ARCHIVED - Audit of the Telephone Reporting Program

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November 2013

Please note: The {*} asterisk denotes sections that have been removed because they contain sensitive information.

1.0 Introduction

The Agency is responsible for providing integrated border services that support national security and public safety priorities, and that facilitate the free flow of compliant persons and goods.

Under the Customs Act and the Immigration and Refugee Protection Act people entering Canada must report their arrival to the Canada Border Services Agency (the Agency). To enhance efficiency and traveller convenience, the Agency implemented a telephone reporting service in the 1990’s for airports, marinas, and a land border in remote locations. The Agency has over 600 telephone reporting sites. The telephone reporting service benefits both the traveller and the Agency.

Benefits to the traveller – Travellers do not have to go significantly out of their way to voluntarily comply with reporting requirements.

Benefits to the Agency – Designated telephone reporting sites are not regularly staffed by Agency border services officers (BSOs). Reports from travellers are taken by telephone, thereby minimizing Agency operating costs.

The telephone reporting service is a 24/7 operation and may be used by trusted travellers or the general public. The telephone reporting service is available to people entering Canada by:

  • private or corporate aircraft carrying 15 passengers/crew or less;
  • business aviation carrying 39 passengers/crew or less, arriving at one of the eight major airports;
  • empty cargo flights and medical evacuation flights;
  • private boats carrying 29 passengers/crew or less; and
  • snowmobiles or cars, generally arriving at marine reporting sites during winter months by travelling over ice.

Incoming call volumes and reported passages fluctuate according to month and time of day, with most calls received in the summer season due to the movement of private boats. In the fiscal year 2012-13, the Agency recorded 137,873 telephone reports. Each telephone report may involve multiple travellers and/or several phone calls to the Telephone Reporting Centre, due to the pre-arrival notification requirement for incoming aircraft and marine trusted traveller members (CANPASS and NEXUS).

In April 2013, the telephone reporting service was consolidated from four reporting centres to one, with the goal of improving efficiency.

2.0 Significance of the Audit

The goal of the telephone reporting service is to receive telephone reports and make referral decisions efficiently, while maintaining security and facilitating low risk travellers.

Primary and secondary examination controls are integral in detecting contraband and irregular migration, while facilitating the flow of compliant travellers. Weaknesses could result in security threats, or conversely in inefficiencies and traveller frustration, leading to client complaints.

The objective of this audit was to determine whether controls for the telephone reporting program were designed and operate as intended.

Specifically, whether:

  • primary examination processes were thorough and adequately recorded in systems;
  • secondary examination results were adequately captured in systems, and the results used to improve performance; and
  • client service standards were established and met.

3.0 Statement of Conformance

The audit conforms to the Internal Auditing Standards for the Government of Canada, as supported by the results of the quality assurance and improvement program. The audit approach and methodology followed the International Standards for the Professional Practice of Internal Auditing as defined by the Institute of Internal Auditors and the Internal Auditing Standards for the Government of Canada, as required by Treasury Board Internal Audit Policy.

4.0 Audit Opinion

The Agency has controls in place for the telephone reporting service to ensure program objectives are achieved, with opportunities for improvement.

Controls in the primary examination processes are generally adequate, {*}. Efficiencies in secondary examination referrals could improve client service and alleviate resource pressures. A performance measurement regime has not been developed to support the management and assessment of the program.

This results in a medium-low risk exposure for the Agency.

5.0 Key Findings

Primary examinations conducted on the phone by BSOs working at the Telephone Reporting Centre (TRC) were thorough for the most part, and the reported passages were captured in the Telephone Reporting Centre System (TRCS). The audit identified several opportunities for improvement related to the primary examination process, including: {*} during primary examination; updating reporting site information in the TRCS and ensuring its completeness; informing verification offices in a timely manner when referrals are made by TRC BSOs; and ensuring referral codes are used consistently.

