Review of the Bureau of Alcohol, Tobacco, Firearms and Explosives’
Violent Crime Impact Team Initiative

Evaluation and Inspections Report I-2006-005
May 2006
Office of the Inspector General

Appendix V
OIG’S Analysis of ATF’s Response

On April 10, 2006, the Office of the Inspector General (OIG) provided a draft of this report to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) with a request for written comments. We asked that ATF indicate its concurrence or non-concurrence with each of the five recommendations, describe the actions taken or planned in response to the recommendations, and provide the completion dates of those actions. On April 18, 2006, the Assistant Inspector General for Evaluation and Inspections and the review team met with senior ATF officials to discuss the report’s findings.

ATF responded to the OIG in a memorandum dated May 1, 2006. ATF concurred with all five of our recommendations and provided a description of the actions it plans to take in implementing the recommendations. The actions that ATF has taken and plans to take are partially responsive to our recommendations.

Although ATF concurred with each of the report’s five recommendations, it disagreed with some of the findings. ATF stated that its “primary disagreement was founded on the fact that the [Violent Crime Impact Team (VCIT)] program was a 6-month pilot program actively under review by ATF at the time of the OIG review.” ATF contended that the OIG’s criticisms regarding the implementation of a pilot program were premature. ATF also expressed concerns related to how the OIG assessed two primary issues:  performance measurement and program implementation.


The OIG disagrees with ATF’s foundational argument that it was premature for the OIG to review the VCIT program. First, on multiple occasions in early 2005, ATF and senior Department officials publicly stated that the VCIT initiative had been a success. For example, on March 17, 2005, 11 months after the program began, the ATF Director announced that the “indications are that VCIT is working.... We are acting on these indications of [VCIT] success:  we’re expanding the VCIT program to five cities immediately and to an additional five later this year.” Second, contrary to ATF’s contention that the program was “under design” when the OIG conducted its review, the VCIT Strategy that ATF issued in June 2004 has remained essentially the same, as documented in ATF’s January 2006 Violent Crime Impact Teams:  Best Practices report. Given that ATF and Department officials believed that the program was sufficiently mature to report results and request funding for expansion, and that the program design has not changed significantly since its inception, ATF’s contention that it was premature for the OIG to examine the program is not persuasive.

We discuss below other concerns raised by ATF regarding our assessment of the VCIT initiative.

Performance Measurement Findings

ATF contended that the OIG did not recognize that the VCIT initiative had contributed significantly to the decline in homicides and overall violent crime in VCIT cities. ATF discussed its contributions to reducing violent crime through its participation in Project Safe Neighborhoods and VCIT. ATF also provided data that it had not provided during our review to support its claim of success. ATF noted that it is difficult to measure law enforcement success in preventing crime, but attempted to support its assertions of VCIT’s success by comparing the Federal Bureau of Investigation’s (FBI) Uniform Crime Reports (UCR) homicide data from 2001 through 2004 for the 15 pilot VCIT cities versus all other U.S. cities. According to the data that ATF provided, homicides declined 8.2 percent in VCIT cities from 2003 to 2004, but declined only 1.5 percent in U.S. cities without VCITs during that period. ATF concluded that the greater reduction in homicides in VCIT cities was evidence of the VCIT initiative’s effectiveness.

The OIG disagrees that ATF’s comparison of FBI UCR data on total homicides in the 15 VCIT pilot cities with total homicides in all other U.S. cities that participate in the UCR demonstrates VCIT’s success. First, the 15 VCIT pilot cities were selected because they were experiencing high rates of homicide. In contrast, the comparison group of non-VCIT cities included cities where homicide rates were variously increasing, decreasing, and static. Statistically, the trend in the homicide rate for this broad and diverse group of cities will necessarily fluctuate less than that for the smaller group of high-crime VCIT cities, regardless of any new law enforcement operation. Therefore, we would expect to see more change in homicide rates in VCIT cities, regardless of whether the VCIT program had an impact.

