Recommendation: The Assistant Administrator for EPA's Office of Enforcement and Compliance Assurance should clearly document in guidance to the regional offices how they should use the definition of informal enforcement actions to collect data on these actions. (Recommendation 1)

Agency: Environmental Protection Agency
Status: Open

Comments: In written comments reproduced in appendix I of this report, EPA stated that it agreed with this recommendation. In July 2020, EPA stated that in a September 30, 2019 guidance document, the agency defined an informal enforcement action. However, on March 24, 2020, the Office of Enforcement and Compliance Assurance (OECA) suspended the September guidance because informal enforcement actions as defined appear to be inconsistent with Section 6 of the White House's Executive Order (EO) 13892, Promoting the Rule of Law Through Transparency and Fairness in Civil Administrative Enforcement and Adjudication, issued on October 9, 2019. EPA said that it would amend the September 2019 guidance to be consistent with the Executive Order. Our recommendation focused on guidance on how regional offices should use the definition of informal enforcement action and we will continue to monitor EPA's implementation of this recommendation.

Recommendation: The Assistant Administrator for EPA's Office of Enforcement and Compliance Assurance should clearly document in guidance to the regional offices that they should collect data on compliance assistance activities and specify which mechanism to use to maintain the data, such as ICIS. (Recommendation 2)

Agency: Environmental Protection Agency
Status: Open

Comments: In written comments reproduced in appendix I of this report, EPA stated that it agreed with this recommendation and would collect data on compliance assistance for each of the National Compliance Initiatives and maintain those data in ICIS. Specifically, in July 2020, the agency stated that in order to further its compliance assistance efforts, the Office of Enforcement and Compliance Assistance (OECA) is including a compliance assistance tool as an important part of each of EPA's National Compliance Initiatives. According to EPA, data on compliance assistance efforts that are part of the NCI will be collected and tracked for management review in the Integrated Compliance Information System. In addition, EPA stated it has collected data in the past on webpage visits related to its national Compliance Assistance Centers and would continue to do so in the future. We will continue to monitor the status of EPA's implementation of this recommendation.

Recommendation: The Assistant Administrator for EPA's Office of Enforcement and Compliance Assurance should include the known limitations of data in its annual reports and provide information on the intended use of EPA's data. (Recommendation 3)

Agency: Environmental Protection Agency
Status: Open

Comments: In written comments reproduced in appendix I of this report, EPA stated that it agreed with this recommendation and acknowledged the importance of providing information about a dataset to facilitate proper interpretation. For that reason, EPA said that, in time for its fiscal year 2020 report, the agency will create a webpage to describe how best to interpret the data presented in its "Fiscal Year EPA Enforcement and Compliance Annual Results" report and include a reference to that webpage in the report itself as well as the "Year in Review" report. In July 2020, EPA reiterated its written comments on the report. We will update the status of EPA's implementation of this recommendation upon the release of its annual reports.

Recommendation: The Administrator of the EPA should develop a program management plan that includes a schedule of the actions EPA will take and the resources and funding it needs to establish and implement the Columbia River Basin Restoration Program, including formation of the associated Columbia River Basin Restoration Working Group, and submit this plan to the appropriate congressional authorizing committees as part of the fiscal year 2020 budget process. (Recommendation 1).

Agency: Environmental Protection Agency
Status: Open

Comments: EPA reconvened the Columbia River Toxics Reduction Working Group. As of May 2019, EPA officials told us they are working on the development of a program management plan to identify the actions and timeline for implementing the Columbia River Basin Restoration Program. In July 2019, EPA released a status update entitled, "2019 Status Update: Columbia River Basin Toxics Reduction" that provides a summary of the working group's major accomplishments since 2010, as well as priority efforts for future work. In September 2019, EPA announced the availability of $900,000 in grants to reduce toxics throughout the Columbia River Basin for the Clean Water Act Section 123 Columbia River Basin Restoration Grant Program for fiscal year 2019 through fiscal year 2020. As of October 2020, we have not received additional information from EPA regarding this recommendation. We will update the recommendation's status when we do.

