____________________________________________________________________________
___
Title: Managing the Customs Service
Subtitle:
Report No.: GAO/HR-93-14 Date: December 1992
____________________________________________________________________________
___
Author: United States General Accounting Office
Addressee: High-Risk Series
This file contains the text of a GAO report. Delineations within the text
indicating chapter titles, headings, and bullets are preserved. No attempt h
as
been made to display graphic images or pagination of the typeset report.
Footnotes appear in brackets at the reference point in the text. Underlined
text is indicated by underscore characters (_Introduction_). Superscript
characters are preceeded by a backslash (\a). Figures may be omitted or
replaced with tables. Tables may not resemble those in the printed version.
A printed copy of this report may be obtained from the GAO Documents
Distribution Facility by calling (202) 512-6000 or faxing your request
to (301) 258-4066 or writing to P.O. Box 6015, Gaithersburg, MD 20877.
____________________________________________________________________________
___
Overview
- The Problem
- The Causes
- GAO's Suggestions for Improvement
Customs' Key Trade Enforcement Efforts
Strategic Direction for Operations Not Adequate
- Status of Agency Efforts
Ineffective Information Resources Management Hampers Mission Accomplishment
- Planning Efforts Not Sufficiently Focused on Trade Enforcement Missi
on
- Customs Did Not Adhere to Systems Development Guidelines
- Status of Agency Efforts
Better Accountability and Stronger Controls Needed Over Customs' Resources
- Implement Stronger Controls Over Revenue
- System Improvements and Better Controls Needed Over Debt Collection
- More Reliable Financial Management Systems Needed
- Status of Agency Efforts
Insufficient Attention Given to Human Resources Management
- Better Processes and Structure Needed to Address Hrm Problems
- Status of Agency Efforts
Organizational Structure Hinders Mission Accomplishment
- Status of Agency Efforts
Conclusions and Action Needed
Related GAO Products
High-Risk Series
- Lending and Insuring Issues
- Contracting Issues
- Accountability Issues
Office of the Comptroller General
Washington, DC 20548
December 1992
The President of the Senate
The Speaker of the House of Representatives
In January 1990, in the aftermath of scandals at the Departments of Defense
and Housing and Urban Development, the General Accounting Office began a
special effort to review and report on federal government program areas that
we considered "high risk."
After consulting with congressional leaders, GAO sought, first, to identify
areas that are especially vulnerable to waste, fraud, abuse, and
mismanagement. We then began work to see whether we could find the fundament
alcauses of problems in these high-risk areas and recommend solutions to the
Congress and executive branch administrators.
We identified 17 federal program areas as the focus of our project. These
program areas were selected because they had weaknesses in internal controls
(procedures necessary to guard against fraud and abuse) or in financial
management systems (which are essential to promoting good management,
preventing waste, and ensuring accountability). Correcting these problems is
essential to safeguarding scarce resources and ensuring their efficient and
effective use on behalf of the American taxpayer.
This report is one of the high-risk series reports, which summarize our
findings and recommendations. It describes our concerns over the ability of
the U.S. Customs Service to effectively enforce the trade laws and maintain
effective financial controls.
Copies of this report are being sent to the President-elect, the Democratic
and Republican leadership of the Congress, congressional committee and
subcommittee chairs and ranking minority members, the Director-designate of
the Office of Management and Budget, the Secretary-designate of the Treasury
,
and the Commissioner of Customs.
The Customs Service is responsible for guarding the nation's borders and
enforcing trade laws and policies that protect against the introduction of
foreign goods that threaten U.S. health, safety, or economic well-being.
Attendant to its trade enforcement mission, Customs is the government's seco
nd
largest revenue collection agency; it reported collections of over $16 billi
on
in fiscal year 1991. Confronted during the 1980s with increasing levels of
imports, demands to balance its efforts to enforce the trade laws with those
of facilitating the flow of cargo, and limited resources, Customs instituted
automated systems to speed up the flow of goods and target imports for revie
w
through the Automated Commercial System (ACS).
============================================================================
===
THE PROBLEM
Customs' efforts to speed up the flow of goods were successful, but Customs
cannot ensure that it is meeting its responsibilities to combat unfair forei
gn
trade practices or protect the public from unsafe goods. Customs did not
detect about 84 percent of the estimated trade law violations in imported
cargo during fiscal year 1991. Moreover, Customs has experienced declines in
the percentage of estimated cargo violations detected since calendar year
1988.
