Audit Report

THE DEA'S IMPLEMENTATION OF THE GOVERNMENT PERFORMANCE AND RESULTS ACT NEEDS TO BE IMPROVED

Our audit determined that the DEA had developed a strategic goal and objectives that were consistent with the Department's strategic plan, but the DEA's goal and objectives were not adequate to allow for a future assessment of whether they were being achieved. While the DEA had developed performance indicators for all of its budget decision units, the DEA had not: 1) reported performance results for all its performance indicators, 2) established specific criteria for the field divisions to identify priority target organizations; 3) established specific criteria for the field divisions to identify and report on disrupted or dismantled priority target organizations; 4) developed an effective system to collect, analyze, and report performance data for all of its performance indicators; 5) established procedures and controls to verify the performance data for all of its performance indicators; 6) reported the correct number of priority target organizations disrupted and dismantled for one of the five field divisions included in our review; and 7) established reasonable performance goals for its performance indicators. Until these weaknesses are corrected, it will be difficult for the DEA, the Department, Congress, and the public to assess how effective the DEA has been in achieving its intended results.

To determine if the DEA had established a goal and objectives that were consistent with the Department's goals and objectives, we compared the DEA's FY 2001-2006 Strategic Plan to the Department's FY 2001-2006 Strategic Plan. The DEA established a strategic goal to "Identify, target, investigate, disrupt, and dismantle the international, national, state, and local drug trafficking organizations that are having the most significant impact on America." Our audit determined that this goal was broadly encompassed within the Department's second goal of "Enforcement of Federal Criminal Laws." The DEA had also established the following 15 strategic objectives for accomplishing its strategic goal:

Our audit determined that the first nine objectives were consistent with the Department's objective to "Reduce the threat, trafficking, and related violence of illegal drugs by identifying, disrupting, and dismantling drug trafficking organizations." Furthermore, the remaining six objectives were broadly encompassed under the objectives for the Department's eighth goal to "Ensure professionalism, excellence, accountability, and integrity in the management and conduct of Department of Justice activities and programs."

In addition, the DEA had also taken steps to address the Department's re-positioning of protecting America against terrorism as its number one goal. The DEA proposed changes for its FY 2002-2007 Strategic Plan to incorporate language that addressed terrorism and how it fits into the DEA's overall plan. According to a DEA official, terrorism is an element of drug trafficking and the DEA's primary goal of focusing on drug trafficking organizations will remain the same. As such, the DEA incorporated language in its strategic plan to address the link between drug trafficking and terrorism, as well as how the DEA can continue its current plan while also meeting the Department's emphasis on protecting America against terrorism.⁹

We also evaluated the DEA's strategic goal and objectives to determine if they were adequate to allow for a future assessment of whether the goal and objectives were being achieved. OMB Circular A-11 requires that strategic goals and objectives be either quantitative, directly measurable, or assessment-based to allow for future assessment of achievement. OMB Circular A-11 provides the following illustrative examples of adequate goal and objective definitions:

Our audit determined that the DEA's strategic goal was not quantitative, directly measurable, or assessment-based. The DEA's strategic goal is to identify, target, investigate, disrupt, and dismantle the international, national, state, and local drug trafficking organizations that are having the most significant impact on America. This goal does not provide any quantitative measures such as a percentage of drug trafficking organizations that the DEA plans to identify, target, investigate, disrupt, and dismantle. In addition, the goal is open-ended in that it does not provide a timeframe in which the DEA plans to meet this goal. An example of a strategic goal for the DEA that would meet the requirements of GPRA and OMB Circular A-11 might be to target, investigate, disrupt, and dismantle a certain percent of the most significant international, national, state, and local drug trafficking organizations by a certain year.

We also found that the DEA's strategic objectives were not quantitative, directly measurable, or assessment-based. For example, the DEA's strategic objective number 3 is to dismantle those domestic organizations that are directly affiliated with international cartels. Again, this objective does not provide any quantitative measures such as a percentage of organizations that the DEA plans to dismantle, and it does not provide a timeframe in which the DEA plans to meet this objective. As such, the DEA's strategic goal and objectives were not adequate to allow for a future assessment of whether they were being achieved, as required by GPRA and OMB Circular A-11.

