In its response to our draft audit report, the TSC concurred with each of our 18 recommendations and discussed the actions it has already taken and others it will implement in response to our findings. This appendix contains our analysis of the TSC’s responses to our recommendations and the actions necessary to close each recommendation.

Status of Recommendations

1. Resolved. The TSC concurred with our recommendation that it implement its plan to consolidate the TSDB NTP and legacy databases in a timely manner, and the TSC stated that it developed a project plan to guide the future consolidation of the system. In the interim period while it is still necessary to operate both databases, the TSC stated that it implemented a daily reconciliation process between the TSDB NTP and legacy databases for routine monitoring of the data.

This recommendation can be closed when we receive evidence that the TSC has fully implemented its plan to consolidate the TSDB NTP and legacy databases. In the meantime, please provide evidence that the TSC has implemented a daily reconciliation process that identifies and addresses differences in database content.

2. Resolved. In its response to our draft report, the TSC concurred with our recommendation to develop procedures to regularly review and test the information contained in the TSDB to ensure the data is complete, accurate, and non-duplicative. The TSC noted that it has used informal procedures to review and test the information in the TSDB, and it now has implemented procedures to formalize this process.

This recommendation can be closed when we receive documentation or other evidence to support that the TSC has developed and fully implemented procedures to regularly review and test information in the TSDB to ensure the data is complete, accurate, and non-duplicative.

3. Resolved. The TSC concurred with our recommendation and stated that it will implement our recommended changes as part of its planned, phased improvements for the TSDB NTP, including the incorporation of the export capability of the legacy system.

This recommendation can be closed when we receive evidence that the TSC has modified the TSDB NTP to accommodate designations for both CLASS/Visa and CLASS/Passport, and that it has reviewed and corrected the records identified in the TSDB NTP to appropriately reflect that U.S. persons are not eligible for export to CLASS/Visa.

4. Resolved. The TSC concurred with this recommendation and stated that it had completed its review of watchlist records and made corrections to records in the TSDB NTP with incorrect IBIS handling instructions.

This recommendation can be closed when we receive evidence that the TSC identified and corrected the watchlist records with inappropriate IBIS handling instructions.

5. Resolved. In its response to our draft report the TSC concurred with this recommendation and stated that while it had used previously undocumented procedures, it will now formalize this process to ensure that outdated or obsolete data is removed in a timely manner.

This recommendation can be closed when we receive evidence that the TSC has developed and implemented formal procedures to regularly review the information in the TSDB to ensure that outdated or obsolete data is removed in a timely manner.

6. Resolved. The FBI concurred with our recommendation and stated that it will continue to work to revise the current nomination process. However, the FBI stated that it had implemented its current nomination process initially to address its concern that watchlist nominations were not being processed in a timely manner due to the operations schedule of the NCTC.

While we recognize that the FBI conducts its watchlisting operations on a continuous basis, we believe that the NCTC is operational during the time period in which the majority of watchlist nominations are submitted. Further, an additional emergency nomination process is available to the FBI for those instances in which the FBI determines a nomination is exigent and the NCTC may not be available. Given our identification of significant data errors and inconsistencies resulting from the FBI’s non-standard nomination process for international terrorists, we believe that the FBI, NCTC, and TSC should work together to design a more consistent and reliable process by which FBI-originated international terrorist information is provided to the NCTC for inclusion in TIDE and disseminated to the TSDB and downstream screening systems, including VGTOF. To close this recommendation, please provide us with information on specific steps taken to revise the FBI’s watchlist nomination process for known or suspected international terrorists.

7. Resolved. The TSC concurred with this recommendation and stated that it has taken steps to correct the watchlist records under its purview. This recommendation can be closed when we receive evidence that the records we identified during our review that contained incorrect watchlist designations, handling code errors, and inaccurate and inconsistent information have been corrected.

8. Resolved. The TSC concurred with our recommendation to coordinate with NCTC and FBI to implement an agreement that establishes the areas of responsibility and the timeframes for data quality assurance matters.

This recommendation can be closed when we receive evidence supporting the implementation of a signed agreement between the NCTC and FBI that outlines areas of responsibility and the timeframes for data quality assurance matters.

9. Resolved. The TSC concurred with our recommendation to develop a comprehensive standard operating procedure that describes the TSC’s quality assurance strategy and details the methodology to be used in performing quality assurance reviews.

This recommendation can be closed when we receive evidence that the TSC has finalized its quality assurance strategy and methodology and has trained its staff on using the standard operating procedure in performing quality assurance reviews.

10. Resolved. The TSC concurred with our recommendation to develop a process to perform regular spot-checks of NDIU analysts’ work. This recommendation can be closed when we receive evidence that the TSC has developed, documented, and implemented a process to perform regular spot-checks of NDIU analysts’ work to identify weaknesses and needs for additional training.

11. Resolved. In its response, the TSC concurred with this recommendation and stated that it had implemented a solution to remedy our finding. Specifically, the TSC stated that it will utilize the FBI’s Automated Case Support (ACS) system to track all quality assurance classified correspondence, including e-mails and electronic communications.

This recommendation can be closed when we receive evidence that the TSC has formally documented this process and communicated the policy to its staff.

12. Resolved. The TSC concurred with this recommendation and stated that it has begun developing a tickler system or electronic dashboard for pending quality assurance matters. This recommendation can be closed when we receive evidence that the TSC has implemented such a system.

13. Resolved. The TSC concurred with this recommendation and stated that it will develop a comprehensive plan to ensure that each record in the TSDB has undergone a quality assurance review.

This recommendation can be closed when we receive evidence that the TSC has developed a plan that: (1) includes specific milestones for the successful completion of this comprehensive review, (2) tracks its progress against these milestones, and (3) identifies actions to take if the milestones are not met.

14. Resolved. The TSC concurred with this recommendation and stated that since its inception the TSC has used an undocumented process to coordinate with other partner agencies to obtain relevant information captured by frontline screening agents during encounters with known or suspected terrorists. We recognize that the TSC has endeavored to update watchlist records by incorporating encounter information captured by frontline screening agents. However, without a formal process with which frontline screening agencies agree, the TSC is unable to ensure that it is receiving complete, accurate, and timely encounter information. This recommendation can be closed when the TSC provides documentation to support that a formal process has been developed and implemented between partner agencies to ensure that encounter data is appropriately returned to the TSC for updating watchlist records.

15. Resolved. The TSC concurred with this recommendation and stated that implementation to address this recommendation was underway and pending signatures by all parties. This recommendation can be closed when we receive the finalized agreement containing timeliness measures for processing watchlist redress matters agreed to and signed by the appropriate agencies.

16. Resolved. The TSC concurred with this recommendation and stated it is developing goals and performance measures relative to misidentifications for its strategic plan. This recommendation can be closed when the TSC provides its updated strategic plan that includes goals and performance measures to address reducing the incidence and impact of misidentifications.

17. Resolved. The TSC concurred with this recommendation, stating in its response that it is developing the framework for a program that will proactively review watchlist records related to frequently encountered individuals. This recommendation can be closed when the TSC provides documentation formalizing this new proactive redress program, as well as evidence that this program has been implemented.

18. Resolved. The FBI concurred with our recommendation and stated that it has instituted a new policy and process for resolving redress matters involving the NCIC database. Additionally, the FBI noted that the February 2007 redress matter that was pending at the time of our review has been resolved.

To close this recommendation, please provide us the FBI policy containing timeliness measures for processing NCIC-related redress matters. Additionally, please provide documentation to confirm that the February 2007 redress matter that was pending at the time of our review has been appropriately resolved.