Second, in comparing changes in the number of homicides in VCIT pilot cities and in non-VCIT cities, ATF assumed that the VCITs were the only significant difference in anti-violent crime activities between the two groups of cities. In fact, U.S. cities have implemented a broad variety of strategies to reduce homicides and other violent crime. Because cities also differ in other characteristics related to crime, the FBI offers the following cautionary note with regard to using its UCR data for cross-city comparisons:

Because many of the variables that influence crime in a particular town, city, county, state or region, the UCR Program does not encourage the comparison. Some of those variables include, but are not limited to population density and the degree of urbanization, modes of transportation and highway systems, economic conditions and citizens’ attitudes toward crime.

Third, only a small portion of the reduction in homicides in the VCIT pilot cities from 2003 to 2004 could be attributable to local VCIT operations because VCITs:  (1) operated in target areas within cities rather than city-wide, (2) did not focus on homicides resulting from domestic violence, and (3) did not begin operating until June 2004, almost half way through the year. Specifically:

  • ATF could not determine if reductions in city-wide homicides may have been due, in part, to a reduction in homicides in the VCIT target areas because ATF did not have target area data for more than half (8 of 15) of the pilot cities. For the 7 cities where ATF had target area data on homicides committed with firearms, it did not determine if the target area accounted for a significant portion of the total number of homicides in the city. That analysis is essential for ATF to show that a reduction in homicides committed in the target area could have had a significant impact on the city-wide homicide rate.

  • Using the total number of a city’s homicides as a measure of VCIT effectiveness is inappropriate because a significant portion of homicides result from domestic violence and VCITs were not designed to focus on domestic violence.

  • Because local VCIT operations were not initiated until June 2004, it is highly improbable that the effect of those operations would be reflected in 2004 UCR data. The VCITs required, at a minimum, several months to identify and arrest targeted individuals in the target area and remove them from the target area pending prosecution. As a result, VCITs could not have begun to affect crime rates until the last few months of 2004.

We therefore concluded that the reductions indicated by the UCR data of total city-wide homicides from 2003 to 2004 among the 15 pilot cities cannot be attributed to the local VCIT operations. Rather than using city-wide UCR data, local police data on homicides for the VCIT target area for several years before and after a VCIT was implemented are required to determine if a relationship exists between a local VCIT operation and a change in that area’s homicide rate. The particular type of homicide data to be used for this analysis (e.g., homicides, homicides committed with firearms, or non-domestic homicides) would depend on the specific focus of the VCIT operation.

In sum, the available data were not sufficient to support ATF’s conclusions regarding the success of the initiative. While the OIG recognizes that it is difficult to measure the effectiveness of crime prevention efforts, the collection and analysis of appropriate data are essential to provide accurate information to decision-makers who allocate federal funds.

Finally, in its response to the report’s performance measurement findings, ATF stated that “the OIG should not base any tables or analysis on unvalidated figures (see Table 2 in Executive Digest of the OIG review, Figure 4, Table 7 and Table 8 in the OIG review).”31 ATF said that its data on homicides with firearms undergoes a thorough validation with the local police departments and that none of the violent firearms crime data the OIG had referenced had been verified or validated. ATF requested that the OIG validate these numbers it had provided with the local police departments.

The OIG included an analysis of these data to illustrate how the use of more appropriate data could be used for determining the effectiveness of VCITs. However, we have included a footnote for Table 2 in the Executive Digest and Table 7 in the body of the report indicating that the original source of the data was local police departments.

Program Implementation Findings

In its response, ATF stated that the goal of the VCIT pilot was to determine if ATF could affect the number of homicides in specific high-crime areas and identify which elements of the Strategy were effective and should be included in future implementation plans. ATF argued that the OIG prematurely reviewed the VCIT initiative in a way it would have reviewed a government program that had been in operation for many years. ATF further stated that the VCIT Strategy was designed to give local ATF offices a framework so that they could model their implementation of VCIT around the aspects of the program that actually worked in their areas. ATF also took issue with the OIG’s selection of five key elements that the OIG “believed to be the most important to the implementation of the VCIT strategy” and instead said the OIG should have conducted its evaluation based on six objectives in ATF’s Strategy.

The OIG disagrees with ATF on most of those points. First, in referring to our report, ATF states, “We agree that VCIT does prevent crime....” The OIG actually concluded that while the VCIT Strategy itself may be an effective tool to reduce violent crime in target areas, and the OIG also concluded that ATF could not yet determine the effectiveness of the Strategy.