The secondary verification process would benefit from being reviewed to ensure it operates efficiently and effectively. The current referral rate for secondary examination creates resource pressures and logistical challenges for the verification offices, as reporting sites may be distant or BSOs may not be readily available. Consequently, lower-risk referrals are often declined by the verification offices and/or the TRC. The high referral rate can be attributed to the random referral approach and other mandatory referral practices. There are opportunities for improving secondary referral practices, while respecting the Agency’s tolerance for risk.

Most secondary examination results were captured within the required 30 days of referral. However, the automated function, which updates outstanding referrals from ‘pending’ to ‘declined’, creates a risk that pending referrals may not be reviewed to determine if they were a security risk.

The Agency has not conducted a review of its designated reporting sites. Such a review could identify sites that are no longer appropriate or do not meet the Agency’s operational needs.

Since the telephone reporting program relies on travellers’ voluntary compliance, establishing and meeting service standards is key to drive service improvement, monitor performance and demonstrate the Agency’s commitment to service excellence. Client service standards for the primary and secondary examinations have not yet been established. Standards for the handling of client complaints are in place, and generally were met.

Performance measurement, a government wide expectation, has not been developed for the telephone reporting program, which limits management’s ability to continuously monitor and assess program results.

6.0 Sumary of Recommendations

The audit makes five recommendations to the Agency:

  • issue guidance on the selection of referral codes, and develop a process to {*};
  • update the reporting site information in TRCS and ensure verification offices are notified when referrals are made;
  • review referral practices;
  • review designated telephone reporting sites to ensure they continue to meet operational needs; and
  • develop client service standards and performance measures, and monitor performance.

7.0 Management Response

The Programs and Operations branches agree with the recommendations provided by this audit. The audit identifies effective practices during the primary examination process. The recommendations in this audit will further enhance the efficient risk-based approach to border management.

To strengthen controls for the Telephone Reporting Program, the Agency will develop a process to {*} by way of TRC reporting. We will also analyse internal practices and issue guidance on the use and acquittal of referral codes. A review of designated sites will be undertaken to ensure that operational needs are met, and client service standards and performance measures for processing of telephone calls in the TRC will be developed and monitored with a scheduled completion date of May 2014.

8.0 Audit Findings

8.1 Primary examinations

Audit Criteria:

  • Telephone Reporting Centre BSOs conduct thorough primary examinations (verbal interviews conducted by phone).
  • Reported passages (calls) are captured in the Telephone Reporting Centre System.
  • The referral reasons for a secondary examination are documented, adequately detailed and communicated to secondary examination offices.

Primary examination process

The primary examination process is initiated by a phone call to the Telephone Reporting Centre (TRC) from a traveller, or person in charge of a conveyance, who intends to enter or is entering Canada. Each traveller must provide his/her name, date of birth, citizenship and residency, and declare all goods he/she is importing to Canada, including controlled goods and currency and monetary instruments totalling $10,000 Canadian or more. This information is recorded in the TRCS. The Agency relies on the person in charge of the aircraft, boat or other vehicle to gather and provide this information, and to ensure all persons coming to Canada are in possession of valid travel documents required by legislation, such as passports and visas.

A review of 424 telephone reportsFootnote1, interviews with and observation of BSOs taking calls showed that BSOs conducted thorough primary examinations for the most part, actively offered service in both official languages, and properly captured reported passages in the TRCS.

However, there are gaps related to the TRC’s primary examination process. {*}

Depending on the outcome of the primary examination, travellers may be referred for secondary examination. In 2012-13, 15%Footnote2 of travellers were subject to an in-person secondary examination {*}. Hence, 85% of immigration admissibility decisions were made during the primary process and {*}.

Once a decision is made by the TRC BSO to refer a traveller, the secondary verification office is informed of the decision. We noted the following gaps in the referral process:

  • Reporting site information in the TRCS was out-of-date or incomplete. TRC BSOs spend time tracking down missing phone/fax numbers or make repetitive unanswered phone calls to the verification office. This reduces their time to take further incoming calls.
  • TRC BSOs were not notifying the verification offices of the referral decisions for incoming aircraft in advance of arrivals; rather, the TRC BSOs faxed the referrals and made notification calls after the aircraft arrived at the reporting site. Verification offices indicated that faxed referrals were sometimes missedFootnote3, or there was insufficient lead time to travel to distant reporting sites.
  • There was no written guidance on verification referral codes and TRC BSOs selected them inconsistently, compromising the Agency’s ability to analyze the program.

