oversight

CBP Needs to Improve the Oversight of its Canine Program to Better Train and Reinforce Canine Performance (REDACTED)

Published by the Department of Homeland Security, Office of Inspector General on 2021-02-08.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                      LAW ENFORCEMENT SENSITIVE
                  OFFICE OF INSPECTOR GENERAL
                       Department of Homeland Security
                        Washington, DC 20528 / www.oig.dhs.gov


                                 February , 2021

MEMORANDUM FOR:         Troy Miller
                        Senior Official Performing the Duties of the
                        Commissioner
                        U.S. Customs and Border Protection

FROM:                   Joseph V. Cuffari, Ph.D.                   Digitally signed by
                        Inspector General
                                                 JOSEPH V          JOSEPH V CUFFARI
                                                                   Date: 2021.02.04
                                                       CUFFARI     10:06:30 -05'00'

SUBJECT:                CBP Needs to Improve the Oversight of Its Canine
                        Program to Better Train and Reinforce Canine
                        Performance – Law Enforcement Sensitive

Attached for your action is our final report, CBP Needs to Improve the Oversight
of Its Canine Program to Better Train and Reinforce Canine Performance – Law
Enforcement Sensitive. We incorporated the formal comments provided by your
office.

The report contains four recommendations. Your office concurred with all four
recommendations. Based on information provided in your response to the
draft report, we consider recommendations 1, 2, and 3 resolved and open.
Once your office has fully implemented the recommendations, please submit a
formal closeout letter to us within 30 days accompanied by evidence of
completion of agreed-upon corrective actions so that we may close the
recommendations.

Based on information provided in your response to the draft report, we
consider recommendation 4 unresolved and open. As prescribed by the
Department of Homeland Security Directive 077-01, Follow-Up and Resolutions
for the Office of Inspector General Report Recommendations, within 90 days of
the date of this memorandum, please provide our office with a written response
that includes your 1) agreement or disagreement, 2) corrective action plan, and
3) target completion date. Also, please include your responsible parties and
other supporting documentation to inform us about the current state of the
recommendation. Until your response is received and evaluated, the
recommendation will be considered unresolved and open. Please send your
response or closure request toOIGAuditsFollowup@oig.dhs.gov.

Consistent with our responsibility under the Inspector General Act, we will
provide copies of our report to congressional committees with oversight and
appropriation responsibility over the Department of Homeland Security. We
will post a redacted version of the report on our website.


                      LAW ENFORCEMENT SENSITIVE
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                      Department of Homeland Security


Please call me with any questions, or your staff may contact Thomas Kait,
Acting Assistant Inspector General for Audits, at (202) 981-6000.

Attachment




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                                      DHS OIG HIGHLIGHTS
                   CBP Needs to Improve the Oversight of Its Canine
              Program to Better Train and Reinforce Canine Performance

February 8, 2021                          What We Found
Why We Did                                CBP’s training approach and execution do not fully
                                          support the canine teams’ mission of detecting
This Audit                                smuggling of illegal narcotics, agriculture products, and
                                          humans at and between ports of entry. In fiscal
The U.S. Customs and                      year 2019, CBP decided to realign its Canine Academy,
Border Protection’s (CBP)                 which contributed to a decrease of canine teams
Canine Program is the                     trained in the first two quarters of FY 2020. This
largest canine program in                 occurred because CBP did not adequately plan for the
DHS, with more than                       realignment or measure performance to demonstrate
1,500 canine teams                        how the realignment would affect canine performance.
deployed at and between
the Nation’s ports of                     The Office of Field Operations (OFO) canine teams used
entry. We conducted this                  pseudo narcotic training aids past the recommended
audit to determine to                     replacement cycle (outdated). Both Border Patrol and
what extent CBP’s canine                  OFO canine teams used outdated actual narcotic
training approach and                     training aids during proficiency training in the field.
execution support the                     Additionally, OFO canine team files did not have
Canine Program mission.                   required proficiency training documentation. The use
                                          of outdated training aids and the missing
What We                                   documentation occurred because CBP Canine Program
                                          management did not provide adequate oversight to
Recommend                                 ensure training aids were available to canine teams and
                                          certified instructors were properly documenting
We made four                              proficiency training.
recommendations that, if
implemented, should                       CBP’s inadequate governance of canine team operations
help CBP improve                          led to outdated Canine Program policies and
oversight of its Canine                   procedures, inconsistent retention periods for training
Program, formalize and                    documents, and an absence of Canine Tracking System
implement a realignment                   policies and procedures. This inadequate governance
plan for the training                     ensued because CBP Canine Program management did
academy, provide proper                   not prioritize program management as other challenges
training capabilities, and                took precedence. Without a comprehensive
update and standardize                    realignment plan, adequate proficiency training, and
program guidance.                         proper governance, the CBP Canine Program will not be
                                          able to achieve desired growth or operate as intended.
For Further Information:
Contact our Office of Public Affairs at
(202) 981-6000, or email us at
DHS-OIG.OfficePublicAffairs@oig.dhs.gov
                                          CBP Response
                                          CBP concurred with the recommendations.


