Indian Trust Funds:

Improvements Made in Acquisition of New Asset and Accounting System But Significant Risks Remain

AIMD-00-259: Published: Sep 15, 2000. Publicly Released: Sep 15, 2000.

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Pursuant to a congressional request, GAO evaluated the Department of the Interior's effort to acquire and develop its new Trust Asset and Accounting Management System (TAAMS), focusing on: (1) actions Interior has taken in response to GAO's previous reviews and recommendations; and (2) the business and technical risks and challenges still confronting Interior as it begins to deploy TAAMS.

GAO noted that: (1) Interior is taking positive actions to address several of the concerns raised in GAO's 1999 reports as well as additional concerns raised in GAO's subsequent briefings on TAAMS testing efforts; (2) Interior has taken actions to strengthen its testing processes; (3) Interior is beginning to develop an information systems architecture for Indian trust management which is needed to ensure that trust fund and related systems are interoperable, function together efficiently, and are cost-effective over their life cycles; (4) these actions are good steps toward enhancing management of the TAAMS effort; (5) however, there are a number of major business and technical challenges that still put the TAAMS effort at considerable risk; (6) as to the business challenges, Interior has not yet completed actions designed to enhance overall trust fund management, including its efforts to revamp policies and procedures for the entire trust management cycle and to address long-standing internal control weaknesses; (7) both efforts could have a significant impact on TAAMS because they may require new features to be built into the system or current capabilities to be modified and, in turn, increase the risk of introducing new system defects; (8) fixing such defects late in the development effort can be very costly; (9) in addition, Interior has not reengineered the business processes that TAAMS is to support even though these processes were designed in a very different system environment; (10) without taking time now to examine and revise its business processes, Interior will not be able to maximize the benefits that can be gained from TAAMS and it may perpetuate outmoded ways of doing business; (11) on the technical side, there are actions underway to strengthen Interior's management of the TAAMS project, such as hiring a contractor to evaluate data integrity and the adoption of more disciplined testing processes; and (12) there are challenging undertakings still ahead.

Recommendations for Executive Action

  1. Status: Open

    Comments: In January 2002, the Secretary of the Interior initiated an effort to develop a comprehensive, department-wide approach for improving Indian trust management. On March 28, 2003, Interior issued the Comprehensive Trust Management Plan, which presented a strategic plan to guide the design and implementation of integrated trust reform efforts, including organizational reform and business transformation as well as systems architecture and a higher level of systems integration. Under the comprehensive plan, Interior placed trust management reform activities under a new Assistant Secretary for Trust Management, separating it from other Bureau of Indian Affairs (BIA) operations, to provide more focus on trust management reform. During fiscal year 2007, BIA and the Office of Special Trustee (OST) converted leasing data from BIA's old legacy systems to the Trust Asset and Accounting System (TAAMS) and integrated TAAMS with its Trust Fund Accounting System (TFAS) to ensure that both systems have accurate and complete title and leasing information. Further, as each Interior region's system was converted, the Office of Special Trustee was to provide beneficiaries with asset statements that identified the source of funds and a listing of assets owned in that region and any active encumbrances, as required by the American Indian Trust Fund Management Reform Act of 1994 (Pub.L. 103-414). Prior to system conversion, statements that beneficiaries received only included information on account balances and account transactions. In addition, Interior implemented a data quality and integrity project to verify the completeness and accuracy of TAAMS title and leasing information for Indian lands. On December 8, 2009, Interior Secretary Ken Salazar established the Secretarial Commission on Indian Trust Administration and Reform by Sec. Order No. 3292. The Commission held a series of hearings over a 2-year period and determined that sweeping reforms were needed. In August 2013, Interior announced a new Chief Information Officer (CIO) with responsibility for advancing the Department's ongoing IT Transformation efforts. The new CIO previously held positions as Interior's Director of Information Planning in the Office of the Assistant Secretary for Indian Affairs and Chief for Portfolio Management in the Office of the CIO. TAAMS underwent technical upgrades to meet the Department's technology and security architecture requirements for all system operating on the Indian Affairs network. TAAMS upgrades included (1) enhanced search and retrieval capability; (2) a single user ID and a single password logon; (3) Web-based navigational features (i.e., menus, drop-down lists and tabs); and (4) the ability of tribes using VPN to connect to the Interior site to print reports to any stand-alone or network printer from their desktop. A new release of TAAMS was targeted to be deployed on September 25, 2015, with tribes verifying the accuracy of their data conversion to the new TAAMS system. Tribal training followed the TAAMS conversion. BIA management and trust systems officials advised us that TAAMS implementation was delayed until July 6, 2016. We requested and are awaiting documentation to confirm full implementation of the TAAMS conversion and identify any remaining issues.