Second, as discussed previously, we initiated this review after ATF officials announced that the VCIT pilot was successful and that they were planning to expand the initiative based on the pilot’s success. The pilot took place from June through November 2004. At the time our review began, ATF had almost a full year of VCIT operations for us to review. By the time the OIG’s fieldwork was completed, VCIT had been operating in the pilot cities for approximately 18 months.

Third, in our report, we stated that the five key elements we selected were essential to implementing the VCIT initiative and that, collectively, the key elements differentiated VCIT from traditional ATF law enforcement operations. We further explained that we selected these five key elements because the Office of the Deputy Attorney General (ODAG) and ATF officials consistently highlighted them as essential to implementing the VCIT strategy.

Regardless of whether the VCIT Strategy is considered to have five key elements or six objectives, the OIG agrees with ATF’s statement that the goal of the pilot was to determine which elements of the strategy were successful and should be included in future implementation. The OIG also recognizes that flexibility is essential to allow the program to be tailored to local conditions. However, the OIG found that, rather than flexibly implementing the VCIT Strategy, some local VCIT operations did not implement the Strategy’s essential elements. As a result, ATF did not effectively test the Strategy and cannot support its claim that the VCIT initiative was effective. For example, we found that seven VCITs using a “worst of the worst” list of targeted individuals did not keep it updated, while six did not use such a list at all. We also found that only one VCIT included representatives from the Drug Enforcement Administration (DEA), FBI, and U.S. Marshals Service (USMS), while four VCITs had no representatives from the DEA, FBI, or USMS. Further, during our site visits, we found that none of those five VCITs actively participated in community outreach.

Specific Findings

  1. Target Small Geographic Areas

  2. ATF stated that the use of the term “small” to characterize the intended size of target areas for the VCIT initiative was inappropriate and that the OIG inaccurately described site-specific details in describing VCIT operations in several cities. ATF also stated:

    While ATF agrees that some cities may have initially selected a larger area than might be ideal, and concurs that a small area may be a reasonable recommendation, to represent this as a ‘key element’ in the implementation of the pilot misrepresents the strategy.

    Specifically, ATF contended that the OIG inaccurately described the VCIT target areas as city-wide for Chattanooga and Miami.

    Although ATF did not use the adjective “small” in reference to target areas in the VCIT Strategy, references in the Strategy and interviews with ODAG and ATF officials led us to conclude that a target area was clearly intended to be a small geographical area within a city. In the VCIT Strategy, ATF used the following terms to describe the target areas:  “community,” “neighborhood,” “geographic areas within cities,” and “police districts.” The VCIT Strategy also recommended assigning four Special Agents and one supervisory agent to a VCIT target area, which clearly indicated that the target area was to be of limited geographic size. Further, in announcing the VCIT initiative pilot in 15 cities, ATF officials frequently said that the VCITs’ efforts would focus on “hot spots” of violent crime. For example, one ATF official stated, “VCIT is a laser-like approach focusing on hot spots of violence.”

    ATF’s contention that the OIG incorrectly described the size of the target areas for the Chattanooga and Miami VCITs is incorrect. In describing the areas within which the VCIT operated, the Chattanooga VCIT Coordinator stated in responding to our survey that during the VCIT’s first 12 months it operated throughout the city-county area and subsequently reduced the target area to the city.32 Similarly, in response to our survey, the Miami VCIT Coordinator reported that the Miami VCIT operated within the whole of Miami-Dade County and that the VCIT operated in five principal areas within the county that warranted specific attention.

  3. Target the Worst Violent Offenders

  4. ATF’s response faults the OIG for not including the reasons why six of the VCITs did not use a “worst of the worst” list.

    Our analysis of the VCITs’ targeting the worst offenders was designed to evaluate whether ATF implemented and measured the impact of this element. The fact that six VCITs did not implement this key element of the VCIT initiative prevented ATF from measuring its effectiveness at those sites, regardless of the reasons for not implementing it. Furthermore, we also found that seven other VCITs did not keep their lists of targeted offenders current, which diminished the usefulness of any attempt to measure the impact of this element in those cities. Overall, 13 of 19 VCIT cities did not implement fully this key element of the VCIT strategy.