After we issued the draft report, the DEA informed us that it has revised its strategic plan since we completed our audit fieldwork. The DEA updates its 6-year strategic plan annually. At the time of our audit fieldwork, the DEA had completed its FY 2001-2006 Strategic Plan. We found that the goal and objectives in the DEA's FY 2001-2006 Strategic Plan were not quantitative, directly measurable, or assessment based. Subsequent to the exit conference for the audit, the DEA informed us that it was then drafting its FY 2003-2008 Strategic Plan to address these shortcomings. In response to a draft of this audit report, the DEA stated that it has drafted its FY 2003-2008 Strategic Plan to include a general long-term goal and four strategic goals with 2-year and 5-year quantitative, time-specific objectives, which it believes will address some of the recommendations in this report. The DEA also stated that these new goals and objectives meet the requirements of GPRA and OMB Circular A-11. The DEA stated that the revised Strategic Plan would be provided to the Office of the Inspector General upon approval of the plan.

We believe the DEA's actions to revise its goal and objectives in the FY 2003-2008 Strategic Plan, partly in response to this audit, are positive steps towards improving the DEA's ability to measure achievement of its goals and objectives. Once we receive the DEA's FY 2003-2008 Strategic Plan, we will evaluate the adequacy of the DEA's revised goals and objectives and provide feedback to the DEA.

In its FY 2003 budget request, the DEA had not identified performance indicators and performance results for all its decision units.¹⁰ According to OMB Circular A-11, the annual performance plan must include a performance goal or indicator with quantifiable results for each decision unit included in the budget. To determine whether the DEA had established performance indicators and reported performance results for each of its decision units, we reviewed the annual performance plan contained in the DEA's FY 2003 congressional budget request and interviewed DEA officials to discuss the sources of information reported in support of the budget. As shown in the following table, in its FY 2003 budget request the DEA had not: 1) reported performance indicators for 7 of the 11 decision units listed in its request, and 2) reported performance results for 2 of the 4 decision units with performance indicators.

DEA FY 2003 Performance Plan Data

Decision Unit	Performance Indicators Included in Plan	Performance Results Included in Plan
Domestic Enforcement	Yes	Yes
Foreign Cooperative Investigations	No	N/A
Drug and Chemical Diversion Control	Yes	No
State and Local Task Forces	Yes	Yes
Intelligence	No	N/A
Laboratory Services	No	N/A
Training	No	N/A
Research, Engineering, and Technical Operations	No	N/A
Automated Data Processing	No	N/A
Management and Administration	No	N/A
Diversion Control Fee Account	Yes	No

Source: DEA's FY 2003 Congressional Budget Request

In its FY 2004 budget request, the DEA reduced its decision units from 11 to 4 at the direction of JMD and included performance indicators for all 4 decision units. JMD instructed the DEA to reduce the number of decision units to provide a better linkage between its strategic plan and its budget. As shown in the following table, the DEA reported six performance indicators for its four decision units.

DEA FY 2004 Performance Plan Data

Decision Unit	Performance Indicators
Domestic Enforcement	Number of priority target organizations disrupted/dismantled Contribution to reduction in drug use and availability
International Enforcement	Number of priority target organizations disrupted/dismantled Contribution to reduction in drug use and availability
Diversion Control	Number of suppliers disrupted/dismantled
State and Local Assistance	Contribution to reduction in drug use and availability

Source: DEA's FY 2004 Congressional Budget Request

Two of the performance indicators (contribution to reduction in drug use and availability and number of suppliers disrupted/dismantled) were newly reported in the FY 2004 budget request. Even though the latter performance indicator was new, the DEA reported performance results in the FY 2004 budget request for this indicator because the DEA had been collecting such data. However, the DEA had not reported performance results for the other new performance indicator because it had yet to develop a methodology for how to collect this performance data.

The DEA used disruption and dismantlement of priority target organizations as the baseline for measuring its success. The DEA generally defined priority target organizations as drug trafficking organizations for which investigations have the potential to achieve disruption or dismantlement at the highest level of the organization and to provide the greatest potential impact on the reduction of illicit drugs. However, the DEA Headquarters had not established specific criteria for determining what constitutes a priority target organization. As a result, field divisions were not consistent in how they determined whether an organization was a priority target.