Furthermore, Customs' financial management system has a range of weaknesses,
including the absence of reliable information on operating costs and the
status of accounts receivable, a lack of data integrity in the general ledge
r,
contract payments made without proof of delivery or acceptance of goods and
services, and weaknesses in its internal controls over the payment of overti
me
to Customs inspectors.
============================================================================
===
THE CAUSES
Customs lacks an effective strategic management process capable of guiding i
ts
operations and establishing accountability for performance. Its current 5-ye
ar
plan does not set forth a clear objective for its trade enforcement
activities, prioritize its numerous objectives, or adequately articulate a
means of fully automating customs transaction processing. Further, Customs i
s
experiencing related weaknesses in information management, financial
management, human resource management, performance measurement, and
organizational structure. Left uncorrected, these weaknesses could hinder
Customs' capacity to meet the challenges of the changing world trade
environment.
============================================================================
===
GAO'S SUGGESTIONS FOR IMPROVEMENT
Over the past several years, Customs has achieved some successes. The trade
community, for example, has agreed that ACS, the core information system for
customs transaction processing that was introduced during the 1980s, has bee
n
effective in meeting its needs. Furthermore, Customs has been able to arrang
e
broad agreement among the diverse interests within the trade community in
support of legislation to enable Customs to proceed toward full automation o
f
the customs transaction process.
As Customs pursues its plans to fully automate customs transaction processin
g,
it must be sure to develop the management processes needed to meet its trade
enforcement responsibilities. To its credit, Customs is actively addressing
the management problems identified by us and others. It has initiated a
program of financial reforms and established task forces to address needed
improvements in its trade enforcement efforts, strategic management processe
s,
and the management of its information and human resources.
The success of these efforts will be influenced by how well Customs
(1) develops and gains acceptance for a comprehensive trade enforcement
strategy, (2) corrects its long-standing financial management problems, and
(3) has the support and oversight it needs from the Congress and the Office
of
Management and Budget (OMB) to help it focus on key strategic and
organizational issues and achieve fundamental management improvements.
The American public relies on the U.S. Customs Service--a key agency
responsible for guarding the nation's borders--to enforce trade laws and
policies against the introduction into the country of foreign goods that
threaten our health, safety, or economic well-being. Customs confronts
continuing challenges to its efforts to effectively enforce the trade laws.
etween 1980 and 1990, the volume of imports that Customs processed more than
doubled, from about 4.4 million to 9.2 million. Rapid changes in world
business patterns, such as free trade agreements and "just in time" inventor
y
systems, increase the complexity of the import control function and heighten
demands on Customs to release goods quickly. Finally, the pressures on the
resources available for Customs' trade enforcement have been aggravated by t
he
agency's increasing involvement in the war on drugs. During the 1980s,
resources for narcotics enforcement increased 324 percent compared to a
115-percent increase for trade activities.
As a primary border enforcement agency, the Customs Service works with 40
other government agencies to enforce over 400 laws. Customs' trade enforceme
nt
responsibilities rest primarily with its inspectors and import specialists.
nspectors are responsible for the actual inspection of cargo at the nation's
docks, airports, and land borders to ensure compliance with the trade laws.
Faced with an expanding volume of imports, inspection efforts are targeted,
largely through the criteria within the Cargo Selectivity System (CSS), towa
rd
those imports deemed to represent the highest risk. In fiscal year 1991,
Customs performed 522,000 inspections, which was about 8 percent of all
imports.
Import specialists draw upon the knowledge they develop about specific
commodity areas to review a variety of documents importers are required to
submit to ensure that the proper amount of duties and fees are paid on
merchandise and to verify that imports comply with various quota and other
restrictions. The Entry Summary System (ESS) is designed to select documents
for import specialist review on the basis of risk criteria. In fiscal year
1991, approximately
8 million import documents were submitted to import specialists.
When Customs detects noncompliance with regulations, fraud, or other illegal
acts, it will assess and seek to collect fines or penalties and/or seize the
merchandise. While inspectors, import specialists, or special agents assess
penalties and make seizures, it is the fines, penalties, and forfeitures
(FP&F) staff that is responsible for making sure civil enforcement cases are
properly processed and that penalties are collected.
STRATEGIC DIRECTION FOR OPERATIONS NOT ADEQUATE
----------------------------------------------------------------------------
---
Customs needs an effective strategic management process capable of guiding
operations and establishing accountability for performance. Customs' current
5-year plan does not set forth a clear objective for its trade enforcement
activities. Trade enforcement needs to be defined in terms of increased
detection of violations, increased voluntary compliance by importers,
increased collections of duties, or some comparable objective. A clearer
objective would also help Customs personnel balance their efforts among
numerous enforcement programs and between the goals of enforcing the trade
laws while also facilitating the flow of goods.