    The OIG found that VCITs might not have focused on targeted offenders because these offenders represent only about 20 percent of VCIT arrests. The VCIT initiative was designed to focus on the “worst of the worst” in areas with a high volume of violent crime. The fact that only one in five arrestees was classified as a “targeted individual” appeared to be a low ratio. Moreover, over a third of the VCITs arrested less than half of the individuals they targeted while arresting many non-targeted individuals, which indicates that these VCITs did not sufficiently focus on targeted individuals. We agree that arresting additional alleged offenders is positive, but ATF designed the VCITs to focus primarily on the worst of the worst.

    The OIG also disagrees with ATF’s statement that the OIG does not understand the term “worst of the worst” criminals in a community. We recognized that the definition of the worst of the worst to be targeted across VCITs would likely differ, as each VCIT should have tailored the definition to fit local conditions.33 Yet, we concluded that to effectively implement and evaluate the results of this element of the VCIT Strategy, it is necessary to define which offenders will be targeted, develop a list of targeted individuals for each VCIT, and track VCIT arrest data for targeted and non-targeted individuals. Without such information, ATF cannot determine whether a VCIT tailored this element to its local conditions, effectively implemented the element, or obtained the desired results.

  5. Build Effective Working Relationships with Community Leaders

  6. ATF disagreed with our finding that VCITs did not incorporate community outreach into their strategies and asserted that each of the five cities that the OIG identified as not participating in community outreach either had a direct community outreach or a complementary outreach mechanism in place.

    The information the OIG developed during our site visits does not support ATF’s contention that community outreach was incorporated into these cities’ VCIT strategies. During our site visit in Tampa, for example, several local ATF officials told us that the VCIT was not involved in any community outreach activities. Only one local official indicated that there had been some community involvement when the VCIT was initiated. The officials indicated that ATF participated in other programs in Tampa, including Drug-Free Kids and the Great American Teach-In, but these were independent of the VCIT initiative. Similarly, during our visit to Tucson, local ATF officials reported that the VCIT did not participate in community activities. However, we noted in our report that the Tucson Police Department told us that it had mentioned the VCIT at community meetings.

    Further, none of the three examples of ATF community outreach in Tampa and Tucson address the VCIT Strategy objective to “work with community leaders to cultivate solid and sustained commitment between the residents of the community and law enforcement authorities to ensure positive results.” In their responses to our survey, none of the 19 VCIT Coordinators reported community activities that addressed the objective of working with community leaders. Finally, during our site visits, we found no instance, and ATF’s response offered no examples, of a VCIT reaching out “to social service agencies, nonprofit community assistance agencies, faith-based groups, schools, and private businesses to promote a comprehensive and coordinated community action plan to deal with gang suppression, intervention, and prevention.” Consequently, we concluded that our description of the VCIT outreach activity was full and accurate.

  7. Utilized ATF’s Investigative Technology Resources

  8. ATF stated that the OIG mischaracterized the VCITs’ use of technology resources by stating that they did not consistently use the National Tracing Center (NTC), National Integrated Ballistics Information Network (NIBIN), and Crime Gun Analysis Branch (CGAB) services. ATF stated that the OIG’s survey results revealed extensive use of the technologies. In its response, ATF also faults the Executive Digest of our report for not fully presenting much of the site-specific detail and not incorporating the full results of the review contained in the body of the report.

    Although the OIG acknowledges that, in response to our survey, most of the VCITs reported that they use these technologies, we do not agree with ATF’s contention that the data rebut our finding that the VCITs used the technologies inconsistently. For example, with respect to the NTC usage, our report states, “Overall, during the 1-year period following the implementation of the initial 15 VCITs, NTC data showed a 15-percent increase in the number of trace requests it received from those cities. However, because the city-wide NTC data is not specific to the VCIT target areas, the changes may not be attributable to VCIT operations. We also noted that while 11 of the cities increased their NTC usage, 4 submitted fewer trace requests.”34 Further, over half of the VCIT cities made fewer submissions to the NIBIN after ATF implemented local VCIT operations.

  9. Work in Partnership with Other Department Law Enforcement Components

  10. ATF stated that its greatest concern regarding the OIG’s finding on the VCITs’ working in partnership with other Department law enforcement components is that the OIG measured this element by the participation levels of the other components. ATF also stated that ATF is concerned that local law enforcement participation is understated in the report.