To determine the criteria the DEA used to select its priority targets, we obtained a list of the 726 FY 2001 priority target organizations identified by the DEA. From the list, we selected five field divisions (Atlanta, Chicago, Los Angeles, New Orleans, and New York) to verify the priority target performance data reported. The five field divisions accounted for 248 of the 726 priority target organizations. We interviewed the Special Agents-in-Charge (SAC) at the five field divisions to obtain their feedback on the use of priority targets as the DEA's source for measuring performance, and we interviewed DEA personnel to determine the criteria used to establish the 248 priority targets. While all five SACs rated the use of priority targets as a good to excellent source of measuring performance, they also believed that the field divisions were not consistently identifying and reporting priority target performance data.¹¹ Our audit work confirmed the inconsistencies.

As detailed in Appendices 4 through 8, our audit determined that both within and between each of the five field divisions the criteria used by DEA personnel to select priority target organizations varied. For example, in the Atlanta field division, we interviewed 18 staff [Group Supervisors, Resident Agents-in-Charge, and Assistant Special Agents-in-Charge (ASAC)] and determined they used a total of 19 different reasons for selecting an organization as a priority target. We found that some individuals in the Atlanta field division used as many as 6 of the 19 reasons for selecting a priority target while other individuals used as few as one. In addition, we found that the primary reason for selecting priority target organizations varied between field divisions. For example, the Atlanta field division's primary reasons for selecting priority target organizations was volume of drugs and level of impact on the community, while the Chicago field division's primary reasons was national/international trafficking and whether the organization was part of an Organized Crime Drug Enforcement Task Force operation.

A DEA Headquarters official stated that specific criteria for identifying priority targets had not been established because the DEA's efforts had been focused on establishing performance indicators first and then the DEA would concentrate on identifying and correcting any problems associated with the selection and reporting of priority target data. In its FY 2004 congressional budget request, the DEA reported that it was in the process of establishing criteria for the selection of priority target organizations. In November 2002, the DEA formed a committee of ASACs to develop the criteria. Once the committee develops the criteria, it will be submitted to the SAC Advisory Board for approval. At the time we drafted this report, the DEA had not finalized the criteria for selecting priority target organizations.

The DEA used disrupted and dismantled priority target organizations as the primary performance indicator to measure its success. The DEA defines a disrupted priority target organization as an organization whose normal effective operation is significantly impacted so that it is unable to conduct criminal operations for a significant period of time. The disruption must be the result of an affirmative law enforcement action, including but not limited to the arrest, indictment, and conviction of the organizational leadership or a substantial seizure of the organization's assets. The DEA defines a dismantled priority target organization as an organization that is incapacitated and no longer capable of operating as a coordinated criminal enterprise. The dismantlement must be the result of an affirmative law enforcement action, including but not limited to the arrest, indictment, and conviction of all or most of its principal leadership, the elimination of its criminal enterprises and supporting networks, and the seizure of its assets. To be considered dismantled the organization must also be impacted to the extent that it is incapable of reforming. However, the DEA had not established specific criteria beyond the general description to define what constitutes a disrupted or dismantled priority target organization, thereby leaving the definitions subject to interpretation by the field divisions. As a result, our audit determined that the field divisions were not consistent in how they determined whether a priority target organization was disrupted or dismantled.

To determine the criteria used to decide whether a priority target organization should be classified as disrupted or dismantled, we identified organizations listed as being disrupted and dismantled and interviewed DEA personnel involved with classifying the organizations. We determined that of the 726 FY 2001 priority targets identified by the DEA, the DEA reported 50 as being disrupted and 50 as being dismantled. We obtained a list of these 100 priority target organizations and identified 41 of the 100 as being from the five field divisions included in our review. We then interviewed DEA personnel at these locations to determine the criteria used to classify the organizations as either disrupted or dismantled.