The 5-year plan also does not prioritize its numerous objectives or adequate
ly
articulate how to fully automate Customs' transaction processing, the
cornerstone of its efforts for meeting its trade enforcement responsibilitie
s.
Eliminating these weaknesses would improve the plan's usefulness in guiding
operations and establishing accountability for performance.
Accountability for performance could also be improved. This could be
accomplished by making better use of information for management
decisionmaking. For example, each year Customs conducts thousands of random
cargo examinations--nearly 53,000 in fiscal year 1991--to deter importers fr
om
bringing merchandise into the country in violation of laws or restrictions a
nd
to assess the risk-targeting capabilities of CSS. However, the information
from its random cargo exams could also be used to develop estimates of the
violations in all cargo imports. Without the benefit of this latter
information, Customs was unaware that the effectiveness of its cargo
inspection activities had been declining over the past 3 years, both in term
s
of detecting estimated violations and in achieving acceptable levels of
voluntary compliance.
Another change that is needed to correct problems related to Customs'
operational performance is the development of an institutional standard for
measuring the significance of trade violations. Right now, Customs does not
have a good basis for determining whether it is focusing its limited resourc
es
on the most important violations. Marking violations--inaccurate
representations of required information on imports--represent over 60 percen
t
of the violations discovered during the past 3 years. And Customs officials
generally agree that marking violations are the least significant category.
Customs recognized that the assessment and collection of fines, penalties, a
nd
forfeitures is the foundation of efforts to ensure compliance with the trade
laws and regulations. Currently, efforts are under way to redesign the FP&F
information system. Quick action by Customs to include the capability to
compare actual collections to penalty assessments, or to monitor collection
performance by field location, would enhance its ability to effectively use
this key enforcement tool.
Various studies by others have also identified weaknesses in certain key
management processes. For example, Customs' internal management assessments
have usually been too narrowly focused to identify the root cause of program
management problems and would be more useful if done more routinely. Further
,
Customs is not aggressive enough in ensuring that recommended corrective
actions are implemented. Finally, more specific performance standards in
senior executive contracts are needed to measure managers' success in
achieving agency goals.
============================================================================
===
STATUS OF AGENCY EFFORTS
In response to our recommendations regarding strategic planning and trade
enforcement, Customs has initiated efforts to develop a trade enforcement
strategy, reevaluate its selectivity systems, and improve its planning
process. As a result of these efforts, Customs stated that its trade
enforcement objective is to ensure a high level of voluntary compliance by t
he
trade community. Customs has not yet released the details of its trade
enforcement strategy. However, Customs has outlined plans that promise to
significantly improve its selectivity systems. The incoming Commissioner wil
l
need to ensure that progress on these important efforts is sustained.
INEFFECTIVE INFORMATION RESOURCES MANAGEMENT HAMPERS MISSION ACCOMPLISHMENT
----------------------------------------------------------------------------
---
Customs has not managed its information resources effectively, thereby
limiting the availability of information needed by employees for program
execution and oversight. Also, Customs employees often lack basic informatio
n
needed to assess the effectiveness of trade enforcement efforts. These
conditions arise because of weaknesses in two key areas related to how Custo
ms
manages its information resources.
============================================================================
===
PLANNING EFFORTS NOT SUFFICIENTLY FOCUSED ON TRADE ENFORCEMENT MISSION
In developing ACS during the 1980s, Customs management was able to overcome
long-standing obstacles to automating the import filing process and produce
a
system that the trade community overwhelmingly agreed has been effective in
meeting its needs for quickly processing imports. Thus, Customs has been
successful in meeting one of its objectives for ACS.
However, Customs' second objective for ACS was to develop a system useful fo
r
detecting shipments that violate U.S. laws. Customs officials acknowledge th
at
this objective received limited attention during ACS planning. Consequently,
ACS is not serving as an effective resource for managers and field staff to
enforce compliance with the multitude of trade laws or to measure the
effectiveness of the agency's programs. For example, ESS--the automated syst
em
within ACS that determines which import documents will be reviewed--operated
for over 3 years without Customs achieving the capability to compare entry
document review results with the specific criteria prompting the review. Thi
s
capability is critical to both assessing the effectiveness of selectivity
criteria and analyzing violation trends.
