It is important to both the airline industry and to INS that airline employees be capable of identifying improperly documented passengers and preventing their boarding of flights to the United States. Section 286 of the INA stipulates that "the Attorney General shall provide for the expenditures for training and assistance" of airline industry personnel. Because INS training helps the airlines identify improperly documented passengers, thus reducing or avoiding fines associated with transporting improperly documented passengers, the airlines typically wish to receive as much INS training as is practical within the constraints of their business operation.
Based on our observations and interviews, CAO has done a commendable job in attempting to meet its training mandate given its small staff and budgetary limitations. From the training that we observed, the staff was very professional and effective in presenting the subject matter. The consensus of the airline industry was that CAO was doing an excellent job within its limited resources. Nevertheless, we identified a number of areas in INS training that need improvement.
INS Does Not Adequately Evaluate the Effectiveness of All Its Training Provided to Airlines
INS does not evaluate the effectiveness of the training it provides to airline industry personnel and cannot, therefore, determine whether training resources are well spent. Without a credible process for evaluating its diverse training courses, INS cannot determine whether the training meets minimum acceptable levels. Professional training standards require a formal process of evaluation to determine whether a training course is effective at imparting a knowledge base that enables a student to successfully perform intended tasks or functions.5 INS only receives limited, voluntary feedback from some airlines on the airline employees' opinion of the training. Based on this feedback and our interviews with airline personnel, the training provided by INS was useful. However, no systematic approach exists for evaluating if airline employees learn all or most of the material or if the employees can apply what they learn.
Because various INS offices (i.e., the CAO, JFK, Miami, LAX, and overseas offices) independently conduct training, it is important for INS to determine: the specific intended results of INS's training effort, if all training courses accomplish the intended results, and if one (or more) course is especially effective and can be adopted as a best practice. The INS offices conducting such training have selected their own curricula. Although most of the airline training has the same purpose (to train airline boarding agents to identify and thereby deny boarding to improperly documented passengers on flights bound for the United States), the curricula used by the various offices can vary widely. For example, some training focuses more on teaching entry requirements while other training focuses more on the identification of fraudulent documents.
INS also does not evaluate the CAO's "train the trainer" program. In an effort to reach the largest number of those airline industry personnel involved with boarding passengers, INS trains airline staff to serve as trainers for fellow airline employees at overseas airports. Some airlines have their own training programs that include professional trainers. The airline industry had concerns with the "train the trainer" program, especially for airlines without a training program. The main problem cited by airline executives is the limited training (provided by INS to the airline employee being trained as a trainer) could not impart the level of expertise in INS policy, laws, and fraudulent documents that would enable the airline employee to be a competent trainer in these areas. Two other problems were cited in regard to airlines that do not have a training organization. First, the employees of those airlines were hired to perform the duties of airline employees and may not have the personality/ability to be effective teachers, and second, creating a professional training organization is costly for those airlines.
With an effective INS evaluation program, INS could determine optimum curricula and implement more effective training programs.
The CAO Does Not Have Information on How Many Airline Personnel Need Training
INS has not developed a credible estimate of the number of airline industry personnel who need training. Without this information, INS cannot plan its training effort and devote sufficient resources to the effort. While airline employee training is performed by different INS offices around the world, the CAO is INS's centralized program for coordinating reports on the total number of airline industry personnel trained by INS each year.
The records maintained by the CAO do not have accurate figures on actual airline industry personnel who have been trained. The CAO reported that INS provided airline industry training to 9,606 individuals world-wide, but this number includes non-airline industry personnel such as foreign officials and others who do not make determinations on whether to board airline passengers. INS does not know how many airline industry personnel were actually trained.
The airline industry estimates that less than 20 percent of those needing training have been trained. Due to high airline industry turnover and the need for refresher training, the airlines require cyclical INS training for overseas airline employees who board passengers. The refresher training is needed because the deceptive schemes for entering the United States illegally and the fraudulent documents used to gain entry change over time. The industry executives we interviewed estimated that such training was needed every year or two. Based upon rough estimates from INS and the airline industry, approximately 40,000 airline employees still need training. INS has not developed a methodology to get credible estimates of the number of personnel needing training, and thus has no comprehensive plan to address such extensive training needs on a continuing basis, or to allocate resources to meet the needs.
INS Does Not Maintain a Centralized Schedule of All Planned INS Airline Training and Cannot Therefore Provide Such Information to the Airlines
Based on our interviews with local airline officials, airlines have not always received advance notice of training. Advance scheduling of training is a very important issue for many airlines because they often have practical restrictions on when they can spare employees to undergo training. For example, many airlines are extremely busy due to increased tourist travel in certain months of the year. During such peak periods, they cannot spare their agents for training.
Because INS's training program is decentralized, INS does not maintain a centralized schedule of all the airline training that it intends to conduct during the year. However, the CAO does publish a schedule of the training that it specifically intends to conduct each year, which is furnished to the airline industry. Additionally the CAO considers the airline peak periods in planning its schedule. The major ports that conduct training (i.e., JFK and Miami) also attempt to provide advance schedules to airlines on the training they intend to conduct. Approximately 75 percent of the airline training is independently conducted by various INS overseas offices that coordinate their own training schedules. Given the lack of a comprehensive INS training schedule, the airline industry reports that it is unclear on all its options for receiving training. Lacking a comprehensive training schedule, INS cannot maximize the use of its current training resources.
Recommendations on Training
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