    Recommendation: To ensure that TAAMS is fully aligned with trust management needs and that Interior's use of the systems is optimized, the Secretary of the Interior should direct the Assistant Secretary for Indian Affairs to work with the Special Trustee for American Indians to do the following before phase II of TAAMS: (1) examine and revise business processes supported by TAAMS; (2) properly develop and implement data conversion plans; and (3) evaluate and revise policies, procedures, and internal controls relating to TAAMS: ensure that top trust fund managers across the department participate in this effort; and ensure that any needed modifications to TAAMS are made and tested.

    Agency Affected: Department of the Interior

  2. Status: Open

    Comments: According to BIA management and trust systems officials, the new CIO approved in August 2013 and BIA Director worked together to implement disciplined acquisition and software development processes. We have requested and are awaiting documentation on the details of BIA's actions to establish such disciplined processes.

    Recommendation: To facilitate Interior's adoption of disciplined software and acquisition processes, the Secretary of the Interior should direct the Chief Information Officer to evaluate existing software development and acquisition processes against the Capability Maturity Models developed for these activities by the Software Engineering Institute, implement disciplined processes where they are lacking, and regularly assess progress in this regard.

    Agency Affected: Department of the Interior

  3. Status: Open

    Comments: In June 2001, Interior contracted with an information technology firm to develop, define, and document requirements for trust asset management. In January 2002, the Secretary of the Interior initiated an effort to develop a comprehensive, department-wide approach for improving Indian trust Management. In March 2003, Interior issued the Comprehensive Trust Management Plan, which presented a strategic plan to guide the design and implementation of integrated trust reform efforts, including organizational reform and business transformation along with a systems architecture and higher level of systems integration. According to BIA management and trust systems officials the new CIO who took over in August 2013 and the Director of BIA worked together to implement disciplined acquisition and software processes. Interior defined TAAMS requirements under revised business processes supported by TAAMS and performed a gap analysis to assess whether TAAMS was capable of providing necessary functionality and what modifications, if any, were needed. We have requested and are awaiting documentation for the disciplined processes that were implemented.

    Recommendation: To facilitate Interior's adoption of disciplined software and acquisition processes, the Secretary of the Interior should direct the Chief Information Officer to ensure that contractors used by Interior to develop software systems have implemented disciplined software development processes.

    Agency Affected: Department of the Interior

  4. Status: Open

    Comments: In June 2001, Interior contracted with an information technology firm to develop, define, and document requirements for trust asset management. In January 2002, the Secretary of the Interior initiated an effort to develop a comprehensive, department-wide approach for improving Indian trust Management. In March 2003, Interior issued the Comprehensive Trust Management Plan, which presented a strategic plan to guide the design and implementation of integrated trust reform efforts, including organizational reform and business transformation along with a systems architecture and higher level of systems integration. According to BIA management and trust systems officials the new CIO who took over in August 2013 and the Director of BIA worked together to implement disciplined acquisition and software processes. Interior defined TAAMS requirements under revised business processes supported by TAAMS and performed a gap analysis to assess whether TAAMS was capable of providing necessary functionality and what modifications, if any, were needed. We have requested and are awaiting documentation on the details of the disciplined processes that were implemented.

    Recommendation: To facilitate Interior's adoption of disciplined software and acquisition processes, the Secretary of the Interior should direct the Chief Information Officer to define and manage the requirements that TAAMS should meet using accepted processes. Once the requirements have been adequately defined, perform a gap analysis to assess whether TAAMS is capable of providing the necessary functionality and what modifications, if any, are necessary to address Interior's needs. If modifications are needed, then Interior should develop the cost, schedule, and performance impacts of making those modifications.

    Agency Affected: Department of the Interior

  5. Status: Open

    Comments: Following the August 2013, appointment of a new Chief Information Officer (CIO), TAAMS underwent technical upgrades to meet the Department's technology and security architecture requirements for all systems operating on the Indian Affairs network. According to BIA trust systems officials, the technical upgrades included an analysis of the infrastructure necessary to support the TAAMS application to ensure its adequacy as well as steps to ensure that TAAMS could interface with Trust Fund Accounting System (TFAS)and the Mineral Management (MMS) System. Additional interfaces were developed with systems that maintained lease and ownership information. We requested and are awaiting documentation on these actions.

    Recommendation: To ensure that TAAMS can properly interoperate with other trust fund systems, GAO reiterates its recommendation to the Secretary of the Interior to develop an information systems technology architecture for trust fund operations. In the interim, the Secretary should direct the Chief Information Officer to: (1) perform an analysis of the infrastructure necessary to support the TAAMS application and ensure its adequacy; and (2) ensure that TAAMS can interface with TFAS and MMS systems.

    Agency Affected: Department of the Interior

 

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