Further, ESS does not readily identify why an import specialist receives ent
ry
documents for review. The importance of this information increases when entr
y
documents contain multiple items of imported merchandise. Without this
information, an import specialist does not know what needs to be reviewed.
============================================================================
===
CUSTOMS DID NOT ADHERE TO SYSTEMS DEVELOPMENT GUIDELINES
In developing and implementing its information systems, Customs did not adhe
re
to federal information systems guidelines. This delayed the implementation o
f
key information systems. For example:
-- In 1989, Customs began developing an in-house Asset Information Managemen
t
System (AIMS) without performing a feasibility study to determine whether
it would be more cost efficient to meet its financial information needs
through use of an off-the-shelf software package. After 3 years of in-hou
se
development and expenditures of over $4 million, Customs did a feasibilit
y
study that prompted it to abandon its in-house efforts.
-- From the initial design of ESS in 1987 to the present, Customs did not
prepare feasibility studies, risk or cost-benefit analyses, or developmen
t
and implementation plans. Customs implemented the first phase of ESS
without fully testing the system. As a result, import specialist reviews
are being hampered because they are experiencing difficulty getting key
information on why an entry document was selected for review.
============================================================================
===
STATUS OF AGENCY EFFORTS
Customs is taking a number of positive steps to improve planning and make
better use of its information resources to enforce the trade laws. It has
slowed the pace of ACS development and implementation to help the broker
community keep pace with the changes taking place in the processing of
imported cargo. It has shifted responsibility for defining information needs
from the ACS systems analysts to program personnel. It is exploring ways of
making more effective use of the trade data residing in ACS without impeding
progress toward the system's primary function of expediting the release of
cargo. And Customs has implemented the ESS history file, which should enable
it to better evaluate the effectiveness of its automated criteria. These
actions are commendable. But to maximize their potential to succeed, the
incoming commissioner will also need to
-- identify program and cross-functional information needs,
-- prepare an information and systems architecture that shows how informatio
n
technology will fit into the agency's overall trade enforcement strategy
and prescribes the critical characteristics of the equipment and resource
s
needed to meet current and future needs,
-- adhere to federal system development guidelines, and
-- evaluate the effectiveness of its information resources management
activities.
BETTER ACCOUNTABILITY AND STRONGER CONTROLS NEEDED OVER CUSTOMS' RESOURCES
----------------------------------------------------------------------------
---
Customs continues to face the challenge of establishing adequate
accountability and control over its resources. Stronger controls for
identifying and collecting fees owed and for debt collection would have
produced greater success in collecting millions of dollars in user fees and
delinquent accounts receivable. Further, Customs' automated and manual
accounts receivable systems would be more useful if they contained more
complete and accurate data. Finally, Customs needs to improve both its
accounting for and controls over property.
============================================================================
===
IMPLEMENT STRONGER CONTROLS OVER REVENUE
Stronger internal controls governing the efforts of Customs import specialis
ts
to determine whether appropriate duties are paid would produce more revenues
Limitations in the capabilities of ESS leave Customs without assurance of th
e
effectiveness of its efforts to target high-risk import documents for review
ESS has not had a history file to monitor the results of its reviews to eith
er
confirm the current selection criteria or to develop a valid basis for
changing them. Although Customs randomly selected about 93,700 entry documen
ts
for review in fiscal year 1990, it was not able to use the results of these
reviews to develop estimates of overall importer compliance with tariff
provisions because there is currently no standardized way to capture and
analyze the results of the reviews.
Strengthening internal controls over other Customs revenue-generating
activities could also benefit the agency. Currently, Customs does not
routinely compare the amount of user fees collected from airline carriers an
d
exporters with amounts owed. Customs' own fiscal year 1990 review at 1 airpo
rt
showed that 6 of 10 carriers had underpaid passenger user fees by $1.9
million. Also, when Customs recently compared export shipment data with
collection information, it discovered that some exporters shipped goods out
of
the country without paying harbor maintenance fees.
============================================================================
===
SYSTEM IMPROVEMENTS AND BETTER CONTROLS NEEDED OVER DEBT COLLECTION
Customs' delinquent accounts receivable totaled almost $344 million as of
September 30, 1991. Customs could increase its capability to collect these
receivables by upgrading its systems so it could monitor such important
information as the age of receivables and the sufficiency of the bonds
required to cover the value of importer activity. Also, Customs could make
greater use of its authority to impose sanctions (restricting import activit
y
through Customs) against delinquent importers and sureties. Such actions cou
ld
also help it collect delinquent debts in a timely manner and, thereby,
increase revenue.