While controls in the primary examination process were in place and generally worked as intended, the robustness of the primary process would be improved by addressing the above gaps.

Recommendation 1:

The Vice-President of the Programs Branch, in consultation with the Operations Branch, should issue guidance on the selection of referral codes and develop a process to {*}.

Management Response

The Programs and Operations branches agree with this recommendation. The Agency will review the referral selection choices available in the TRCS. In addition, guidance to the TRC BSOs will be issued on the use of the referral code options. These measures will be implemented by May 2014.
{*}

Completion Date: May 2014

Recommendation 2:

The Vice-President of the Operations Branch should ensure the TRCS reporting site information is updated and verification offices are notified by the TRC in a timely manner when a referral for secondary examination is made.

Management Response

The Operations Branch agrees with this recommendation. Operations Branch will work with Programs Branch to update standard operating procedures to clearly indicate that TRC BSOs must immediately notify verification offices of a referral. An Operational Bulletin will then be sent by Operations Branch by October 2013 communicating the change in procedures for verification and acquittal notification. Operations Branch will also review and update the list of approved reporting sites in the TRCS. These updates will be completed by May 2014.

Completion Date: May 2014

8.2 Secondary examinations

Audit Criteria:

  • Referrals result in secondary examinations.
  • Secondary examination results are captured in the Telephone Reporting Centre System within 30 days of referral.
  • Secondary examination BSOs are provided with needed facilities.

Secondary examination process and practices

When the verification office receives a referral call from the TRC, a further assessment may be jointly conducted by the TRC BSO and the verification site BSO to determine whether to conduct the secondary examination. The assessment compares the risk to resources available and distance to the reporting site. Lower risk referrals, as determined by the TRC and the verification site BSOs, may be declinedFootnote4. If the referral is accepted, then two BSOs from the verification office are dispatched to the reporting site.

There are challenges in completing secondary examination referrals. In 2012-13, of the total of 137,873 telephone reports, 26,887 (19%) were referred. This level of referral creates logistical challenges and resource pressures for the Agency verification offices. Some reporting sites are distant from the verification offices, requiring extensive travel time by car and/or boat. In addition, verification resources may not be readily available, particularly if there is no lead time. Consequently, referrals were declined 39%Footnote5 of the time in 2012-13. This high level of referral can impact program efficiency. Even when referrals are declined, additional work is performed by the TRC BSO and the verification site BSO to further risk assess and document the decline in the TRCS.

The high referral rate can be attributed to the random referral approach and other mandatory referral practices, such as overseas arrivals, and entry date stamping of passports.

Random referrals

In 2012-13, 7,454 telephone reports (5.4%) were randomly referred, accounting for 28% of all referrals. Most (78%) random referrals were declined by the verification offices as they were considered lower risk. However, the decline of random referrals prevents the Agency from accurately identifying the compliance baseline. The program’s approach to random referrals would benefit from a review to ensure it is statistically sound, cost effective and aligned to the Agency’s tolerance for risk.

Overseas arrivals

Overseas arrivals refer to travellers arriving from countries other than the United States. The referral of overseas arrivals for secondary examination is not a requirement under the Customs Act. In 2011, overseas arrivals became a mandatory referral due to the risk of irregular migration (refugees) triggered by political instability in foreign countries. Over the past two years (April 2011 to March 2013) there were 6,325 completed referrals for overseas arrivals, which generated 80 enforcement actions (1.3%). None of the 80 enforcement actions involved refugee claimants. From a risk perspective, the enforcement rate for overseas referrals (1.3%) was lower than for arrivals from the United States (2.8%). The effectiveness of referring overseas arrivals as a control to mitigate the risk of irregular migration is not demonstrated by results.