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Table of Contents

Background .................................................................................................... 2

Results of Audit .............................................................................................. 6

        CBP Did Not Adequately Justify Realignment of Its Canine Training....... 6

        CBP Could Not Ensure Canine Teams Received Adequate Proficiency
        Training................................................................................................. 9

        CBP Had Inadequate Governance for Its Canine Team Operations........ 13

Recommendations......................................................................................... 16

Appendixes

        Appendix      A:   Objective, Scope, and Methodology ................................. 20
        Appendix      B:   CBP Comments to the Draft Report .................................. 23
        Appendix      C:   CBP Performance Standards Score Sheet (Form 1250) ..... 28
        Appendix      D:   Office of Audits Major Contributors to This Report ........... 29
        Appendix      E:   Report Distribution .......................................................... 30


Abbreviations

        CBP                U.S. Customs and Border Protection
        CCEP               Canine Center El Paso
        CCFR               Canine Center Front Royal
        GAO                U.S. Government Accountability Office
        K9TS               Canine Tracking System
        LSSD               Laboratories and Scientific Services Directorate
        MDMA               3,4-methylenedioxymethampehtamine
        NCP                National Canine Program
        OFO                Office of Field Operations
        OTD                Office of Training and Development
        POE                port of entry




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                                              Background

U.S. Customs and Border Protection’s (CBP) mission is to safeguard America’s
borders from dangerous people and materials while enhancing the Nation's
global economic competitiveness through legitimate trade and travel. CBP’s
Canine Program, which refers to its collectively
managed canine team operations and training, is
critical to achieving this mission. The primary goal
of canine teams, each consisting of a certified
detection canine and a certified handler, is to detect
and apprehend persons attempting entry into the
United States whose intent is to organize, incite, and
carry out acts of terrorism. The Canine Program's
secondary goal is detection (as shown in Figure 1)
and seizure of controlled substances and other
contraband, often used to finance terrorist and
                                                        Figure 1. Office of Field
criminal drug trafficking organizations.
                                                                      Operations (OFO) canine team
                                                                      Source: Office of Inspector General
CBP’s Canine Program is the largest canine program        (OIG) audit team
in the Department of Homeland Security, with more
than 1,500 canine teams deployed at and between the Nation’s ports of entry
(POE). According to CBP data, the number of canine teams in CBP has
remained relatively constant over the last 5 years, as shown in Figure 2.

                      Figure 2. CBP Canine Teams, 2015 – 2019
             1000

              800

              600

              400

              200

                  0
                       2015            2016        2017    2018          2019

                              Border Patrol      OFO NCP   OFO Agriculture

            Source: OIG analysis of CBP data

The operational aspect of the CBP Canine Program comprises U.S. Border
Patrol’s (Border Patrol) canine teams, OFO National Canine Program (NCP), and
OFO Agriculture Canine Program. CBP certifies canine teams in multiple
disciplines to detect concealed humans, narcotics, human remains, currency,

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firearms, and prohibited agricultural items. CBP’s Office of Training and
Development (OTD) initially certifies canine teams for Border Patrol and OFO
NCP. 1 The U.S. Department of Agriculture trains and initially certifies the OFO
Agriculture canine teams at its National Detector Dog Training Center in
Newnan, Georgia, which is a separate training program from that of CBP.
Figure 3 shows a comparison of the different types of CBP canine teams.

Figure 3. Comparison of CBP Canine Teams by Operational Program




Source: OIG analysis of CBP records

2009 Merger of CBP Canine Academy and 2019 Realignment

In October 2009, OTD merged the Border Patrol and OFO NCP canine training
programs to create the CBP Canine Academy. OTD combined best practices
from Border Patrol and OFO NCP into one standardized curriculum containing
identical training philosophies and methodologies geared toward individual
subcomponent operational requirements. CBP instituted the new academy
using two training delivery sites: Border Patrol's National Canine Facility in El
Paso, Texas, now known as Canine Center El Paso (CCEP), and OFO's Canine
Enforcement Training Center in Front Royal, Virginia, now known as Canine
Center Front Royal (CCFR).



1Student canine handlers are tested with their assigned canine using U.S. Customs and Border
Protection Canine Detection Team Certification Standards. For certification, teams must
accurately search multiple environments and locations. Each team must successfully
complete the certification process to deploy operationally to a CBP location.

