice Issues Page 12
    GAO/GGD-99-121 OI Case Management Problems Continue Page 13
    GAO/GGD-99-121 OI Case Management Problems Continue Contents 1
    Letter 16 Appendix I Objectives, Scope, and Methodology 18
    Appendix II               GAO Comments
    23 Comments From the U.S. Customs Service 24 Appendix III GAO
    Contacts and Staff Acknowledgments Table 1: Number of Cases With
    Incomplete Statistics                         4 Tables
    Table 2:  Arrests and Their Final Dispositions Were
    4 Missing From the Electronic Case Management Database Table 3:
    Seized Items and Their Final Dispositions Were
    5 Missing From the Electronic Case Management Database Table 4:
    Number of Cases That Lacked Evidence of
    6 Supervisory Review Table 5: Number of Supervisory Reviews Not
    Completed                        7 in a Timely Manner Table 6:
    Number of Reports of Investigation Not Prepared
    7 in a Timely Manner Table 7: Information on the Seven Case Files
    That Could                     8 Not Be Located in New York Page
    14                    GAO/GGD-99-121 OI Case Management Problems
    Continue Contents Abbreviations DCI         Data Collection
    Instrument MID         Management Inspection Division OI
    Office of Investigations SAC         Special Agent in Charge Page
    15                    GAO/GGD-99-121 OI Case Management Problems
    Continue Appendix I Objectives, Scope, and Methodology Our overall
    objective was to review Customs' Office of Investigation (OI) case
    management process.  Specifically, we sought to identify whether
    OI was following its case management policies and procedures.  To
    conduct the investigative case file reviews, we selected separate
    random samples of case files closed from October 1, 1995, to July
    14, 1998, in the New York and Chicago Special Agent in Charge
    (SAC) offices.  In New York, we drew a random sample of 34 cases
    from a population of 1,443 cases.  In Chicago, we drew a sample of
    47 cases from a population of 1,143 cases.  In total, we reviewed
    81 case files in the hard-copy form. To conduct the file reviews,
    we developed a data collection instrument (DCI) to measure whether
    Customs was following its own case management policies and
    procedures.  We reviewed the hard-copy version of the files in New
    York and Chicago, two of the SAC offices with large numbers of
    cases.1 To minimize nonsampling error in our file reviews, we
    pretested the DCI at the Baltimore SAC.  We also verified 100
    percent of the data entered from our DCI into a database that we
    created. To improve the reliability of our estimates, we combined
    the New York and Chicago cases in our analysis.  We determined,
    however, that the results of the file reviews were similar for
    both locations.  We calculated sampling errors at the 95-percent
    confidence interval.  In the text, when we make estimates in terms
    of noncompliance of "at least `x' percent," we are using the lower
    bound of a one-sided 95-percent confidence interval.  In other
    words, if we drew repeated samples of the same size from the
    population of cases in New York and Chicago, we would expect that
    the statement "at least `x' percent of the cases were not in
    compliance" would be true in at least 95 of 100 samples.  For the
    subpopulation of cases that should have had statistics reported in
    the electronic case management database, we also used simulation
    methods to estimate the standard error of the proportion of cases
    that had missing statistics.  Using the lower bound rather than
    the point estimate provides a more conservative estimate of the
    percentage of cases not in compliance with Customs' policies and
    procedures. In addition, we examined the computer version of the
    case files to determine whether agents were updating statistics in
    the electronic case management database, which is a part of the
    Treasury Enforcement 1Because we were reviewing regulatory audit
    concurrently, we specifically included only larger SAC offices
    that were colocated with a Customs' Office of Regulatory Audit.
    Page 16                                                  GAO/GGD-
    99-121 OI Case Management Problems Continue Appendix I Objectives,
    Scope, and Methodology Communication System.  A Customs official
    verified the information on the statistics that we reported as
    missing from the case management database.  We also interviewed
    several Customs officials about the importance of case management,
    including the use of case enforcement statistics to evaluate what,
    if anything, Customs was doing to improve compliance with its own
    policies and procedures. The second part of this review was to
    determine the role that Customs' Office of Internal Affairs,
    Management Inspection Division (MID), played in monitoring case
    management in OI.  To accomplish this objective, we (1) reviewed
    the combined annual report for fiscal years 1994 and 1995 and
    management inspection and follow-up reports on 62 OI offices
    completed between fiscal years 1995 and 1998 and (2) interviewed
    MID officials who conduct case management reviews.2 2MID officials
    told us that they also conducted a trend analysis of their 1996
    management inspections; however, they were unable to locate a copy
    of the report. Page 17
    GAO/GGD-99-121 OI Case Management Problems Continue Appendix II
    Comments From the U.S. Customs Service Note:  GAO comments
    supplementing those in the report text appear at the end of this
    appendix. Page 18    GAO/GGD-99-121 OI Case Management Problems
    Continue Appendix II Comments From the U.S. Customs Service See
    comment 1. Page 19                       GAO/GGD-99-121 OI Case
    Management Problems Continue Appendix II Comments From the U.S.
    Customs Service See comment 2. Page 20
    GAO/GGD-99-121 OI Case Management Problems Continue Appendix II
    Comments From the U.S. Customs Service Page 21
    GAO/GGD-99-121 OI Case Management Problems Continue Appendix II
    Comments From the U.S. Customs Service Page 22
    GAO/GGD-99-121 OI Case Management Problems Continue Appendix II
    Comments From the U.S. Customs Service The following are GAO's
    comments on the U.S. Customs Service letter dated July 13, 1999.
    1.  As a part of this review, we did not determine whether the
    mission GAO Comments    statistics affected OI's performance
    evaluation process.  However, since the initial seizure data may
    include seized items that are eventually returned to the alleged
    violators rather than forfeited to the government, we believe that
    the final disposition of seizure data would be more accurate than
    the initial seizure data. 2.  Customs written procedures require
    cases such as these to be closed. Page 23
    GAO/GGD-99-121 OI Case Management Problems Continue Appendix III
    GAO Contacts and Staff Acknowledgments Brenda Bridges, (202) 512-
    5081 GAO Contacts Charity J. Goodman Acknowledgments    Carolyn S.
    Ikeda Ronald J. Salo Barry J. Seltser Sidney H. Schwartz Rebecca
    Shea Jan B. Montgomery Page 24                   GAO/GGD-99-121 OI
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