    The OIG disagrees with ATF’s contention that partnerships with other Department components should not be used to measure law enforcement coordination because it is not consistent with the VCIT Strategy. While ATF was assigned to be the lead agency, the VCIT initiative was intended to involve the Department’s other law enforcement components. This is reflected in the VCIT Strategy and in virtually every Department press release and speech by ATF and Department officials addressing the VCIT program.

    Although we believed ATF’s argument regarding federal partners to be unpersuasive, we added to the report older data on law enforcement partnerships during the pilot period. The report now includes Department component partner data obtained through the VCIT Coordinator Survey for both the pilot period (June 2004 through November 2004) and for September 2005.

    In addition, the OIG agrees with ATF that local law enforcement agencies are a key resource for VCIT in achieving many of the program’s objectives, and we included local and state law enforcement partners in our descriptions of the VCITs we visited. These groups play a key role in identifying appropriate target areas, identifying and arresting the “worst of the worst” violent offenders in those areas, and in identifying and reaching out to community groups to gain support and cooperation.


Recommendation 1:   Establish specific operational guidelines for VCIT implementation, and provide training based on these guidelines for ATF Special Agents in Charge and VCIT Coordinators on tailoring the VCIT initiative to local crime problems.

Status:  Resolved – Open

Summary of ATF’s Response:  ATF concurred with this recommendation. In addition, ATF reported that it had completed an in‑depth assessment of the 6-month pilot implementation of VCIT, which included meetings with all VCIT Coordinators in August 2005. During these meetings, the VCIT Coordinators articulated their VCIT teams’ strategies. ATF provided the Coordinators with preliminary copies of a report, Violent Crime Impact Teams:  Best Practices, and ATF personnel made presentations on the overall VCIT Strategy, reporting requirements, the NIBIN, and operational guidelines for VCIT implementation.

ATF also responded that the 10 best practices contained in the Best Practices report “have been established as the basic tenets for all VCIT cities.” ATF stated that its “executive leadership” and ODAG “senior staff” have met with senior representatives from all partner agencies prior to each VCIT implementation to ensure that the VCITs are tailored to local crime problems and to address the concerns of the communities where the VCITs were to be located. They further stated that this practice will continue as ATF implements additional VCITs. Finally, ATF stated that VCIT implementations may vary within the Best Practices framework.

OIG’s Analysis:  ATF’s actions are partially responsive to this recommendation. We agree that ATF has taken an important first step in developing operational guidance for implementing the VCIT strategy by defining the 10 best practices that each VCIT should implement. We also agree with ATF that the VCITs must be tailored to local crime problems. Because a key finding of our review was that rather than tailoring the key elements of the VCIT Strategy to local operations, VCITs ignored many of the elements, ATF’s operational guidance should clarify that all VCITs are required to adapt the 10 best practices and also set standards and provide guidance for implementing each practice.

For example, ATF should include guidance to the Field Divisions regarding criteria and standards for selecting target areas to address issues such as level of crime, size, population density, and the number of ATF Special Agents to be assigned. The standards would become the basis for ATF to determine whether a VCIT is, in fact, implementing the best practices.

To close this recommendation, by August 15, 2006, please provide the OIG with the guidance provided to ATF Field Divisions explaining ATF requirement that VCITs tailor the 10 best practices to local conditions and the standards that ATF will use to judge whether each of the 10 best practices has been implemented. In addition, please provide the OIG with copies of the presentations, including any handouts used during VCIT Coordinator meetings, on how to implement the VCIT Strategy, meet reporting requirements, and use the NIBIN.

Recommendation 2:  Develop and implement a pre-deployment assessment for prospective VCIT locations to determine the potential applicability of VCIT to local violent crime problems.