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instructors conduct maintenance training and non-task-related training once a
pay period, 3 for 8 hours, using training aids. Enforcement training aids are
made with actual narcotics [marijuana, cocaine, 3,4-
methylenedioxymethampehtamine (MDMA), heroin, and methamphetamine
(meth) 4]; whereas, agriculture aids contain pork, beef, and prohibited fruits.

Certified canine instructors are responsible for constructing and concealing
training aids, made with actual or pseudo narcotics, in different containers, as
shown in Figure 5. The instructors also document and score the canine team’s
performance in detecting such training aids.




Additionally, OFO canine teams perform
daily task-related proficiency training
activities using pseudo narcotics and/or
soft narcotics (marijuana and hashish).
Pseudo narcotics are chemically
formulated, non-narcotic materials
designed to mimic the real odors of
illegal substances such as heroin
(Figure 6), cocaine, meth, and MDMA.       Figure 6. Pseudo Narcotics Used by
CBP manufactured pseudo narcotics at                  OFO NCP canines
CCFR until August 2020, when they          Source: OIG photo taken during site visit
transferred the equipment and responsibility to the Laboratories and Scientific
Services Directorate (LSSD). Border Patrol does not require its canine teams to


3A pay period covers 2 work weeks as defined by 5 U.S. Code § 5504.
4In response to the opioid epidemic, OFO added fentanyl to its list of actual narcotics for
canine proficiency training. Only the OFO NCP canines train with fentanyl.

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conduct daily proficiency training, nor does Border Patrol use pseudo narcotic
training aids.

                                      Results of Audit

CBP’s training approach and execution do not fully support the canine teams’
mission of detecting smuggling of illegal narcotics, agriculture products, and
humans at and between POEs. In FY 2019, CBP decided to realign its Canine
Academy, which contributed to a decrease in canine teams trained during the
first two quarters of FY 2020. This occurred because CBP did not adequately
plan for the realignment or measure performance to demonstrate how the
realignment would affect canine performance.

OFO’s NCP canine teams used outdated 5 pseudo narcotic training aids. Both
Border Patrol and OFO NCP canine teams used outdated actual narcotic
training aids during proficiency training in the field. Additionally, we found
OFO NCP canine team files did not have required documentation for proficiency
training. The use of outdated training aids and missing documentation
occurred because CBP Canine Program management did not provide adequate
oversight to ensure training aids were available to canine teams and that
certified instructors were properly documenting proficiency training.

Furthermore, CBP’s inadequate governance of canine team operations led to
outdated Canine Program policies and procedures, inconsistent retention
periods for training documents, and an absence of Canine Tracking System
(K9TS) policies and procedures. This inadequate governance ensued because
CBP Canine Program management did not prioritize program management as
other challenges took precedence. Without a comprehensive realignment plan,
adequate proficiency training, and proper governance, the CBP Canine Program
will not be able to achieve desired growth or operate as intended.

CBP Did Not Adequately Justify Realignment of Its Canine
Training

In FY 2019, CBP decided to separate what had been a unified Canine Academy
training program into two subcomponent-specific training curricula realigned
with Border Patrol and OFO NCP. In the first and second quarters of FY 2020,
in transitioning to this realignment, the number of canine teams trained
decreased. This reduction in the number of teams trained occurred in part
because, prior to its decision, CBP did not adequately plan for the realignment


5   “Outdated” refers to training aids that are past their recommended replacement cycle.

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or measure performance to demonstrate how the realignment would affect
canine performance.

Training Realignment Decision

According to CBP, realigning training with Border Patrol and OFO NCP would
reduce the component’s liability, as well as strengthen each subcomponent’s
capabilities through selection of task-specific personnel and canines and
mission-specific canine training. CBP also asserted its growing footprint
required support from more canine teams and an accompanying adjustment to
the training curriculum. Finally, according to CBP Canine Program officials,
Border Patrol and OFO NCP have unique training methods and operational
environments, and subcomponent-specific curricula would better prepare
canine teams for the dynamic operational needs of their respective
environments.

In realigning training, CBP decided to re-establish two mission-driven
academies — CCEP for Border Patrol and CCFR for OFO NCP. At each
academy, the respective subcomponent would control its own policy and
training curriculum, as well as use its own specific curriculum and instructors
to train canines. OTD remains responsible for training execution to ensure it
aligns with component established policies and procedures.

In August 2019, the CBP Acting Commissioner instructed Border Patrol, OFO,
and OTD to form a joint working group to help transition to the realignment.
As of May 2020, the joint working group was evaluating the instructional
design of canine training, focusing on positive reinforcement and canine
aggression requirements. In addition, the separated Concealed Human and
Narcotics Detection Canine Handler Course (handler course) 6 curriculum for
Border Patrol and OFO NCP was still in draft. Therefore, as of May 2020, the
two academies were still using the combined curriculum for the handler
course.

