Transportation Worker Identification Credential: Mailing Credentials to Applicants' Residences Would Not Be Consistent with DHS Policy Page: 3 of 14
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To assess the factors affecting DHS's ability to mail cards to an approved applicant's
residence or enrollment center of choice, we reviewed existing processes for TWIC
production, personalization, activation, and issuance. We analyzed documentation
provided by TSA regarding TWIC program systems and processes, such as the TWIC
User Manual for Trusted Agents, concept of operations, and statement of work. We
also reviewed information provided by USCIS on its credential production and
personalization process, such as information on the Secure Mail Initiative.5 We
interviewed TSA and USCIS officials about the feasibility of mailing cards to an
applicant's residence or enrollment center of choice. We also interviewed relevant
officials from the TSA TWIC contractor to discuss the possibility of modifying the
current TWIC card production and mailing processes.
To identify the security implications associated with mailing cards to an individual's
residence or enrollment center of choice, we analyzed pertinent regulations, policies,
and guidance establishing requirements for secure issuance of credentials.! We
interviewed officials from TSA and SCO to identify how security requirements were
identified for the TWIC processes and obtain views on how changes to the TWIC
activation and issuance process might affect security. We interviewed officials from
USCIS to obtain information about their approach to securely mailing other
government credentials to individual residences. We also interviewed officials from
the Department of Commerce's National Institute of Standards and Technology
(NIST) to confirm our understanding of Federal Information Processing Standards
(FIPS) Publication 201-1 requirements and security standards, and officials from the
Coast Guard to identify what impact the mailing of TWICs might have on compliance
and enforcement.
To determine costs DHS has associated with mailing cards to an applicant's residence
or enrollment center of choice, we analyzed TWIC program fee requirements as
established in the TWIC rule and supporting regulatory evaluation to understand the
costs related to the current activation and issuance process, and how changes to the
issuance process could influence program fees. We also reviewed GAO's Cost
Estimating and Assessment Guide and DHS's Cost Benefit Analysis Guidebook to
determine the required elements for estimating costs and DHS requirements for
conducting a cost-benefit analysis.7 We interviewed officials from TSA and USCIS
about the cost implications of mailing cards to an applicant's residence or enrollment
center of choice.
Our work for this report was also informed by ongoing work we are conducting for
your committees and others evaluating the extent to which TWIC program controls
6 USCIS's Secure Mail Initiative utilizes the United States Postal Service's Priority Mail with Delivery
Confirmation service to enhance accountability and customer service in the delivery of secure
immigration documents to customers. This initiative allows USCIS to prove when secure documents
were mailed, and allows customers to track their documents through the mailing process.
6 See, for example, Federal Information Processing Standards (FIPS) Publication 201-1, Personal
Identity Verification (PIV) of Federal Employees and Contractors (Gaithersburg, Md., March 2006),
and National Institute of Standards and Technology Special Publication 800-63, Electronic
Authentication Guideline (Gaithersburg, Md., April 2006).
See GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and
Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March 2009), and Department of
Homeland Security, Cost Benefit Analysis Guidebook, Version 2.0 (Washington D.C., February 2006).GAO-11-542R Mailing TWICs to Residences and Enrollment Centers
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United States. Government Accountability Office. Transportation Worker Identification Credential: Mailing Credentials to Applicants' Residences Would Not Be Consistent with DHS Policy, text, April 13, 2011; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc301629/m1/3/: accessed March 18, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.