Recommendation: The Director of OMB should develop and provide guidance on the types of projects and activities that agencies involved in the protection and restoration of the Columbia River Basin should include in their reports, as well as the processes they should follow in compiling the related budget and spending information. (Recommendation 2).

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: As of April 2020, OMB staff did not provide an update. When we receive an update, we will provide information on actions taken.

Recommendation: The EPA Region 10 Administrator should work with the management conference on future updates to the CCMP to help prioritize among the indicators that currently lack measurable targets and ensure that such targets are developed for the highest priority indicators where possible. (Recommendation 1)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA agreed with this recommendation, and in June 2019 EPA provided GAO with a written update on the status of actions being taken in response to the recommendation. EPA stated that the leader of the management conference, the Puget Sound Partnership, has initiated an effort to review and revise the Puget Sound recovery vital signs, including updating their associated indicators and targets. EPA estimated that this effort will be completed in fiscal year 2021 for use in the 2022 comprehensive conservation and management plan (CCMP) update. In December 2019, EPA stated that work is ongoing. We will continue to monitor the status of this effort and will assess the extent to which it addresses our recommendation.

Recommendation: The Director of IHS should implement a targeted, resource-efficient method to identify additional eligible Indian homes that may have existing deficiencies to include in IHS's Home Inventory Tracking System (HITS). (Recommendation 1)

Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open

Comments: In August 2018, IHS's Division of Sanitation Facilities Construction issued a memo to its Area Directors directing them to identify additional eligible Indian homes that may have existing deficiencies to include in HITS. The memo directed Area Offices to use existing staffing resources to leverage their annual efforts to gather sanitation needs data, in collaboration with tribes, to identify any additional homes. In December 2019, IHS officials stated that, as a result of implementing the 2018 memo, Area Directors had increased the number of eligible homes that they identified in 2019. We will continue to monitor the results of IHS's actions.

Recommendation: The Director of IHS should implement a mechanism to indicate in HITS whether each home with a deficiency level of 0 has been assessed. (Recommendation 2)

Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open

Comments: As of December 2019, IHS had developed a mechanism in HITS to indicate whether a home currently classified as deficiency level (DL) 0 had been assessed. IHS stated that it has eliminated the category of DL 0 from HITS; in its place, it created a new category of "Pending Assessment" for those homes that are in HITS but that have not been assessed. IHS also came up with a way to prioritize the homes in the Pending Assessment category based on their eligibility to receive assistance from IHS. Homes currently in HITS that have a DL 0 and received service through the Sanitation Facilities Construction Program from 2015 through today will be reassigned a DL 1 to indicate the deficiencies are only associated with routine operations and maintenance. IHS stated that the changes to HITS have been implemented and shared a proposal of how it will distribute the former DL 0 homes across the new categories. We will evaluate IHS's actions after they are complete.

Recommendation: The Director of IHS should reassess the point distribution across the Sanitation Deficiency System scoring factors as part of its program guidelines update, in light of trade-offs between funding projects that address the most severe sanitation deficiencies and projects that meet other needs. (Recommendation 3)

Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open

Comments: As part of its reassessment of the point distribution across the scoring factors, in 2018 and 2019 IHS consulted with tribes and analyzed various options for changing the point distribution. We have asked IHS to provide additional information about its reassessment efforts. We will evaluate IHS's actions after we receive the additional information.

Recommendation: The Assistant to the Secretary of Agriculture for Rural Development should implement a scoring factor that awards points for proposed Native American program grant projects that address health risks from a lack of access to safe drinking water and wastewater disposal, as it does with the Colonias grant program. (Recommendation 4)

Agency: Department of Agriculture
Status: Open

Comments: As of January 2020, USDA stated it would prefer to use its discretionary points under its existing regulations to implement this scoring factor instead of making a regulation change to do so. USDA stated that using existing flexibility in the regulations could meet the intent of the recommendation more quickly than by permanently changing the regulation. USDA stated that it has established policy guidance to states that addresses scoring for projects with health and sanitation risks. We will monitor the actions that USDA has taken in response to this recommendation and evaluate them when complete.