Realignment Reduced the Number of Teams Trained

The Canine Academy realignment transition contributed to the reduced
number of teams trained in the first two quarters of FY 2020 (October 2019
through March 2020). In this period, Border Patrol and OFO NCP both
graduated fewer teams than planned in the new Concealed Human and

6The Concealed Human and Narcotics Detection Canine Handler Course certifies a handler
and canine at the completion of the 7-week course under the CBP Canine Detection Team
Certification standards.

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objectives, and formulates plans to achieve its objectives.” In August 2019,
Border Patrol and OFO briefed the CBP Acting Commissioner on the separate
training curricula. According to a CBP official, OFO also drafted a governance
document establishing oversight responsibilities for itself, Border Patrol, and
OTD during the transition to separate, realigned curricula. However, CBP did
not develop a strategic plan prior to the execution of the realignment, such as
how it would provide enough instructors to staff each academy. Following
approval of the realignment in August 2019, Border Patrol and OFO
immediately decided they would no longer place new:

   •   Border Patrol instructors at OFO’s training center in Front Royal, or
   •   OFO instructors at Border Patrol’s training center in El Paso.

Instead, each subcomponent would only place its own instructors at its
designated academy. OFO NCP did not provide enough instructors to facilitate
full capacity training classes at the academies. Specifically, OFO did not
provide enough instructors to meet OTD’s required 2:1, student-to-instructor,
ratio.

CBP also could not provide performance metrics or other supporting
documentation to clarify how the realignment would affect canine performance
or enhance the subcomponent’s capabilities by implementing mission-specific
canine training. OTD expressed concerns that it would be helpful if OFO
provided metrics for canine training processes that were not working in order
to establish guidance to correct the deficiencies. In addition, OFO Canine
Program officials stated they did not have performance measures in place to
support the need for the realignment.

CBP Could Not Ensure Canine Teams Received Adequate
Proficiency Training

Canine teams for OFO NCP used outdated pseudo narcotic training aids, and
teams from Border Patrol and OFO NCP used outdated actual narcotic training
aids during proficiency training in the field. In addition, we found OFO NCP
canine team files did not have required documentation for proficiency training.
The use of outdated training aids and missing documentation occurred
because CBP Canine Program management did not provide adequate oversight
to ensure training aids were available to canine teams and that certified
instructors were properly documenting proficiency training.




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Procedures state how often narcotic training aids should be replaced. In
addition, LSSD had not completed any tests or studies to determine the
effectiveness of narcotic training aids based on age and when they should be
replaced. Finally, CBP had not established serviceable life for the fentanyl
training aids OFO used and did not know when OFO should replace the aids.

OFO NCP Was Not Properly Documenting Proficiency Training

OFO NCP canine teams did not have required proficiency training documents
in their team files. According to Border Patrol and OFO guidance, once a pay
period, certified canine instructors are to document canine training on the CBP
Performance Standards Score Sheet (Form 1250), which is physically
maintained in the canine team files. (See Appendix C for a sample Form 1250.)

During our site visits, we reviewed 28 Border Patrol and OFO NCP canine team
files. Of those, 43 percent (12 of 28) of the files did not have Form 1250s to
verify completion of proficiency training. A CBP Canine Program manager said
the field office had a limited number of instructors to ensure all teams received
and documented their training. In fact, three of the six POEs we visited did not
have a certified canine instructor.

Inadequate Oversight of Proficiency Training

CBP Canine Program management did not provide adequate oversight to
ensure refreshed training aids were available timely and certified canine
instructors were available to properly document proficiency training. Both
Border Patrol and OFO NCP used outdated actual narcotic aids for proficiency
training in the field because CBP Canine Program management did not ensure
canine teams promptly received and refreshed these required training aids. In
particular, according to the 2017 MOU, Canine Program managers were
supposed to request actual narcotic training aids from LSSD twice a year.
However, the LSSD Canine Training Aid Program faced challenges fulfilling
these requests due to the limited availability of narcotics, as well as insufficient
staff. In addition, LSSD did not know the baseline volume of narcotics the
components needed annually, which would help planning for requests. Finally,
CBP Canine Program management had not developed a delivery schedule for
Border Patrol sectors or OFO field offices to sustain and refresh training aids.

Furthermore, CBP Canine Program management did not ensure adequate
production and distribution of replacement pseudo narcotic training aids used
in OFO NCP proficiency training. Historically, OTD Materials Controls
Specialists produced pseudo narcotic aids for all OFO field offices, but after all
the specialists retired in 2015, management did not fill their vacated positions.

