CSMS Message: 94-001113

REVISED PROPOSAL ON REMOTE FILING (NOVEMBER 94)

BACKGROUND

THE ORIGINAL "CONCEPT PAPER" CONTAINING THE THREE PHASE CONCEPT OF
REMOTE FILING WAS PRESENTED TO THE TRADE IN JUNE. SINCE THAT TIME
THERE HAS BEEN A CONSIDERABLE AMOUNT OF DISCUSSION WITH THE TRADE, AND
WITHIN THE AGENCY, ON HOW REMOTE FITS IN WITH OTHER MAJOR INITIATIVES
TAKING PLACE. THE TWO AREAS HAVING THE MOST IMPACT ARE THE CUSTOMS
REORGANIZATION AND THE REDESIGN OF ACS BEING LED BY THE AUTOMATED
COMMERCIAL ENVIRONMENT (ACE) TEAM.

CHANGE IN STRATEGY

SINCE OUR ORIGINAL CONCEPT PAPER IN JUNE SIGNIFICANT PROGRESS HAS BEEN
MADE REGARDING THE REORGANIZATION AND THE ACE PROJECT. THE CURRENT
FEELING IS THAT "REMOTE FILING" NEEDS TO BE PLACED IN CONTEXT WITH THE
BUSINESS PROCESS REENGINEERING (BPR) WORK BEING DONE ON THE
REORGANIZATION, AND THE REDESIGN EFFORT OF THE ACE TEAM. IT SHOULD BE
USED AS A PROTOTYPE, BOTH TECHNICALLY AND OPERATIONALLY, FOR ACE.

BPR IS STRESSING TWO KEY CONCEPTS: ACCOUNT BASED PROCESSING AND A
"SINGLE DECLARATION" THAT WILL ALLOW US TO DO A COMPREHENSIVE RISK
ANALYSIS. REMOTE FILING IS A LONG TERM PROJECT THAT WILL EVOLVE OUT
OF HOW WE REINVENT THE CUSTOMS SERVICE. THE BPR PROCESS THAT WE ARE
GOING THROUGH WILL BE THE ROAD MAP, AND THE ACS REDESIGN WILL BE
CLOSELY COORDINATED WITH THAT PROCESS.

IN ORDER TO BLEND REMOTE IN WITH THE WORK BEING DONE ON THE
REORGANIZATION AND ACE, IT IS NOW PROPOSED THAT WE CONDUCT TWO
"PROTOTYPES" IN A CONTROLLED ENVIRONMENT WITH A LIMITED NUMBER OF
PARTICIPANTS AND LOCATIONS. THESE PROTOTYPES WILL ALLOW US TO GAIN
SOME EXPERIENCE WITH REMOTE AND TO LATER INCORPORATE THE WORK DONE BY
THE BPR GROUPS.

PARAMETERS

1. WE WILL COMBINE FEATURES OF PHASES I AND II AS OUTLINED IN
THE ORIGINAL CONCEPT PAPER. THIS WILL INCLUDE DESIGNATED
EXAM SITES. (CHANGE IN CUSTOMS ORIGINAL POSITION)

2. PARTICIPANTS IN THE PROTOTYPE MUST MEET THE LEGISLATIVE
REQUIREMENTS OF REMOTE ENTRY FILING. THEY MUST HAVE THE
CAPABILITY TO PROVIDE ON AN ENTRY-BY-ENTRY BASIS FOR THE
FOLLOWING:
A. THE ELECTRONIC ENTRY OF MERCHANDISE;
B. THE ELECTRONIC ENTRY SUMMARY OF REQUIRED INFORMATION;
C. THE ELECTRONIC TRANSMISSION OF INVOICE INFORMATION;
D. THE ELECTRONIC PAYMENT OF DUTIES FEES, AND TAXES.

3. CARGO RELEASE MUST BE CERTIFIED FROM THE ABI ENTRY SUMMARY
(EI) TRANSACTION. THIS WOULD HELP SUPPORT OUR ATTEMPT TO
MOVE TO A SINGLE ENTRY DECLARATION. (SAME AS CUSTOMS
ORIGINAL POSITION.) SEE NOTE (4) FOR ADDITIONAL INFORMATION
ON BORDER TRANSACTIONS.

4. REMOTE FILING WILL BE ALLOWED ON IMMEDIATE DELIVERY RELEASES
FOR DIRECT ARRIVAL ROAD AND RAIL FREIGHT AT THE LAND BORDER.
OTHER FORMS OF IMMEDIATE DELIVERY RELEASE AS DESCRIBED IN
CFR 142.21 WILL NOT BE ELIGIBLE FOR REMOTE. IT WILL NOT BE
NECESSARY FOR THESE TRANSACTIONS TO BE "CERTIFIED FROM
SUMMARY". PAPER INVOICES WILL BE ACCEPTABLE FOR IMMEDIATE
DELIVERY RELEASE EFFECTED UNDER LINE RELEASE, BORDER CARGO
SELECTIVITY, OR CARGO SELECTIVITY. THE ELECTRONIC INVOICE
REQUIREMENT WILL BE MET AT THE TIME OF ELECTRONIC FILING OF
THE ENTRY/ENTRY SUMMARY. (CHANGE IN CUSTOMS ORIGINAL
POSITION.)

