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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