Status:  Resolved – Open

Summary of ATF’s Response:  ATF concurred with this recommendation. ATF stated that it has surveyed all ATF Special Agents in Charge (SAC) requesting recommendations for cities where future VCITs might be deployed. The SACs reportedly based their recommendations on preliminary analyses of site surveys, which addressed crime rates, the exact nature of the crime problem in each of the recommended cities, the specific size and location of the proposed VCIT target area, and the level of support anticipated from other law enforcement agencies. In addition, ATF reported that it has worked with the Attorney General’s Anti-Gang Coordinating Committee in developing a Gang Threat Assessment and Law Enforcement Activity Recommendation. The Committee, composed of one representative from each of the Department’s law enforcement and criminal prosecution components, will review and approve all future VCIT sites. According to ATF’s response, “The [Activity] Recommendation is a thorough assessment, an analysis of ongoing law enforcement and task force operations, and a specific plan of operations, including the proposed area of operations and specific goals of the proposed task force.” In its response, ATF stated that it will use the Activity Recommendation as a template for the submission of all future VCIT sites to the Anti-Gang Coordinating Committee for consideration.

OIG’s Analysis:  ATF’s actions are responsive to our recommendation. The OIG agrees that ATF’s new process involves its SACs in selecting cities for VCIT deployment. That change should provide ATF Headquarters with better information about local crime conditions and law enforcement resources, something the OIG found lacking when the original cities were selected. To close this recommendation, by August 15, 2006, please provide a copy of, or provide access to the OIG to review, the site survey used to collect information from ATF SACs and the Coordinating Committee’s assessment and recommendation forms. In addition, please provide three examples of the survey responses and the assessment and recommendation for cities under active consideration for VCIT implementation.

Recommendation 3:  Develop and implement an adequate evaluation strategy to assess VCIT performance and impact on violent firearms crime.

Status:  Resolved – Open

Summary of ATF’s Response:  ATF concurred with this recommendation and stated that it will base its program evaluation on official, validated, crime data as reported through the FBI’s UCR. ATF’s explained that it now believes that its initial selection of four performance measures, which included all homicides and all violent crimes, was overreaching. ATF stated that “considering ATF’s firearms jurisdiction, ATF determined that any evaluation [of VCIT effectiveness] should be measured by its impact on firearms-related crimes.” It further concurred with the OIG that “the best overall evaluation of the VCIT program’s success would be the number of violent criminal acts [committed] with a firearm.”

ATF explained that data on the reports of criminal acts committed with a firearm could not be satisfactorily validated until the underlying data that make up the UCR were released to law enforcement agencies for analysis. Further, ATF stated that as of May 1, 2006 (18 months after the end of the pilot), these data were still not available from the FBI. Because firearms-related violent crime data were not available from the FBI’s UCR, ATF used homicide data to determine the impact of the VCITs. Acknowledging that the number of homicides committed with a firearm was small in some VCIT cities, ATF stated that “when the homicide data is analyzed over the 15 VCIT cities and compared to the rest of the cities in the United States, ATF feels any large difference in a trend is statistically significant.”

ATF’s response included an analysis of UCR data for total homicides reported (as opposed to firearms-related homicides) that shows the homicide rate during the VCIT pilot period (June 2004 through November 2004) in the 15 VCIT cities fell 8.2 percent, while the homicide rate during the same period in all other U.S. cities fell 1.5 percent. ATF concluded by saying that it does not claim that the VCIT initiative alone was responsible for these results. However, ATF said it does believe that there was a “unique and positive occurrence” in the VCIT communities and that the decline in homicides “seems beyond mere coincidences and happenstance.” Finally, ATF stated that the homicide measures used seem appropriate given ATF’s mission.

OIG’s Analysis:  ATF’s actions are partially responsive to this recommendation. The OIG agrees with ATF that continued emphasis on evaluation of the VCIT initiative is critical. We also agree that the best outcome measure of VCIT success is changes in violent firearms crime rather than only changes in the number of homicides committed with firearms. The OIG does not agree with ATF’s contention that UCR data are appropriate for measuring the impact of VCITs on violent firearms crimes and also disagrees with conclusions based on the analysis of UCR homicide data. FBI Uniform Crime Reports are issued for U.S. cities approximately 2 years after the year for which the data are collected (e.g., 2004 data will be released in 2006). However, to determine whether violent firearms crime is declining in the part of a city where a VCIT operates, ATF needs to obtain crime data for the target area at regular intervals from the local police department. For example, the ATF could collect data from a local police crime-mapping program or from victimization surveys in the target area.35

To correctly attribute to VCITs any observed crime reductions, the evaluation strategy must assess how well the VCITs have implemented the 10 best practices. In the section of our report on evaluation, we provided examples of performance measures that could be used to assess how well VCITs implemented the five key elements, which are included in the 10 best practices.