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According to OFO Canine Program management, this created a gap in
production of the training aids. Since April 2016, OFO had detailed officers to
CCFR to produce pseudo narcotic training aids for the field on three occasions
in the absence of Materials Controls Specialists. Canine Program management
officials said that operational requirements had delayed consistently sending
OFO officers to CCFR for the production of pseudo training aids. According to
CBP, as of April 2020, it is transitioning production and distribution of
replacement pseudo narcotic training aids from OTD to LSSD. LSSD was to
work with OFO to establish appropriate manufacturing and shipping schedules
to ensure regular replacements for the pseudo training aids. 12

OFO management did not adequately oversee the certified canine instructors to
ensure they conducted and properly documented canine training to validate its
completion. Such oversight would include routine communication with
instructors in the field to ensure they were complying with program guidance
and meeting all training-related requirements. For example, we visited
multiple OFO POEs without instructors, which caused canine teams to
sacrifice required proficiency training. CBP Canine Program management also
did not have a process to ensure enough instructors were in the field to meet
OFO NCP canine team training needs. During our site visit to an OFO POE, no
instructor was available to provide break-in training for multiple, newly
deployed canine teams, therefore delaying their operational use.

CBP Had Inadequate Governance for Its Canine Team
Operations

According to the GAO Standards for Internal Control in the Federal Government,
an effective way to achieve accountability is to implement control activities
through policies. 13 Per the standards, management should communicate to
personnel the policies and procedures so that the personnel can implement the
control activities for their assigned responsibilities. CBP’s inadequate
governance of canine team operations led to outdated Canine Program policies
and procedures, inconsistent training-document retention periods, and an
absence of K9TS policies and procedures. We attribute CBP’s inadequate
governance to CBP Canine Program management not prioritizing program
management as other challenges took precedence.




12Memorandum titled, “Pseudo Narcotics for Canine Training Aids,” April 2020.
13GAO, Standards for Internal Control in the Federal Government, GAO-14-704G, September
2014, Principle 12 – Implement Control Activities.

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Outdated Canine Program Policies and Procedures

At the time of our fieldwork, Border Patrol and OFO NCP Canine Program
policies and procedures had not been updated in more than 9 years, despite
changes in the operational environment. During our audit, CBP had not
updated the Border Patrol Canine Unit Policy and Procedures since 2010.
However, at the completion of our fieldwork, Border Patrol issued an updated
Border Patrol Canine Unit Policy and Procedures. Border Patrol’s 2020 policy
still did not include a timeframe or process for knowing when actual narcotic
training aids are outdated or for refreshing the training aids. The OFO Canine
Enforcement Program Handbook, which was last updated in 2002, was missing
information and included some outdated information. For example, the
handbook did not mention or include guidance regarding fentanyl aids
deployed to the field in 2017. In addition, according to the handbook, OTD
should provide narcotic training aids for the field, but LSSD has been
producing and distributing training aids.

Inconsistent Retention Periods for Maintaining Training Documents

Border Patrol stations and OFO field offices did not use the same record
retention schedule. To illustrate, OFO did not document its rationale for its
record retention policy, which is inconsistent with the General Records
Schedule. The General Records Schedule provides authority for records
common to many Federal agencies and specifically states canine service
records should be destroyed when superseded, obsolete, or 3 years after the
canine is released from service, whichever is sooner. According to the OFO
Canine Enforcement Program Handbook, offices should maintain training
records for a minimum of 90 days. OFO modified its record retention policy to
90 days because it placed more emphasis on annual certification than on
proficiency training results. OFO leadership at one POE explained it kept
canine proficiency training records longer than necessary to support local court
cases; CBP could lose cases if it could not provide adequate training records.

Furthermore, OFO did not consistently maintain proficiency training
documents. During our fieldwork visits, training documentation maintained by
OFO field offices was either missing or insufficient to demonstrate the
completion of required proficiency training. OFO field offices were not following
their policies for maintaining adequate training records for a minimum of 90
days. For example, during our site visits, we reviewed 16 OFO NCP canine
team files. Of those files, 75 percent (12 of 16) did not have Form 1250s to
verify completion of proficiency training. Although the 2020 Border Patrol
Canine Unit Policy and Procedures does not include document retention


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periods, all stations we visited simply kept training documents for the life of the
canines.

No Guidance on Standard Use of K9TS

CBP has not issued policies and procedures to ensure standard use of K9TS,
which is a web-based depository of CBP canine data for canine officers, canine
supervisors, and field canine advisors. Canine handlers use K9TS to access
monthly records of seized illegal or prohibited items, utilization statistics,
certifications and certification dates, health and veterinarian appointments and
information, microchip numbers, vaccination records, temporary duty
assignments, and photos of canines. Canine handlers did not always record
accurate seizure and veterinarian data in K9TS. For example, when evaluating
data for OFO Agriculture canines, we identified inflated seizure statistics on
detected, prohibited produce and/or meats, which could lead management to
make ill-informed decisions on allocating canine resources and when
requesting additional funding from Congress. In addition, during our site visits
to three Border Patrol sectors and six POEs, we observed OFO Agriculture staff
recording training hours for their canines in K9TS. Conversely, Border Patrol
and OFO NCP did not record any training information at all. Lastly, we found
canine veterinarian records in K9TS that were not as up-to-date as supporting
medical documents.

