By Eileen Mayer, Chief, Criminal Investigation Division, Internal Revenue Service, Washington, D.C.
n the United States, the accreditation of state and local law enforcement agencies is a well-established process that enhances the professionalism of public safety services. The benefits of accreditation are many, including providing the public a measure of assurance that an institution has voluntarily engaged in an evaluation process that ensures it has met peer-established standards for quality, efficiency, integrity, and effectiveness.
Until recently, federal law enforcement agencies did not have a similar process to earn accreditation. However, since 2005, the Federal Law Enforcement Training Accreditation (FLETA) Board has accredited nine federal law enforcement training academies. Among the first to earn accreditation was the Internal Revenue Service (IRS) National Criminal Investigation Training Academy (NCITA). The FLETA Board has also accredited two NCITA training programs.
The NCITA, located in Glynco, Georgia, at the Federal Law Enforcement Training Center (FLETC), is the training academy for the IRS Criminal Investigation Division (CI). CI special agents are duly sworn law enforcement officers who investigate complex financial crimes associated with tax evasion, money laundering, illegal narcotics, organized crime, public corruption, terrorism, violations of the Bank Secrecy Act, and much more. Special agents’ accounting and law enforcement skills are essential qualities in conducting investigations that lead to the conviction of criminals who are committing increasingly sophisticated financial crimes. Whenever money leads to crime, CI is usually involved.
The NCITA trains new CI special agents in the fundamentals of financial investigation, including the elements of criminal tax offenses, methods of proof for federal tax investigations, and the special skills and abilities to be financial investigators. With a conviction rate of over 90 percent, highly skilled CI special agents are considered to be among the best financial crime investigators in the world.
Developing Federal Training Accreditation
The NCITA has been involved in the development of a federal law enforcement accreditation process since the inception of this process. The need for federal law enforcement training standards and accreditation became much more important following several high-profile and highly publicized incidents in the 1990s. These incidents raised questions about the ability of federal law enforcement agencies to carry out their missions and effectively use their training resources. The public clearly needed assurance that the more than 80 federal law enforcement agencies in existence, both military and civilian, were meeting a standard of excellence that ensured the effective delivery of law enforcement services while protecting constitutional rights.
Responding to these concerns, in 2000 the U.S. Office of Management and Budget provided funding for the FLETC to form a task force to develop standards and an accreditation process for federal law enforcement training. The task force comprised representatives from federal law enforcement training academies, including the NCITA, the Commission on Accreditation for Law Enforcement Agencies, the International Association of Directors of Law Enforcement Standards in Training, and state peace officer standards and training commissions.
The task force worked for two years to develop professional standards for federal law enforcement training programs and academies as well as procedures for evaluating, granting, and maintaining accreditation. The accreditation process became known at this time as FLETA.
In 2002, the FLETA Board was officially appointed to take over the work of the task force. The board approved the first federal law enforcement standards in 2003, with a goal to accredit all federal law enforcement academies and training programs. In addition to the board, the Office of Accreditation (OA) provides the framework and support necessary for federal agencies to apply for accreditation, receive accreditation manager training, and maintain the proofs of compliance with the standards.
To receive FLETA accreditation and maintain it, federal law enforcement academies must apply not only for overall academy accreditation but also for their basic training and instructor development programs. Academies have three years from the date they apply to obtain accreditation for their basic and instructor training. The NCITA elected to apply for all three at the same time. The FLETA Board accredited the NCITA and its Special Agent Basic Training (SABT) in November 2006, and accreditation for Basic Instructor/Facilitator Training followed in March 2007.
The accreditation process has five major phases: application, self-assessment, FLETA assessment, board review, and accreditation. As part of the accreditation process, the NCITA underwent a comprehensive assessment of its academy and programs. This independent assessment, performed by peers from various federal law enforcement agencies, focused on the following areas: academy administration, qualifications and development of training staff, program administration, and program and curriculum development. The assessment included a thorough review of NCITA policies, procedures, and compliance with FLETA standards.
To maintain accreditation, the NCITA must continue to comply with 193 FLETA standards (73 standards for the academy accreditation and 60 for each of the two accredited programs), provide the FLETA with annual reports showing standards-related changes in its programs, and repeat the self-assessment and FLETA assessment process every three years.
CI Agent and Instructor Training
The SABT program starts with a three-day NCITA prebasic orientation program, followed by a 10-week FLETC Criminal Investigator Training Program (CITP). (CITP is a FLETA-accredited FLETC program.) The FLETC is the interagency law enforcement training organization for over 80 federal agencies. Most federal trainee special agents from such agencies as Immigration and Customs Enforcement; the Bureau of Alcohol, Tobacco, Firearms, and Explosives; and the Secret Service, and many others, jointly attend the CITP.