To close this recommendation, by August 15, 2006, please provide the OIG with a copy of ATF’s guidance to the Field Divisions on implementing an evaluation strategy that provides information on how well local VCIT operations are adapting and implementing the 10 best practices, outcome data on violent firearms crime in the target area, and requirements for reporting evaluation data and information to ATF Headquarters.

Recommendation 4:  For existing VCITs, where possible, and for future VCITs, establish interagency agreements with federal and local partner agencies that define resource commitments and operational responsibilities.

Status:  Resolved – Open

Summary of ATF’s Response:  ATF concurred with this recommendation. ATF stated that it has developed uniform Memorandums of Understanding (MOU) for all future VCIT operations and that these MOUs are under review by ATF counsel. ATF stated that the MOUs, in conjunction with the Coordinating Committee’s assessment and recommendation forms that require concurrence by all participating law enforcement agencies, will provide a full understanding of resource commitments and operational responsibilities.

ATF further responded that the DEA and USMS fiscal year 2008 budget request will include funding for 2 full-time positions to serve on each of 40 VCITs.

OIG’s Analysis:  ATF’s actions are responsive to this recommendation. To close this recommendation, by August 15, 2006, please provide copies of ATF counsel-approved standard MOUs that ATF plans to use in the future.

Recommendation 5:  Establish management authority and responsibility for overseeing the implementation and evaluation of local VCIT operations in accordance with ATF’s VCIT Strategy and the guidelines developed in response to Recommendation 1.

Status:  Resolved – Open

Summary of ATF’s Response:  ATF concurred with this recommendation. ATF stated that VCIT was a pilot program and therefore ATF provided broad guidance to the field to gauge what practices would prove most successful as well as to allow each VCIT to address specific community issues and unique problems that were the root causes of the violent crime problem.

ATF’s response states that its Best Practices report will continue to serve as clear operational guidance for the VCITs’ operations. Additionally, ATF Field Divisions are now required to submit biannual plans that address or reevaluate current crime problems, target areas, and concepts of operations. The Field Divisions must also submit written justifications if they wish to vary from the approved local VCIT strategic plans. In addition, Field Divisions are required to submit weekly workload statistics on arrests, gun traces, and seizures, and monthly performance reports on outcome measures such as number of homicides and, where available, violent crime statistics.

OIG’s Analysis:  ATF’s actions are partially responsive to our recommendation. We agree that the information ATF now requires from each Field Division on its VCIT operations will assist ATF Headquarters in overseeing the implementation of the VCIT initiative. However, ATF did not identify the organizational units at ATF Headquarters that have the responsibility for reviewing and assessing this information and the authority to direct adjustments in VCIT implementation where necessary.

To close this recommendation, by August 15, 2006, please identify the organizational units within ATF that will be responsible for overseeing:  (1) the implementation and evaluation of local VCIT operations and ensuring that the local VCITs are meeting their reporting requirements and (2) compliance with ATF’s VCIT Strategy, including the guidelines developed in response to Recommendation 1. If these responsibilities are allocated among different units, provide a description of how these units communicate and coordinate to ensure compliance with VCIT operating, reporting, and evaluation guidelines.

  1. In the final version of the report, Table 7 was renumbered as Table 6 and Table 8 was renumbered as Table 7.

  2. Our report refers to “VCIT Coordinators” because we found that was how ATF personnel commonly referred to people in that particular position. In its response to the report, however, ATF used the term “supervisors.”

  3. We agree with ATF that the Philadelphia VCIT’s definition constituted an example of an acceptable definition. However, we note that the Philadelphia VCIT did not develop a list of suspects who met this definition.

  4. Annual firearms tracing data was unavailable for the VCITs that were added in 2005.

  5. To ensure that the necessary target area data are available to evaluate the impact of VCIT on violent firearm crime, ATF’s site survey should request information on the accessibility of such data. ATF should also address access to local crime data in its Memorandums of Understanding with local law enforcement agencies (see Recommendation 4).

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