Management Did Not Prioritize the Canine Program

CBP’s inadequate governance of the Canine Program is attributed to not
prioritizing the program due to other challenges that took precedence. CBP
management’s oversight and leadership to both the Border Patrol and OFO
Canine Programs provide guidance and support to southern border operations.
Since 2014, CBP has experienced a dramatic increase in migrants along the
Southwest border, which has resulted in overcrowded detention facilities and
prolonged processing times for migrants. According to CBP Officials, increased
attention to these issues has reduced CBP’s attention to Canine Program
operations. For example, CBP closed selected Border Patrol checkpoints,
reallocating canine handlers to help with other duties such as processing
migrants. CBP also moved more than 700 OFO officers from POEs to help
Border Patrol process the surge of apprehended migrants. Additionally,
Southwest Border Patrol sector chiefs reassigned canine handlers to help
process migrants, therefore requiring the handlers to kennel their canines.
Given these other priorities, Canine Program management did not have the
support needed to develop and issue updated policies on canine operations and
implement standards for using K9TS.


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                                 Conclusion

CBP’s canine teams play a vital role in detecting people, illicit goods, and
prohibited agricultural items from entering the country illegally. However,
without a comprehensive plan for realignment, proper training, and updated
and consistent program guidance, the CBP Canine Program has not been able
to achieve desired growth or operate as intended. Because it did not
adequately plan for or analyze the performance enhancing benefits of realigning
its canine training curricula, CBP could not adequately justify the realignment
and ensure it met the needs of Border Patrol and OFO.

Additionally, CBP did not ensure its canine teams were adequately trained in
the field to achieve their mission. Using training aids that were contaminated
or past their recommended replacement cycle can be counterproductive to
canines’ detection capabilities. Canines that cannot detect odors accurately
and consistently put the Nation at significant risk of prohibited items crossing
our borders. Therefore, CBP needs to ensure canine teams have a regularly
refreshed supply of training aids.

Finally, without updated policies and guidance, the Canine Program may not
be able to reliably inform management about where to best deploy canine
teams. Unclear guidance and outdated policies could lead to ineffective canine
teams. Ultimately, CBP cannot ensure its training approach and execution
allows its canine teams to accomplish their mission of detecting smuggling of
illegal narcotics, unreported currency, firearms, agriculture products, and
humans into the country at and between ports of entry as effectively as
possible.

                            Recommendations

Recommendation 1: We recommend the Office of Training and
Development Assistant Commissioner develop a comprehensive
assessment of the realignment of the Canine Program to ensure
implementation according to the Office of Training and Development’s
training standards. The assessment should:
   • ensure the training curriculum aligns with component policies, strategic
       plans, and if applicable, specific Canine Program strategic plans; and
   • evaluate post-graduation performance measures to validate efficiency
       and effectiveness of the component specific objectives and curriculum to
       demonstrate continual improvement in the canine training program.



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Recommendation 2: We recommend the U.S. Border Patrol Chief and
Office of Field Operations Executive Assistant Commissioner ensure the
Canine Program has enough certified canine instructors and adequate
training aids to provide proficiency training for canines after they are
deployed. This should include:
   • implementing a process to ensure sufficient staff are available to provide
       all training needs to U.S. Border Patrol and the Office of Field Operations
       canine teams; and
   • creating a systemic schedule and plan for pseudo and actual narcotic
       replacement for every U.S. Border Patrol sector and Office of Field
       Operations field office within the time recommended by the Laboratories
       and Scientific Services Directorate. (See Recommendation 3.)

Recommendation 3: We recommend the Executive Director of the
Laboratories and Scientific Services Directorate conduct a study to determine
the appropriate time for replacement of pseudo and actual narcotics to limit
the constant expiration of these training aids. Pseudo and actual narcotic
replacement cycles should be updated according to the results of the
Laboratories and Scientific Services Directorate study.

Recommendation 4: We recommend the U.S. Border Patrol Associate
Chief of Law Enforcement Operations and Office of Field Operations
Director of Tactical Operations update the Canine Program policies to
provide adequate oversight to ensure program needs are being met. The
policies should include:
    • record retention timelines for all training documents to be
       consistent with the CBP Records General Schedule or provide
       adequate documentation on retention policies after consultation
       with record retention personnel to determine the appropriate
       approach;
    • a systematic schedule and plan for pseudo and actual narcotic
       training aids (see Recommendation 2.); and
    • development of standard operating policies, procedures, and
       quality assurance measures for use of the Canine Tracking
       System.