After completing the FLETC CITP, CI special agent candidates must then complete the 15-week NCITA Special Agent Investigative Techniques (SAIT) program. The SAIT program, which is a part of the SABT program, is a combination of classroom instruction and practical exercises that prepares special agents to become proficient criminal investigators. Since 1996, the NCITA has provided training using student-centered facilitation techniques based on the best practices of adult learning. Some traditional classroom instruction remains, but most classes use team-building practical exercises and role playing to reinforce key concepts.
The SAIT program covers tax law, criminal tax fraud, money laundering, and other fraud schemes. Students are also introduced to enforcement operations, undercover operations, electronic surveillance techniques, forensic science, court procedures, computer investigative techniques, trial preparation, and testifying. Throughout their careers, CI special agents return to the NCITA for advanced training and continuing professional education.
Since 1986, the NCITA has trained its own instructors. Previously, CI sent its agents to IRS Basic Instructor Training, but with too few training slots available to meet its needs, CI decided to develop its own instructor training program. Many federal academies rely on the FLETC to train their instructors, but CI remains committed to its internal instructor training program, which is considered a model for other law enforcement agencies.
The NCITA also provides advanced training for CI special agents, continuing professional education for all CI employees, training for CI investigative support staff, and computer training. This means that accreditation has much wider ramifications for the NCITA than for other federal law enforcement training academies. While not all of CI’s individual training programs are accredited, the NCITA must develop, deliver, and document each program under the FLETA’s demanding standards.
The accreditation process for the NCITA took only 11 months to complete, a much shorter period of time than for most law enforcement academies. The NCITA applied for accreditation in January 2006 and completed its self-assessment and FLETA assessment by September of that year. However, because the FLETA Board meets only three times a year, the NCITA had to wait for the November 2006 board meeting to receive accreditation approval.
Depending on the scale of the applicant training program and whether the applicant can dedicate staff to the process, the FLETA OA advises that the accreditation process could take three or more years to complete. What set the NCITA apart from other academies was that it already had many of the basics in place to meet FLETA standards. It did not have to start from scratch or redesign anything it was already doing. The NCITA primarily needed to compile the documentation necessary to demonstrate that it was already meeting the FLETA standards. Nevertheless, this still required a massive effortthe NCITA submitted over 400 pieces of evidence as proof that it was complying with FLETA standards.
The NCITA could not have completed the accreditation process so quickly without a staff dedicated to working solely on accreditation. In November 2005, then NCITA director Lane Timm assigned a new staff person solely to achieving accreditation. A few months later, she assigned a second person to the process. This forced other staff members to take on the second staff person’s original responsibilities, but it also ensured that the process would be completed quickly and successfully. The NCITA did not receive any additional funds for accreditation; it worked within its existing budget. This also strained the NCITA’s limited resources, but Timm was determined to let no obstacle stand in the way of accreditation, and she had CI’s full support for this effort. The NCITA now has one full-time accreditation manager to ensure that it maintains its accreditation.
Obtaining accreditation can be costly and time consuming, but the cost of not pursuing accreditation can be even greater. One of the primary benefits of accreditation is that it gives CI special agents greater credibility when they go to court to testify. Additionally, it helps minimize or eliminate entirely lawsuits and liability based on an agent’s training and/or an agency’s failure to properly train an agent. With the success or failure of a money laundering, tax evasion, narcotics, terrorism, or other prosecution often resting on the credibility of the investigating agent, accreditation can become a key factor in a conviction.
Accreditation has benefited CI in numerous, positive ways. It has raised the NCITA’s profile among federal law enforcement agencies as many of them turn to CI’s experienced accreditation staff for help and guidance as they embark on this arduous process; it has raised morale throughout CI and reinforced the esprit de corps of the entire CI workforce; and it has solidified CI’s reputation as having the finest financial investigatorsworldwide.
In the future, the NCITA plans to submit applications for accreditation for several more of its training programs. The NCITA’s full-time accreditation manager is also already gearing up for reaccreditation in 2009.
A Growing Trend
In addition to the NCITA, other accredited federal law enforcement training academies include the U.S. Department of State Diplomatic Security Training Center; the U.S. Air Force Office of Special Investigations Academy; the U.S. Postal Inspection Service Career Development Division; FLETC’s U.S. Secret Service James J. Rowley Training Center; the Naval Criminal Investigative Service Training Academy; the U.S. Transportation Security Administration Federal Air Marshal Training Center; and the U.S. Coast Guard Marine Law Enforcement Training Center. The FLETA Board has also awarded accreditation to 25 training programs at these academies.
The FLETA Office of Accreditation has over 80 applications for accreditation pending. Although accreditation is currently voluntary for all federal law enforcement agencies, this could change in the future. The Office of Management and Budget is considering making funds for law enforcement training academies contingent on accreditation status.
For further information about CI or pursuing a career as a CI special agent, readers can visit the Web site at http://www.irs.gov/compliance/enforcement/index.html. For further information about FLETA and the accreditation process, readers can visit its Web site at http://www.fleta.gov/accreditation. ■