Verification of identity documentation

The Immigration and Refugee Protection Regulations state the length of time a visitor (a temporary resident) is authorized for a stay in Canada begins on the day of entry. The entry date(s) of travellers reporting by telephone is recorded in the TRCS, along with their name and date of birth.

Citizenship and Immigration Canada provides some flexibility on entry date stamping of traveller passports issued by visa-exempt countries. However, the TRC refers all foreign nationalsFootnote6 (except United States citizens) for entry date stamping and examination of passports. This applies to both visa-exempt and visa-restricted countries. Despite this mandatory referral practice, the Agency verification offices are not able to conduct examination for all of these referrals. For example, in 2012-13, of 13,512 persons who should have been referred for passport verification and stamping, only 9,152 (68%) were examined.

The Agency has not reviewed the necessity in relation to risks of sending BSOs to entry date stamp passports issued by visa-exempt countries, considering the entry date is already recorded in the TRCS.

Other secondary referral practices that increase the referral rate

The audit noted other referral practices that may not be risk-based. This increases the referral rate and impacts Agency verification offices and the travelling public. For example:

  • Certain verification offices requested referral of all incoming conveyances/travellers reporting by telephone. The risk-based rationale was not always evident.
  • Processing of hunting rifles and currency should be handled over the telephone by the TRC, unless risk indicators suggest otherwise.
  • CANPASS Private Air/Boat and CANPASS Corporate Air enrollments were finalized through secondary examination upon first entry to Canada using the telephone reporting service, rather than being finalized at enrollment centres.
  • TRC BSOs may refer and notify the verification office without conducting a full risk assessmentFootnote7 to confirm or discount the need for referral.

While the consolidation of the TRC resulted in reduction of BSOs needed to handle incoming calls, secondary referral practices have not been examined from an efficiency and effectiveness perspective. There are opportunities for improving secondary referral practices, while respecting the Agency’s tolerance for risk.

Capture of secondary examination results

After a secondary examination is completed the results should be captured in the TRCS within 30 days and the referral status updated from ‘pending’ to ‘complete’. Most (97%) status updates and results entries were done within the 30 day period.

The audit review of a sample of outstanding requests older than 30 days determined that most ‘pending’ referrals were ‘declined’ (79%), but had not been updated in the TRCS. Each month the TRC extracts the Outstanding Verification Report which lists all pending referrals, and asks the verification offices to update their referrals. However, not all verification offices have access to the TRCS to further review or update the system.

Periodically, outstanding ‘pending’ referrals are system updated to ‘declined’ by an automated process. The problem with this automated process is that outstanding referrals may not be reviewed to determine whether they are a security risk.

Designated reporting sites

The Agency may designate sites as customs offices and may amend or cancel designationsFootnote8. The owner or operator of any airport, wharf or dock that receives conveyances arriving internationally, and which has been designated, shall provide, equip and maintain free of charge adequate buildings, accommodation or other facilities for the proper detention and examination of imported goods or for the proper search of persons by BSOsFootnote9.

According to the Regions, availability of facilities at designated reporting sites varied. While some telephone reporting sites had dedicated office space or an alternate option available, such as temporary use of airport or marina facilities, other sites did not.

As of September 2013, the Agency publically listed 441 marine sites and 207 airports designated for telephone reporting. However, not all sites are used by the public. For example, in 2012-13 the Agency received telephone reports from 392 marine sites. Reporting sites may be remote and rarely attended, hence the Agency may be unaware of their condition.

The designation of a reporting site may be removed if the site is no longer needed or if facilities are not appropriate or safe. The Agency has not reviewed telephone reporting sites to ensure they continue to meet Agency operational and client service needs.

Recommendation 3:

The Vice President of the Programs Branch, in consultation with the Operations Branch, should review referral practices to ensure they are consistent with an efficient risk-based approach to border management.

Management Response

The Programs and Operations branches agree with this recommendation. The TRC policy is to allow clients to report and be cleared over the telephone unless reasons exist to refer for a secondary examination. The Agency will review the specific referral practices and issue direction to BSOs as necessary. The Agency will also issue a reminder to acquit outstanding referrals in the TRCS in a timely manner by October 2013.