                  CBP Response and OIG Analysis

CBP concurred with all four of our recommendations and is currently
taking actions to address them. Appendix B contains a copy of CBP’s
management comments in their entirety. CBP also provided technical

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comments and suggested revisions to our report in a separate document.
We reviewed the technical comments and made changes to the report
where appropriate. We consider recommendations 1, 2, and 3 resolved
and open. We consider recommendation 4 unresolved and open. A
summary of CBP’s responses and our analysis follows.

CBP Response to Recommendation 1: CBP concurred with the
recommendation. The Border Patrol and OFO will provide applicable
policies and strategic planning documents to OTD. Additionally, Border
Patrol and the OFO NCP will assist OTD with post-graduation
performance measures to validate efficiency and effectiveness of
component-specific objectives and continued improvement of the canine
training program. Estimated Completion Date (ECD): October 31, 2021.

OIG Analysis of CBP Comments: OTD has taken steps to satisfy the
intent of this recommendation with the assistance of Border Patrol and
the OFO NCP. We consider this recommendation resolved, but it will
remain open until OTD has provided documentation to support that all
recommendation actions are completed.

CBP Response to Recommendation 2: CBP concurred with the
recommendation. Border Patrol officials asserted their 471 canine
instructors are capable of providing the required training and
accompanying documentation. Border Patrol will improve applicable
training documentation and processes to include adding the instructor-to-
student ratio of 1:5; standardizing the training aid acquisition,
establishing an automatic training aid replenishment system; and
coordinating with LSSD on courses of action.

Separately, OFO will implement a process to ensure sufficient staff are
available to provide oversight of field canine training and will establish
procedures and a mechanism for regular training aid replacement within
the prescribed timeframes establish by LSSD. ECD: October 31, 2021.

OIG Analysis of CBP Comments: Border Patrol and the OFO NCP are
taking action to ensure sufficient certified instructors are available to
provide proficiency and maintenance training. In addition, Border Patrol
and OFO have committed to establishing procedures and a mechanism to
replenish training aids within the timeframes established through
collaboration with LSSD. We consider this recommendation resolved, but


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it will remain open until Border Patrol and OFO provide documentation to
support that all planned corrective actions are completed.

CBP Response to Recommendation 3: CBP concurs with the
recommendation. LSSD will work with Border Patrol, OFO, and OTD
canine components to collect and replace training aids that are nearing,
or past, their recommended replacement dates. LSSD will create a
standard operating procedure that outlines the actions needed for this
study and begin collection of training aids by January 31, 2021. LSSD
will perform chemical testing on those collected aids to determine whether
noticeable changes are present that may be detrimental to the aids’
effectiveness. By June 30, 2021, LSSD anticipates completing analysis
and assessment. LSSD will update policies and procedures with training
aid lifecycles based on scientific results, risk-minimization, and
practicality with the CBP canine components. ECD: September 30, 2021.

OIG Analysis of CBP Comments: The steps outlined by LSSD satisfy the
intent of this recommendation. We consider this recommendation
resolved, but it will remain open until LSSD provides documentation to
support that all planned corrective actions are complete.

CBP Response to Recommendation 4: CBP concurred with the
recommendation. Border Patrol and OFO will collaborate on specific
policies that define the appropriate retention timeframe for Border Patrol
and OFO canine documents, and will collaborate with LSSD to establish a
narcotic replacement standard operating procedure. Border Patrol will
establish policies for the use of the Canine Tracking System.

The OFO NCP will update policies to ensure adequate oversight and
program needs are met, to include appropriate records retention in
accordance with the agency records management plan.
ECD: October 31, 2021.

OIG Analysis of CBP Comments: Both Border Patrol and OFO have
taken steps to satisfy the intent of this recommendation. However, OFO's
corrective action does not establish policies for consistent use of the
Canine Tracking System. We consider this recommendation unresolved
and open. It will remain open until OFO clarifies how it will meet all
facets of the recommendation and both Border Patrol and OFO provide
documentation to support that all elements of this recommendation have
been implemented.

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Appendix A
Objective, Scope, and Methodology

The Department of Homeland Security Office of Inspector General was
established by the Homeland Security Act of 2002 (Public Law 107−296) by
amendment to the Inspector General Act of 1978.

