CBP Completes Gap Analysis for its ITDS ConOps
The International Trade Data System has posted the Executive Summary of U.S. Customs and Border Protection’s ITDS concept of operations (ConOps) gap analysis of CBP’s ConOps and the ConOps of key admissibility Participating Government Agencies.
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(In January 2010, the CBP Office of International Trade (OT) completed and approved the CBP ITDS ConOps. The ConOps describes the anticipated future import processes to be used by CBP in ACE. The ConOps serves as the foundation to incorporate the future vision of CBP business practices into ACE.
Upon completion of the ConOps, CBP/OT determined that among the next steps was to commission a Phase 2 effort during which a team would perform a gap analysis. This analysis helps to verify the applicability of the CBP Business Processes defined in the CBP ConOps, as well as support the further definition of CBP and PGAs ACE Business Processes needs. The gaps found in the analysis represent the areas of fine-tuning that will need to occur in the future.)
ACE/CBP Team Performed Analysis, Identified Six PGAs
A team composed of members from the ACE Modernization Support Team (MST) and CBP/OT was formed to perform this analysis (team). For this effort, CBP identified six PGAs. The PGAs were selected based on their agency’s role in determining admissibility and their completion of a CBP-approved ConOps. In addition, CBP wanted to include PGAs whose ConOps represent a variety of complex import business processes.
The agencies selected as part of this effort were: (1) Food and Drug Administration (FDA); (2) Animal and Plant Health Inspection Service (APHIS); (3) Food Safety and Inspection Service (FSIS); (4) Environmental Protection Agency (EPA); (5) National Marine Fisheries Service (NMFS); and (6) Coast Guard (CG).
These PGAs reviewed the gap reports produced by the team and provided their feedback regarding their Business Processes most important to their admissibility missions.
Gap Analysis Shows Over 80% of Functions PGAs Expected in CBP ConOps Satisfied
The analysis of the six PGAs shows that more than 80% of the functions the PGAs expected to be in the CBP ConOps were satisfied. However, the result may be different when additional PGAs are analyzed.
The gaps noted represent the areas of fine-tuning that will need to occur in the future. CBP realizes there will be exceptional processes that may remain unique to a PGA, and so attaining zero gaps is not practical. In those instances, automation cannot substitute for inter-agency coordination. In addition, it is anticipated that new gaps may be identified as the PGA and CBP business processes are further developed.
CBP ConOps Appears to Have Increased Number of Notifications in ACE
The analysis also notes that the CBP ConOps appears to have increased the number of notifications in ACE that will go to various interested parties.
Generic Processes May be Added to ConOps, CBP Could Consider Other Functionality
In addition to the analysis, the team created 16 Generic Process flow diagrams to describe processes that were depicted in the CBP ConOps, but were not defined when the CBP ConOps was developed. These Generic Processes could be accepted as an addendum to the CBP and PGA ConOps. Examples of these generic processes include creating reports and maintaining reference files.
Other functionality that CBP could consider developing or updating in the future to satisfy other PGA needs include General Order (GO), Prior Notice (PN), sending samples to the lab, and Conduct Targeting.
Analysis Provides Foundation for Complete Business Needs Document
This analysis provides a foundation for a complete business needs document that can lead to future ACE requirements. The mappings and other repository information can be combined and analyzed to give a broader picture of the overall needs of CBP and the PGAs in ACE.
(See ITT’s Online Archives or 08/11/10 news, 10081113, for BP summary of CBP officials providing an update on CBP’s ConOps.
See ITT’s Online Archives or 06/16/10 news, 10061655, for BP summary announcing that CBP was trying to make its ConOps available to the trade, etc.
See ITT’s Online Archives or 04/20/10 news, 10042026, for BP summary of CBP discussing its own ITDS ConOps.
See ITT’s Online Archives or 03/24/10 news, 10032410, for BP summary announcing that CBP completed Phase 1 of its ConOps.)