Quick Response Audits (QRA) are single-issue audits with a narrow focus. These audits are designed to address a specific objective within a short period of time.
QRA is a term used to cover a variety of audits that will have limited objectives as opposed to the complete evaluation of a company's Customs and Border Protection (CBP) activities in the focused assessment program. Because audit objectives vary among QRA, a universal audit program cannot be established and used for all QRA.
Examples of a QRA might be an audit of an importer's CBP operations to determine if there is a potential for unlawful transshipment or an audit of the company’s controls concerning intellectual property rights. Generally, QRA originate from referrals by other CBP and Homeland Security offices utilizing risk management principles to identify specific companies involved in certain types of transactions.
CBP Policy for Audits of ISA Approved Companies
One of the major benefits of the ISA program is that the ISA member company is withdrawn from the Focused Assessment audit pool. This means that because of the company’s demonstrated compliance level and willingness to partner with CBP, the company will not be considered a candidate for routine Focused Assessments. CBP has always stipulated that ISA membership did not grant total immunity from any CBP single focus inquiry where the identification of a specific risk by CBP was sufficient to warrant a review of the transactions associated with the particular issue.
In such instances, CBP and the importer will work together to determine a mutually acceptable course of action whenever possible. However, it is unlikely that an ISA approved company, with established internal controls, would be the subject of a referral audit.
QRA of ISA Applicants
If a company that is applying for ISA or is contemplating applying for the program is notified that it has been selected for a QRA, some element of the importer’s transactions have been identified as a potential risk. Consequently, CBP will have to resolve the risk issue, either through the scheduled QRA or through the ISA review process. Any potential high-risk issues must be resolved before a company can be approved for ISA.
In some cases with a specific identified risk, it would be more practical and efficient to have the audit team that is scheduling the QRA conduct the review and furnish their results to the ISA review team.
In other cases it may be possible for the ISA review team to complete the audit work if it is within the scope of the ISA review process. The timing and the identity of the specific audit team conducting the work will be decided on a case-by-case basis depending upon the audit team best suited to do the work. In most cases, it will be in the best interests of the company that is applying for ISA to resolve the immediate issue before the actual ISA review. A resolution of an outstanding issue will expedite the ultimate decision of CBP as to the company’s eligibility for ISA.