CBP Uses Criteria and Documented Procedures to Evaluate and Approve Public-Private Partnership Applications and Administer Programs

		CBP Uses Criteria and Procedures to Approve Public-Private Partnership Applications and Coordinate with Partners

			RSP Application Process

CBP has developed detailed guidance on the RSP application process,  including application timeframes, requirements, and evaluation criteria,  and this guidance is on CBP’s website. Further, the partner agrees to reimburse  CBP for these services within 15 days of billing through a Department of  the Treasury system. After a DAP proposal is submitted and checked for completeness, CBP  and GSA subject matter experts evaluate the proposal against seven  operational and six technical criteria (see table 4 below). Public-Private Partnerships Are Increasing and Provide a Variety of Additional Services and Infrastructure Improvements

		RSP Partnerships are Increasing and Provide a Variety of Additional Services at POEs

As noted previously, as CBP’s authorities to enter into new RSP  agreements expanded to an unlimited number of agreements per year,  and in total, for all types of POEs in 2017, the number of applications that  CBP has selected has also increased. From fiscal year 2013 through  fiscal year 2017 cycle 2, CBP has tentatively selected over 100 partners  for RSP agreements. Tables 6 and 7 provide the amount that partners reimbursed CBP for  overtime services, the total number of overtime hours that CBP officers  worked for each fiscal year from 2014 through 2017, and the total number  of travelers and vehicles that CBP officers inspected during RSP partner  requests for services from fiscal years 2014 through 2017 respectively. DAP Partnerships Provide for Infrastructure Improvements at POEs

Similar to the RSP, the number of DAP partnerships more than doubled in  fiscal year 2017. In fiscal years 2015 and 2016, CBP selected seven DAP  proposals. The donations that partners will provide CBP and GSA, as applicable,  include a variety of POE improvements such as the installation of new  inspection booths and equipment, removal of traffic medians, and new  cold inspection facilities, as well as smaller items such as a high-capacity  perforating machine, which reduces document processing time and  allows CBP officers to focus on more critical operational duties, among  other donations. According to CBP, these 16 donation proposals  combined are intended to support over $150 million in infrastructure  improvements at U.S. POEs. CBP Uses Various Processes to Monitor and Evaluate Its Partnerships, but Could Benefit from Establishing an Evaluation Plan to Assess Overall Program Performance

		CBP Has Various Processes to Monitor and Evaluate the Implementation and Benefits of Its Public- Private Partnership Programs

			RSP Audits, Metric Reports, and Partner Satisfaction Surveys

Given that partner requests for RSP services are predominately for the  purposes of CBP officer overtime, CBP primarily monitors the RSP  through audits. Monitoring and Evaluation of DAP Implementation and Benefits

CBP has guidance that it follows to monitor and evaluate the  implementation of DAP projects, and CBP and its partners use tools such  as implementation roadmaps and other policy documents, such as  standard operating procedures, to administer and monitor the progress of  DAP projects at the POEs. However, the provision requiring that an evaluation plan be  established for the section 559 pilot program was repealed by the Cross- Border Trade Enhancement Act of 2016. As of November 2017, CBP had not decided whether it will use a  performance evaluation plan going forward. We identified some staffing challenges that could  affect CBP’s management and implementation of its RSP and DAP  programs, which roughly doubled in the number of agreements from fiscal  year 2016 to 2017. Such a plan could further integrate evaluation activities into program  management and could better position CBP to assess relative costs,  benefits, and performance trade-offs as CBP expands its RSP and DAP,  and consider the extent to which any future program changes may be  needed. To date, CBP and its partners  have utilized public-private partnerships to help meet an increased  demand for CBP services and infrastructure improvements at POEs, and  agency officials and program partners have generally concurred that the  RSP and DAP have been effective in helping to bridge CBP resource  gaps and improve partner operations. Recommendation for Executive Action

The CBP Commissioner should develop and implement an evaluation  plan to be used to assess the overall performance of the RSP and DAP,  which could include, among other things, measurable objectives,  performance criteria, evaluation methodologies, and data collection plans  to inform future program decisions. Specifically, DHS stated that CBP will develop  and implement a plan to assess the overall performance of the RSP and  DAP to inform future program decisions. Appendix I: Details of U.S. Customs and Border Protection Reimbursable Services Program Agreement Memoranda of Understanding