We conducted this audit to determine to what extent CBP’s canine training
approach and execution support the Canine Program mission. To achieve our
audit objective, we:

   •   reviewed the policies, procedures, handbooks, directives, training
       curriculum, memoranda, and muster documents related to CBP’s Canine
       Program and academy;
   •   interviewed CBP Headquarter officials from Border Patrol Law
       Enforcement Operations, OFO’s Tactical Operations and Agriculture
       Program Trade and Liaison, and OTD to gain an understanding of the
       Canine Program;
   •   interviewed CBP officials (canine supervisors, advisors, certified canine
       instructors, handlers) in the field from Border Patrol, OFO, and OTD to
       gain an understanding of the Canine Program;
   •   observed the initial training course and interviewed officials, supervisors,
       and instructors at CCEP, CCFR, and the National Detector Dog Training
       Center to gain an understanding of their roles and responsibilities and
       how training and certification tests are conducted;
   •   reviewed the memorandum of understanding among CBP
       subcomponents (LSSD, Border Patrol, OFO, and OTD) relating to actual
       narcotic training aids;
   •   observed maintenance training, task-related training, and non-
       task-related training in the field to gain an understanding of the
       proficiency training and use of the performance standards score sheet;
       and
   •   interviewed LSSD officials from Headquarters and the Houston
       Laboratory to gain an understanding of their role and responsibilities
       relating to actual narcotic training aids for canine teams.

We obtained lists of all CBP canine teams deployed throughout the United
States. We judgmentally selected air and land POEs and stations along the
southern and northern borders to conduct site visits. Additionally, we
developed a data collection instrument to document when and what training
aids (pseudo and actual narcotic) canine teams used, and observed how


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training aids were stored and maintained. We conducted site visits to certain
Border Patrol Stations and POEs within the following locations:
    • Laredo Field Office (Laredo POE)
    • Laredo Sector (Laredo North and Hebbronville Border Patrol Stations)
    • Tucson Field Office (Nogales and Douglas POE)
    • Tucson Sector (Border Patrol Tucson Sector Canine Unit and I19 Border
       Patrol Checkpoint)
    • Seattle Field Office (Seattle-Tacoma International Airport and Blaine
       POE)
    • Blaine Sector (Bellingham Border Patrol Station)
    • Atlanta Field Office (Hartsfield-Jackson International Airport)
    • El Paso Field Office (El Paso and Santa Teresa POE)
    • El Paso Sector (Ysleta Border Patrol Station and El Paso Canine Facility)

We assessed the reliability of CBP’s K9TS system by verifying documents such
as team certifications and veterinarian records from CBP’s physical canine
teams hard copy file. We obtained 3 months of OFO canine team seizure and
utilization reports to compare them to the data stored in K9TS. We requested
system standard operating procedures, and inquired with officials about access
and user controls and determined there are no procedures for users or data
validation. We performed limited data reliability testing. CBP components are
not consistently and accurately inputting data, such as seizure data, into
K9TS, which limits an adequate and comparative assessment of the reliability
of K9TS data. Based on our review, we concluded the data was of
undetermined reliability, and we did not rely on the data from the system to
support findings, conclusions, or recommendations in this report.

We analyzed the CBP Canine Academy graduation data in comparison with the
National Training Plan. We assessed the reliability of the graduation data by:
(1) reviewing existing information about the data and the system that produced
them, (2) interviewing agency officials knowledgeable about the data, and (3)
observing agency officials pull requested documents from official system of
records to compare with data provided. We determined that the data was
sufficiently reliable for the purpose of this report.

We reviewed CBP’s internal controls over processes for the Canine Program by
observing control activities and comparing them to standard operating
procedures. However, we identified the Canine Program had outdated policies
and handbooks, pseudo and actual narcotic training aids past the
recommended replacement cycle, inconsistent proficiency training
documentation, and did not have operating procedures for K9TS. Therefore, we


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determined the controls were insufficient and not supported by standard
operating procedures.

We conducted this performance audit between June 2019 and May 2020
pursuant to the Inspector General Act of 1978, as amended, and according to
generally accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based upon our
audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based upon our audit objectives.




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Appendix B
CBP Comments to the Draft Report




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Appendix C
CBP Performance Standards Score Sheet (Form 1250)




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Appendix D
Office of Audits Major Contributors to This Report

Christine Haynes, Audit Director
Loretta Atkinson, Audit Manager
Renee Foote, Auditor-in-Charge
Clarence Brown, Auditor
Enrique Leal, Auditor
Severa Williams, Program Analyst
Hope Wright, Independent Referencer
Kevin Dolloson, Communications Analyst
Kelly Herberger, Supervisory Communications Analyst




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Appendix E
Report Distribution

Department of Homeland Security

Secretary
Deputy Secretary
Chief of Staff
Deputy Chiefs of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
Commissioner, Customs and Border Protection
CBP Component Liaison

Office of Management and Budget

Chief, Homeland Security Branch
DHS OIG Budget Examiner

Congress

Congressional Oversight and Appropriations Committees




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