As detailed in Appendix 9, our audit determined that both within and between each of the five field divisions, the criteria used by DEA personnel to classify the priority target organizations as either disrupted or dismantled varied. For example, in the New York field division, the fact that members of a large organization were arrested was used to classify one priority target organization as disrupted and another priority target organization as dismantled. In other examples, the New Orleans field division classified an organization as dismantled based on the fact that the leader and couriers of an organization responsible for the distribution of cocaine were arrested while the Los Angeles field division classified an organization as disrupted based on the fact that the leaders and couriers of an organization responsible for the distribution of cocaine and marijuana were arrested. To further illustrate differences between field divisions, the New Orleans and Los Angeles field divisions' primary reason priority target organizations were classified as dismantled was because the leader or leaders of an organization responsible for the distribution of drugs were arrested, while the New York field division's primary reason was because a member or members (not necessarily a leader) of a large organization responsible for the distribution of drugs were arrested. A DEA official stated that they plan to address these inconsistencies in the third or fourth quarter of FY 2003.

To determine whether the DEA had developed an effective system to collect, track, and report performance data, we interviewed DEA officials and reviewed PTARRS data and PTARRS training manuals. We determined that the DEA had not developed a system to effectively track performance data for five of its six performance indicators as shown in the following table.

Number of Priority Target Organizations Disrupted/Dismantled (Domestic Enforcement Decision Unit). From our interviews and review of the PTARRS training manuals and system data, we determined that the DEA formerly tracked its priority target performance indicators and results for its domestic enforcement operations manually through the use of a spreadsheet application program. Because the manual tracking system was labor intensive and time consuming, the DEA developed the PTARRS to replace the manual process. We found that the PTARRS provides an effective capability to track the progress made and resources expended against priority target organizations.

Number of Priority Target Organizations Disrupted/Dismantled (International Enforcement Decision Unit). The DEA tracked its international priority target organizations through a manual spreadsheet application program instead of the PTARRS. Because the manual system is time consuming and labor intensive, the DEA plans to incorporate features into PTARRS to enable tracking of the international priority target organizations. According to a DEA official, the DEA is awaiting funding to modify PTARRS to incorporate the international priority target performance data. This expansion of PTARRS has been delayed because PTARRS is accessible only through the DEA's primary data processing system called Firebird. Most DEA international offices gained access to the Firebird system by March 2003; however, at that time Moscow, Beijing, Peshawar, and Lyon still needed access to the Firebird system. The installation of the Firebird system in these four remaining offices has been delayed because of security and other issues. To minimize the time and labor involved with tracking international priority target data manually, the DEA should begin using PTARRS to track international performance data as soon as the obstacles mentioned above are removed.

Contribution to Reduction in Drug Use and Availability (all three decision units)and Number of Suppliers Disrupted/Dismantled (Diversion Control Decision Unit). The DEA tracked performance data for one of its two new performance indicators - suppliers disrupted and dismantled - using a manual spreadsheet application program. However, for the other new performance indicator on contributing to the reduction in drug use and availability, the DEA had not developed a methodology for measuring success. Without a methodology, we could not determine whether meaningful performance data would be available to effectively measure performance against this indicator. Moreover, the DEA had not developed a reporting system for either of these two new performance indicators. Without a reporting system, we could not determine whether any performance data accumulated would be reported in a meaningful way.

The DEA had not established procedures to verify the priority target performance data for all its performance indicators. To verify the priority target performance data, we obtained the PTARRS training manual and reviewed the procedures for tracking investigative cases. In addition, we had DEA field division personnel demonstrate the system controls, as well as how they ensure the priority target information reported in PTARRS is complete and accurate. We also interviewed DEA officials to discuss the sources of information reported in support of its budgets and reviewed the accreditation package¹² that was used to evaluate the PTARRS. From the accreditation documentation, we found that the DEA had evaluated the risks and controls in place within the system. Our review determined that the PTARRS application was certified and accredited by the Information Security Section of the DEA's Office of Security Programs as having adequate controls for reporting and tracking priority target organizations with certain minor conditions that were to be resolved by September 12, 2002. Because the contract for upgrading PTARRS had yet to be completed, the DEA was granted two 6-month extensions through September 12, 2003, to complete the action items in the accreditation package.

We also found that the DEA's PTARRS application, its system controls and cross checking methods with other systems, and the procedures instituted by the DEA for case review were generally adequate to verify the domestic priority target performance data. However, as previously mentioned, PTARRS was not used to track performance data for the international priority targets or for the two new performance indicators on suppliers disrupted/dismantled and contribution to reduction in drug use and availability. As a result, the DEA is unable to verify the accuracy and reliability of the information recorded, reported, and used to evaluate its performance for these three indicators. According to a DEA official, once the two new FY 2002 performance indicators and the Office of International Operations' international priority target organizations are brought into the PTARRS reporting system, procedures will be established to ensure the performance results are valid. After we issued the draft report, the DEA informed us that it would modify PTARRS to include all international priority target organizations by the end of FY 2004.