Since 2013, U.S. Customs and Border Protection (CBP) has entered into  public-private partnerships with private sector or government entities  under its Reimbursable Services Program (RSP) to cover CBP’s cost of  providing certain services at U.S. ports of entry (POE) upon the request of  partners. Fiscal year 2016 partners:  1. Port of Galveston  5.
Why GAO Did This Study

International trade and travel to the United States is increasing. On a typical day in fiscal year 2016, CBP officers inspected nearly 1.1 million passengers and pedestrians and over 74,000 truck, rail, and sea containers at 328 U.S. land, sea, and air ports of entry, according to CBP. To help meet the increased demand for these types of CBP services, since 2013, CBP has entered into public-private partnerships under RSP and DAP. The RSP allows partners to reimburse CBP for providing services that exceed CBP's normal operations, such as paying overtime for CBP personnel that provide services at ports of entry outside normal business hours. The DAP enables partners to donate property or provide funding for port of entry infrastructure improvements.
The Cross-Border Trade Enhancement Act of 2016 included a provision for GAO to review the RSP and DAP. This report examines: (1) how CBP approves and administers RSP and DAP agreements, (2) the status of RSP and DAP agreements, including the purposes for which CBP has used funds and donations, and (3) the extent to which CBP monitors and evaluates program implementation. GAO reviewed partnership agreements and data on program usage. GAO also interviewed CBP and partner officials at 11 ports of entry selected based on a mix of port of entry and agreement types.

What GAO Found

Within the Department of Homeland Security, U.S. Customs and Border Protection (CBP) uses criteria and follows documented procedures to evaluate and approve public-private partnership applications and administer the Reimbursable Services Program (RSP) and Donations Acceptance Program (DAP). For example, RSP applications undergo an initial review by CBP officials at the affected ports of entry before they are scored by an expert panel of CBP officials at headquarters. The panel evaluates RSP applications against seven criteria, such as impact on CBP operations. Similarly, DAP proposals are evaluated by CBP officials against seven operational and six technical criteria, such as real estate implications. Further, if the proposal involves real estate controlled by the General Services Administration (GSA), CBP and GSA officials collaborate on DAP selection decisions and project implementation. To administer the RSP and DAP, CBP has documented policies and procedures, such as standard operating procedures and implementation frameworks. For example, CBP uses a standard procedure to guide the process for RSP partners to request services and to provide reimbursement. For DAP projects, CBP, GSA (if applicable), and partners follow an implementation framework that includes a project planning and design phase.
The number of public-private partnerships is increasing, and partnerships provide a variety of additional services and infrastructure improvements at ports of entry. From fiscal years 2013 through 2017, CBP selected over 100 partners for RSP agreements that could impact 112 ports of entry and other CBP-staffed locations, and the total number of RSP partnerships doubled from fiscal year 2016 to 2017. According to CBP, since partners began requesting reimbursable services in 2014, CBP has provided its partners nearly 370,000 officer overtime hours of services, which led to over $45 million in reimbursed funds. As a result, CBP inspected an additional 8 million travelers and over 1 million personal and commercial vehicles at ports of entry. Similar to the RSP, the number of DAP partnerships more than doubled from fiscal year 2016 to 2017, and totals 16 projects that impact 13 ports of entry as of November 2017. The donations include improvements, such as the installation of new inspection booths and equipment and removal of traffic medians, and are intended to support over $150 million in infrastructure improvements.
CBP uses various processes to monitor and evaluate its partnerships, but could benefit from establishing an evaluation plan to assess overall program performance. For example, CBP conducts regular audits of RSP records to help ensure that CBP bills and collects funds from its partners accurately, and uses guidance, such as the DAP Implementation Roadmap, to identify and monitor project milestones and tasks. However, as of November 2017, CBP had not developed an evaluation plan—which could include, among other things, measurable objectives, performance criteria, and data collection plans—to assess the overall performance of the RSP and DAP, consistent with Office of Management and Budget guidance and leading practices. Given CBP's staffing challenges and anticipated growth of the RSP and DAP, an evaluation plan could better position CBP to further integrate evaluation activities into program management.

What GAO Recommends

GAO recommends that CBP develop an evaluation plan to assess the overall performance of the RSP and DAP. DHS concurred with the recommendation.