============================================================================
===
MORE RELIABLE FINANCIAL MANAGEMENT SYSTEMS NEEDED
Customs' accounting and internal control systems do not give management
complete and accurate information to effectively manage its resources. No
single accounts receivable system currently captures all amounts (duties,
fees, fines, and penalties) owed Customs from the time of assessment to
collection. As a result, Customs must manually prepare financial reports usi
ng
information from a number of automated and manual systems. For example, the
FP&F system contains information on the fines and penalties assessed violato
rs
of trade laws, but Customs does not establish these amounts as individual
accounts receivable or summarize this information in the primary accounting
ystem or in financial reports. The manual preparation of financial reports o
n
accounts receivable is labor intensive and increases the opportunity for
inaccurate reporting.
Also, differences totaling $61.8 million existed between Customs' property
system and its primary accounting system in fiscal year 1991. Part of these
differences can be attributed to the lack of adequately trained personnel. F
or
example, some property officers were not aware that the method used to proce
ss
property acquisitions can affect how property is recorded in the system. An
additional factor contributing to these differences was improper
classification of property acquisitions. Financial records showed considerab
le
confusion among Customs personnel in deciding when to expense property items
and when to capitalize them.
Also, contingent liabilities were not disclosed in the notes to the financia
l
statements to account for refunds that were likely to be made to exporters w
ho
apply for refund of duties collected on merchandise initially imported and n
ow
being exported--known as drawbacks.
============================================================================
===
STATUS OF AGENCY EFFORTS
Customs has recognized many of its financial system problems, and top
management has expressed its resolve to correct them under the framework of
the Chief Financial Officers (CFO) Act. Under the direction of its CFO, a
number of initiatives are under way, such as an effort to develop a new
financial management system. The incoming Commissioner's involvement and
commitment will be essential to achieving an effective financial management
environment.
INSUFFICIENT ATTENTION GIVEN TO HUMAN RESOURCES MANAGEMENT
----------------------------------------------------------------------------
---
Customs is confronting a number of human resource management (HRM) issues th
at
diminish its ability to effectively enforce trade laws and improve
organizational performance. For example, reviews conducted by a
Customs-established Blue Ribbon Panel and by the Treasury Inspector General
in
1991 found that
-- performance ratings had no relationship to actual performance and
-- the process for dealing with ineffective supervisors and managers did not
work, and employees whose performance was considered inadequate did not
receive such feedback from supervisors.
Customs' managers and brokers also expressed concerns regarding the adequacy
of training efforts, despite the recent expansion of the training program an
d
the revamping of some existing courses. In response to a GAO questionnaire,
over
40 percent of Customs managers expressed concerns about the management
training they received, training for their staffs, and time and funding
provided for training.
Further, 54 percent of customs brokers viewed the turnover of Customs staff
as
negatively affecting job knowledge and the quality of service. The majority
of
Customs managers also thought that staff changes were too frequent and had a
negative effect on their work.
============================================================================
===
BETTER PROCESSES AND STRUCTURE NEEDED TO ADDRESS HRM PROBLEMS
Customs has established ambitious HRM objectives for increasing the
professionalism of its workforce. However, its ability to achieve these
objectives and address its workforce problems are limited by weaknesses in i
ts
HRM processes and structure. Customs does not have a comprehensive HRM plan
that supports organizational goals. Further, it does not routinely analyze
information for evaluating key HRM issues. For example, Customs does not
routinely account for agencywide training expenditures, collect reliable
information on the courses offered throughout its units, or track the traini
ng
histories of its personnel.
Also, the limited capabilities of the central personnel and training offices
diminish their ability to lead an effective agencywide HRM effort. For
example, the Office of Human Resources is faced with an inappropriate
organizational structure, erroneous data in automated systems, paperwork
processing delays, understaffing, inadequate staff training, a high turnover
rate, and recruiting delays.
============================================================================
===
STATUS OF AGENCY EFFORTS
Customs has initiated a number of HRM efforts. It has established HRM
objectives in its 5 year plan, formed an Office of Organizational
Effectiveness headed by an Associate Commissioner to correct problems pointe
d
out by the external reviews conducted in 1991, and has surveyed employees to
determine what job benefits they would like. To maximize its potential to
address its workforce problems, Customs needs to develop a (1) planning
process that targets key HRM issues and is tied to the budget process; (2)
workforce planning capability that identifies the number of people and types
of skills needed and areas where problems may occur; (3) training program to
enhance employee development and productivity; and (4) capability to monitor
,
evaluate, and update information that affects HRM goals. Instituting this
management system will also require sustained commitment from the incoming
Commissioner and his or her team.