The Agency will review the accessibility of the TRCS at verification offices and provide access to the locations that require it by April 2014.

The Agency is reviewing the random referral rates in the TRCS. The suitable rates for the TRC program will be established and programmed into the system by November 2013.

Completion Date: April 2014

Recommendation 4:

The Vice President of the Operations Branch should conduct a review of designated telephone reporting sites to ensure these continue to meet Agency operational needs.

Management Response

The Operations Branch agrees with this recommendation. The Operations Branch will conduct a review of all designated reporting sites to ensure that operational requirements are being met. As a first step, a review will be conducted on the current inventory of telephone reporting sites to determine if they meet program requirements by December 2013. Secondly, volume statistics will be measured on the remaining sites to determine if any should be de-designated based on minimal volumes and/or proximity to other designated sites. This will be concluded by February 2014.

The Operations Branch will carry out a revalidation of the remaining sites by April 2014 to validate that they meet operational needs. Owner/operators of the sites that do not meet Agency operational requirements will be contacted and informed by May 2014 of what is required for them to retain their reporting site designation. If they do not address shortcomings, the sites will be de-designated.

Completion Date: May 2014

8.3 Performance

Audit Criteria:

  • Performance and service standards for the telephone reporting examination processes have been established and are met.
  • Established service standards for the handling of telephone reporting client complaints are met.
  • Performance is monitored, measured and reported upwards.

Service standards are an important element of service management excellence; they help clarify expectations for clients and employees, enable performance management, and support client satisfaction.Footnote10 Since the telephone reporting program relies on clients’ voluntary compliance and reporting, establishing and meeting service standards is integral to drive service improvement, monitor performance and demonstrate the Agency’s commitment to service excellence.

The Agency’s Enhanced Complaint Mechanism is centralized in the Recourse Directorate. Service standards for the handling of client complaints were established and for complaints related to telephone reporting were generally met.

However, client service standards have not been established for primary or secondary examinations, such as call-in wait times or reporting site secondary examination wait times. Establishing and publishing client service standards, such as wait times, would help manage public expectations and provide performance targets for Agency operations.

Performance measurement is a government-wide expectation, and is important for continuously monitoring and assessing the results and efficiency of programs as well as making informed decisions and taking appropriate, timely action with respect to programsFootnote11.

Management at the TRC regularly monitored the work performance of BSOs working at the centre. Statistics, such as call volumes, were reported upwards regionally.

However, program management at Headquarters has not developed a performance measurement framework for the telephone reporting program, to assess whether program goals were being achieved.

Recommendation 5:

The Vice President of the Programs Branch, in consultation with the Operations Branch, should develop client service standards and performance measures for the telephone reporting program, and monitor these for performance.

Management Response

The Programs and Operations branches agree with this recommendation. The Agency will review technical capabilities of monitoring the telephone queue to the TRC and establish a service standard for callers to reach a TRC BSO when reporting to the Agency by April 2014.

Completion Date: April 2014

Appendix A – About the Audit

Audit Objectives and Scope

The objective of this audit was to determine whether controls for the telephone reporting program were designed and operate effectively.

Specifically:

  • primary examination processes were thorough and adequately recorded in systems;
  • secondary examination results were adequately captured in systems, and the results used to improve performance; and
  • client service standards were established and met.

The audit scope covered all activities of the telephone reporting program, including Headquarters, the Hamilton TRC and verification offices. All Regions were surveyed by questionnaire, and the audit team visited the TRC located in Hamilton, Greater Toronto Area Region in February 2013.

Issues related to the deposit of revenues and the changes resulting from the Deficit Reduction Action Plan were excluded from this audit.

Also excluded from the audit was non-reported entry to Canada. Border management in Canada is a shared responsibility, as negotiated between the Agency and the Royal Canadian Mounted Police (RCMP). The division of responsibilities are laid out in the 1991 Memorandum of Understanding between the two organizations, Department of National Revenue Division of Investigative and Enforcement Responsibilities, and are further clarified in the 2008 Canada Border Services Agency and the Royal Canadian Mounted Police Joint Policy.