As previously discussed, prior to the implementation of PTARRS the DEA tracked priority target organization data using a manual spreadsheet application. To examine the accuracy of the priority target performance data reported for the five DEA field divisions, we determined that the field divisions accounted for 248 of the 726 FY 2001 priority target organizations listed in the DEA's manual spreadsheet application. We then reviewed the case files and physically verified that 128 of the 248 priority target organizations were priority targets managed by the field divisions included in our review. For the remaining 120 priority targets managed by sub-offices of the field divisions reviewed, we obtained a signed certification from the respective sub-office official that the organizations were in fact priority target organizations.

To assess the accuracy of the disrupted and dismantled priority target performance data reported for the five DEA field divisions, we first determined that the field divisions accounted for 41 of the 100 FY 2001 disrupted or dismantled priority target organizations in the manual spreadsheet application. We then discussed the respective priority target organizations with the case agents or group supervisors to confirm whether the priority target organizations were disrupted or dismantled, the outcome of the priority target investigations, and the impact the priority target organizations had on drug distribution in the United States. We also had the case agents and group supervisors provide details from the case files of the results of the investigations to include the number of individuals arrested and convicted and the assets seized. Our review determined that the performance data reported for 38 of the 41 FY 2001 disrupted and dismantled priority target organizations listed in the manual spreadsheet application was accurate. However, for the Los Angeles field division, the DEA did not properly report data for 3 of the 28 disrupted and dismantled priority target organizations (5 disrupted and 23 dismantled) reported. Specifically:

The DEA discovered and corrected these three errors when it reconciled the manual spreadsheet data and the PTARRS data in April 2002 when PTARRS was brought online. In addition, as previously discussed we found that the PTARRS system controls and cross-checking methods were adequate to verify the domestic priority target data. Therefore, we make no recommendation regarding this issue.

Goals for Priority Target Organizations and for Disruptions and Dismantlements

Because the DEA had not established specific criteria for identifying priority target organizations and for determining whether the organizations have been disrupted or dismantled, the performance goals established by the DEA may not be useful. In addition, the DEA also had not established reasonable goals for priority target organizations identified and priority target organizations disrupted and dismantled. To determine if the DEA established reasonable performance goals, we reviewed actual and planned priority target performance data reported in the DEA's budget requests for FYs 2003 and 2004. As shown in the following table, we determined that the DEA has not established reasonable goals for the number of priority target organizations that it would identify each year or for the number of priority target organizations that it would disrupt or dismantle each year.

Fiscal Year	Priority Target Organizations Identified		Priority Target Organizations Disrupted or Dismantled
Fiscal Year	Planned	Actual	Planned	Actual
2001	538	566	27	100
2002	588	764	35	190
2003¹³	638	424	45	260

Source: DEA Congressional Budget Requests for FY 2003 and FY 2004

As shown in the preceding table, each year the DEA reported disrupting and dismantling about four times or more organizations than it had planned. As such, the DEA was significantly understating this goal. A DEA Headquarters official stated that the goals were significantly understated because the DEA wanted to be cautious when setting its goals until the field divisions were reporting consistent data. The official said the goals were later modified upward but were still tempered because of the potential impact that standardized criteria for selecting priority targets and for classifying priority targets as disrupted or dismantled could have on the projected goals. According to the same official, the DEA was concerned that restrictive standardized criteria could impact the goals downward. Nevertheless, in order to credibly measure its success, the DEA needs to develop reasonable goals on the number of priority target organizations that it expects to identify each year, as well as the number of priority target organizations that it expects to disrupt or dismantle each year.

Although the DEA had developed a strategic goal and objectives in concert with the Department's strategic goals and objectives, it failed to meet key aspects of GPRA and OMB Circular A-11. Specifically, we determined that the DEA's strategic goal and objectives were not adequate to enable future measurements of success, and the DEA had not:

The DEA needs to effectively address these issues to ensure that its reported performance results provide the Department, Congress, and the public meaningful data to measure how well the DEA is accomplishing its mission.