The projects are directed at improving systems, enhancing the accuracy  and completeness of Interior’s data regarding the ownership and lease of  Indian lands, and correcting deficiencies with respect to records  management, training, policy and procedures, and internal controls within  3 years. Scope and Methodology

The objectives of our review were to assess whether Interior has  reasonable assurance that (1) the High Level Plan provides an effective  solution for addressing long-standing problems with Interior’s Indian trust  responsibilities and (2) its acquisition of a new asset and land records  management service will cost effectively satisfy trust management needs. To determine whether Interior has reasonable assurance that the High  Level Plan provides an effective solution for addressing Interior’s long- standing problems with its Indian trust responsibilities, we reviewed the Clinger-Cohen Act of 1996 and current technical  literature as a basis for assessing the information technology aspects of  the High-Level Plan; reviewed the process that was used to develop the plan; reviewed the Strategic Plan that was produced by Interior’s Special  Trustee for American Indians; met with senior Interior officials responsible for developing the plan,  including Interior’s Chief Information Officer, Chief Financial Officer,  Deputy Special Trustee, and the Interior contractor who assisted in the  development of the plan; and analyzed the High Level Plan for internal consistency and compliance  with generally accepted best practices. Specifically, Interior did not adequately define important  service requirements or sufficiently analyze technical alternatives. Further,  Interior did not develop an overall risk management plan, require the  contractor to demonstrate its system could work with Interior’s data and  systems, or establish realistic project time frames. First, Interior did not develop a risk management plan. As a result, Interior will not know whether the contractor’s system can  interoperate with its legacy systems. Because it did not establish clear requirements and did not take critical  steps to manage risk effectively, Interior has no assurance that the new  asset and land records management service will meet its specific  performance, security, and data management needs or that the service can  be delivered on schedule and within budget. Conclusions

Interior cannot realistically expect to develop compatible and optimal  information systems without first developing an information systems  architecture for Indian trust operations. Interior also disagrees with the report’s second conclusion that Interior  does not have reasonable assurance that its acquisition of the new asset  and land records management (TAAMS/LRIS) service will cost effectively  satisfy trust management needs. Interior then describes several actions which it feels minimizes acquisition  risk. GAO Comments

1. 2. 4. 5. 6. 7. 8. 9.
Why GAO Did This Study

Pursuant to a congressional request, GAO evaluated the Department of the Interior's High-Level Implementation Plan for improving its management of the Indian trust funds and resources under its control, focusing on whether the Interior has reasonable assurance that: (1) the High-Level Plan provides an effective solution for addressing its long-standing problems; and (2) its acquisition of a new asset and land records management service will cost effectively satisfy trust management needs.

What GAO Found

GAO noted that: (1) Interior does not have reasonable assurance that its High-Level Plan for improving Indian trust operations provides an effective solution for addressing long-standing management weaknesses; (2) the plan: (a) recognizes the severity of long-standing weaknesses in managing trust fund assets; (b) identifies 13 projects intended to improve information systems, enhance the accuracy and completeness of its data regarding the ownership and lease of Indian lands, and address deficiencies with respect to records management, training, policy and procedures, and internal controls; and (c) assigns responsibility for oversight and management of the 13 projects; (3) however, Interior has not properly analyzed its information technology needs which are essential to the overall success of the plan; (4) until Interior develops an information systems architecture addressing all of its trust management functions, it cannot ensure that its information systems will not be duplicative or incompatible or will optimally support its needs across all business areas; (5) Interior also does not know whether its acquisition of a new service for managing Indian assets and land records will cost-effectively meet trust management needs; (6) before deciding to contract with a service vendor, Interior did not adequately define important service requirements or sufficiently analyze technical alternatives; (7) Interior also did not take the steps needed to minimize acquisition risks; (8) in particular, it did not develop a risk management plan, ensure that the vendor's system could work with Interior's data and systems, or establish realistic project timeframes; and (9) thus, Interior faces an unnecessarily high risk that the service will not meet its general business and specific performance needs, and it lacks the means for dealing with this risk.