  • The Agency has primary responsibility for designated reporting sites, meaning anned or unmanned ports of entry.
  • The RCMP has primary responsibility for patrolling the unmanned borders falling between Agency designated ports of entry.

Risk Assessment

The risk assessment conducted during the planning phase identified the following key risk areas:

  • Traveller stakeholder expectations for timely, courteous, consistent and professional service may not be met, or unnecessary referrals for secondary examination may result in wasted time and resources, for both the traveller and the Agency; in turn this could generate client complaints, future non-compliance with reporting requirements, negative media coverage or political pressure.
  • Distance, resource, facility or equipment constraints may make it difficult to meet and examine referred travellers, or reported passages and referrals may not be adequately captured in systems; in turn compromising Agency efforts to analyze and improve on performance and to better manage border programs.

Approach

The following approach was used:

  • reviewed legislation, policies, procedures, guidelines, reports, performance information, and other relevant documentation;
  • analyzed and compared data and information from various sources and systems, such as the TRCS;
  • sampled reports and examinations from the TRCS; reviewed and assessed completeness of records;
  • conducted interviews with, and surveyed stakeholders; and
  • visited the Hamilton TRC to walkthrough and observe processes.

Audit Criteria

The following audit lines of enquiry and criteria were selected:

Lines of Enquiry Audit Criteria
Primary Examinations

1.1 TRC BSOs conduct thorough primary examinations (verbal interviews conducted by phone).

1.2 Reported passages (calls) are captured in the TRCS.

1.3 The referral reasons for a secondary examination are documented, adequately detailed and communicated to secondary examination offices.

Secondary Examinations

2.1 Referrals result in secondary examinations.

2.2 Secondary examination results are captured in the TRCS within 30 days of referral.

2.3 Secondary examination BSOs are provided with needed facilities.

Performance

3.1 Performance and service standards for the telephone reporting examination processes have been established and are met.

3.2 Established service standards for the handling of telephone reporting client complaints are met.

3.3 Performance is monitored, measured and reported upwards.

Appendix B – Acronyms

Agency
Canada Border Services Agency
BSO
Border Services Officer
CANPASS
A Canadian trusted traveller program
NEXUS
A trusted traveller program, run jointly with the United States
RCMP
Royal Canadian Mounted Police
TRC
Telephone Reporting Centre
TRCS
Telephone Reporting Centre System

Footnotes

Footnote 1

A telephone report refers to a call received by the TRC and recorded in the TRCS, covering the entry of persons to Canada. A single telephone report may cover multiple travellers.

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Footnote 2

Of 442,305 travellers who reported by telephone, 66,746 were the subjects of an in-person secondary examination.

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Footnote 3

Faxes may not be successfully transmitted. As well, verification offices commented that occasionally a fax requesting a secondary examination was found the next morning on the fax machine, after the plane had arrived the evening or night before.

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Footnote 4

A declined referral means the verification office and/or TRC declined to conduct the examination, and the traveller(s) were released without the in-person secondary examination. A cancelled referral means the traveller, or the person in charge of a conveyance, called back stating they would not be entering Canada, hence the telephone report is cancelled in the TRCS.

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Footnote 5

Of 26,887 referrals, 10,549 were declined.

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Footnote 6

A foreign national means a person who is not a Canadian citizen or a permanent resident of Canada, and includes a stateless person.

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Footnote 7

The TRCS is electronically linked to enforcement databases. Potential matches are highlighted in the TRCS, as the BSOs process the calls. However, the BSOs need to review the information in the enforcement databases to confirm the validity of the match and to determine if the information is still current.

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Footnote 8

Customs Act, section 5.

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Footnote 9

Customs Act, section 6.

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Footnote 10

Guideline on Service Standards, Treasury Board of Canada Secretariat.

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Footnote 11

Supporting Effective Evaluations: A Guide to Developing Performance Measurement Strategies, Treasury Board of Canada Secretariat.

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