Changes in Customs' organizational structure must accompany efforts to impro
ve
management processes. Successful accomplishment of the trade enforcement
mission requires effective coordination of the efforts of the offices of
Inspection and Control, Commercial Operations, and Enforcement. However, 49
percent of Customs' managers feel that there is not a high level of
cooperation or coordination among programmatic units. In 1991, an internal
Customs study concluded that the FP&F program is the foundation on which
Customs' enforcement mission rests because all the resources expended in any
enforcement action are wasted unless they result in a penalty, fine, or
forfeiture. However, the study found that Customs' components lacked a gener
al
understanding of the relationship between their functions and the FP&F
program.
Another problem with the organizational structure is that Customs' reliance
on
its 7 regions to oversee operations in the 44 districts is not ensuring
consistent policy implementation. For example, headquarters inspection and
control program managers were unable to overcome field opposition to
instituting a standard method for tracking the quality of cargo examinations
There are two reasons for the problems. First, Customs' headquarters structu
re
divides policymaking offices by job function (such as inspections, duty
assessment and collection, and criminal enforcement) rather than aligning th
em
by mission. This functional division encourages top policymakers to focus on
functional concerns, as opposed to mission effectiveness, and places the
responsibility for managing conflicting priorities and integrating
cross-office functions in the Commissioner's office.
Second, a structural emphasis is placed on geographic diversity by the
dispersion of line authority from the Commissioner's office directly to
regional offices, which develop independent policies based upon regional
priorities. This diversity conflicts with the agency's objective of
maintaining uniform programs and again places the responsibility for ensurin
g
consistent policy implementation in the Commissioner's office.
The result is an overload of management circuits in the offices of the
Commissioner and Deputy Commissioner, which are the only offices with the
formal authority to ensure agencywide consistency and coordinate the
functionally divided components that carry out the agency's mission. The
current structure essentially mandates that the Commissioner's office manage
the details of the work--a job that should be delegated to subordinate
managers. This structure takes away from the time the Commissioner and Deput
y
Commissioner can devote to their leadership responsibilities.
============================================================================
===
STATUS OF AGENCY EFFORTS
We recommended that Customs closely examine its current structure with the
objective of reorganizing the agency to better achieve the trade enforcement
mission. Serious consideration should be given to reorganizing headquarters
offices according to broadly defined mission components and vesting the top
officials in these offices with line authority over field operations. Any
reorganization should be based on a clearly communicated statement of Custom
s'
mission and a translation of this mission into a comprehensive trade
enforcement strategy.
Any complete study of Customs' organization should also address the agency's
field structure. Customs studies have identified the need for revisions to t
he
field structure on the basis of findings of wide variations among the
districts' workloads and resources. It is very likely that Customs' plans to
fully automate its transaction process will lead to centralized document
filing by the trade community. This could lead to centralizing the duty
assessment function performed by import specialists, with implications for t
he
current configuration of Customs' districts and ports.
However, current appropriations legislation restricts Customs from planning
or
implementing changes to the current field structure. We have recommended tha
t
the Congress remove those legislative restrictions. If the Congress does
remove such restrictions, we recommend that Customs examine its field
structure and consider consolidating districts to improve accountability and
reduce unnecessary expense. Again, such an examination should be done within
the framework of Customs' plans for enforcing the trade laws as it moves to
fully automated customs transaction processing.
In a recent status report on efforts to address the recommendations in our
general management review, Customs agreed that we had identified some valid
organizational issues. However, Customs said that any actions to overhaul it
s
organizational structure would await the outcome of the efforts it has under
way to address the other management problems we identified, and action by th
e
Congress to remove the legislative restriction that prohibits Customs from
changing its current field structure. We believe that Customs' approach is
reasonable.
CONCLUSIONS AND ACTION NEEDED
----------------------------------------------------------------------------
---
Customs has initiated a broad range of efforts to address management problem
sidentified by us and others. Although Customs is making a good faith effort
to
formulate and implement plans, the permanency of these plans is fragile at
this point because of the early stage they are in and the disruptions that m
ay
accompany the transition to the new administration. Therefore, priority
attention from the new Commissioner will be crucial to ensuring that current
efforts are sustained and result in real improvements. In addition to gainin
g
support for broad systems and organizational improvement efforts within
Customs, the incoming Commissioner will also face the task of gaining
acceptance for Customs' trade enforcement strategy from the Congress and the
trade community.