5. REMOTE FILING WILL BE ALLOWED ON NON AMS ARRIVALS. (CHANGE
IN CUSTOMS ORIGINAL POSITION).

6. IF A SHIPMENT IS MOVED IN-BOND TO ANOTHER PORT, IT CANNOT BE
CLEARED USING THE REMOTE ENTRY FILING PROCEDURE. (SAME AS
CUSTOMS ORIGINAL POSITION.)

7. ALL PARTICIPANTS WILL HAVE TO BE CAPABLE OF USING THE
CURRENT ELECTRONIC INVOICE PROGRAMMING (EIP) WHICH INCLUDES
THE AUTOMATED INVOICE INTERFACE (AII) AND EDIFACT. WE WILL
UTILIZE THE "TEST REGS" TO ANNOUNCE THE PROTOTYPES, TO
PUBLISH THE CRITERIA, AND TO SEEK VOLUNTEERS. COMPANIES NOT
CURRENTLY EIP QUALIFIED MUST DEVELOP OPERATIONAL CAPABILITY
IN ORDER TO BE CONSIDERED FOR PARTICIPATION.

PROTOTYPES

BY APRIL 1995

OPERATIONAL WITH FIRST PROTOTYPE. SOME MINOR SYSTEM CHANGES TO
ALLOW REMOTE FILING VIA ABI. CURRENT EIP PROGRAMMING WILL BE IN
PLACE. INCLUDES TIME FOR USER REQUIREMENTS, SPECIFICATIONS,
PROGRAMMING, TESTING, AND PUBLIC NOTIFICATION UNDER THE NEW MOD
ACT TEST REGULATIONS. IT WILL REQUIRE THE USE OF EMAIL AND OTHER
MODES OF COMMUNICATION TO CONDUCT EXAMINATIONS AND INPUT
FINDINGS. FIRST TEST SHOULD LAST FOR SIX MONTHS WITH AN
EVALUATION AT THE END OF THE TEST PERIOD.

IF DESIRABLE, THE PROTOTYPE CAN BE EXPANDED "HORIZONTALLY" TO
INCLUDE MORE PARTICIPANTS AT ANYTIME DURING, OR AFTER THE INITIAL
PROTOTYPE PERIOD. ALSO, WE CAN ADD ANY OPERATIONAL FEATURES OF
"ACCOUNT PROCESSING" THAT ARE DEEMED APPROPRIATE AND REQUIRE NO,
OR MINIMAL PROGRAMMING.

BY APRIL 1996

CONDUCT SECOND PROTOTYPE TO CONTINUE TO EVALUATE OPERATIONAL
ISSUES, AND BEGIN ADDRESSING ADDITIONAL SYSTEMIC NEEDS.
INCORPORATE WORK OF PROCESS IMPROVEMENT TEAMS AND EXPERIENCE FROM
THE FIRST PROTOTYPE. IT WOULD UTILIZE THE SINGLE DECLARATION
APPROACH. MAKE SYSTEM CHANGES TO TRACK THE CARGO TO THE
DESIGNATED EXAM SITE AND INPUT OF EXAM RESULTS FROM MULTIPLE
LOCATIONS IN AN AUTOMATED ENVIRONMENT. IT IS ANTICIPATED THAT
THIS PROTOTYPE WILL BE DONE AS PART OF ACE. COMPLETION OF THIS
PHASE WILL ENABLE US TO EXPAND THE NUMBER OF COMPANIES AND PORTS
INVOLVED SIGNIFICANTLY.

PUBLIC NOTICE

THE INFORMATION CONTAINED IN THIS REVISED "CONCEPT PAPER" IS INTENDED
TO CONTINUE THE DIALOGUE WE HAVE STARTED WITH THE TRADE ON THE MAJOR
INITIATIVES CONTAINED IN THE MOD ACT LEGISLATION. AFTER RECEIVING
ADDITIONAL COMMENTS ON THIS PROPOSAL, A FORMAL NOTICE WILL BE
PUBLISHED IN THE FEDERAL REGISTER AND THE CUSTOMS BULLETIN WHICH WILL
OUTLINE THE PROCEDURES FOR THE PROTOTYPE AND THE CRITERIA FOR
PARTICIPATION IN THE PROTOTYPE. ANY COMMENTS ON THE REVISED REMOTE
ENTRY FILLING PROPOSAL CONTAINED IN THIS DOCUMENT SHOULD BE ADDRESSED
TO DALE SNELL OF THE MOD ACT TASK FORCE, FRANKLIN COURT, 1301
CONSTITUTION AVE. NW, WASHINGTON D.C. 20229; FAX NO. (202) 482-6994.

IF YOU ARE INTERESTED IN OBTAINING ADDITIONAL INFORMATION ON CUSTOMS
ELECTRONIC INVOICE PROGRAM (EIP), PLEASE CONTACT YOUR ABI CLIENT
REPRESENTATIVE. THE FILERS WHO CHOOSE TO DEVELOP EIP CAPABILITY ARE
NOT GUARANTEED PARTICIPATION IN THE APRIL REMOTE ENTRY FILING
PROTOTYPE. IT SHOULD ALSO BE NOTED THAT FOR THE APRIL 1996 PROTOTYPE,
AND FOR THE FINAL NATIONAL IMPLEMENTATION OF REMOTE ENTRY FILING, THE
CURRENT PROGRAMMING REQUIREMENTS FOR REMOTE FILING ARE LIKELY TO
CHANGE BASED ON THE WORK BEING DONE BY THE PROCESS IMPROVEMENT TEAMS.