Recommendation: The Director of IHS, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 7)

Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open

Comments: As of December 2019, IHS had reviewed the 2011 task force report and summarized actions taken and challenges associated with implementing the remaining recommendations. IHS stated that it anticipated discussing its summary with the other members at a future tribal infrastructure task force meeting. We will evaluate IHS's actions when they are complete.

Recommendation: The Administrator of EPA, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 8)

Agency: Environmental Protection Agency
Status: Open

Comments: As of June 2020, EPA had discussed the 2011 task force report with the other member agencies to identify and implement additional actions to increase collaboration at the national level. EPA published a summary matrix of relevant funding sources on the task force website and compiled a draft document summarizing actions the task force member agencies have taken to implement recommendations from the 2011 report. We will continue to monitor EPA's actions in response to this recommendation.

Recommendation: The Assistant to the Secretary of Agriculture for Rural Development, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 9)

Agency: Department of Agriculture
Status: Open

Comments: In July 2019, the task force member agencies met to discuss the status of the recommendations in the 2011 task force report. The agencies each agreed to compile information about the actions they had taken and consider new actions in 2020. USDA stated in December 2018 that the task force agencies had made progress in developing efficiencies in environmental review processes and with online tribal resources and training, in addition to other areas. We will evaluate USDA's actions after the task force has compiled all actions taken in response to the 2011 report and evaluated what further actions or responses should be conducted.

Recommendation: The Deputy Assistant Secretary of the Department of Housing and Urban Development's Office of Native American Programs, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 10)

Agency: Department of Housing and Urban Development
Status: Open

Comments: As of December 2019, the task force members had agreed to jointly consider the actions they have taken from the 2011 report and to discuss additional actions they could take to increase collaboration at the national level. We will evaluate HUD's actions once they are complete.

Recommendation: The Commissioner of Reclamation, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 11)

Agency: Department of the Interior: Bureau of Reclamation
Status: Open

Comments: In April 2018, Reclamation met with other members of the task force and the agencies reviewed and discussed the 2011 task force report recommendations. As of December 2019, the task force members had agreed to jointly consider the actions they have taken from the 2011 report and to discuss additional actions they could take to increase collaboration at the national level. We will evaluate the agency's actions once they are complete.

Recommendation: The Director of IHS, in cooperation with other members of the tribal infrastructure task force, should direct IHS area offices to identify and pursue additional mechanisms to increase their collaboration. (Recommendation 12)

Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open

Comments: As of December 2019, IHS headquarters hosted a meeting that included staff from IHS Areas, EPA headquarters, and EPA regions to discuss additional mechanisms to increase collaboration, including best practices for identifying projects for joint funding collaborations. In addition, IHS and the other tribal infrastructure task force members agreed to jointly draft a memo for distribution to their field offices that would include contact information for other member agencies and encourage interagency coordination. We will evaluate IHS's remaining actions to satisfy this recommendation when they are complete.

Recommendation: The Assistant to the Secretary of Agriculture for Rural Development, in cooperation with other members of the tribal infrastructure task force, should direct USDA state offices to identify and pursue additional mechanisms to increase their collaboration. (Recommendation 13)

Agency: Department of Agriculture
Status: Open

Comments: In December 2018, USDA stated that it would send a memo to its state directors and program directors encouraging them to coordinate with tribal governments, IHS, EPA, and other members of the tribal infrastructure task force on funding infrastructure projects. As of December 2019, task force members had drafted a joint memo to distribute to their field offices encouraging additional coordination. We will evaluate USDA's actions in response to this recommendation once they are complete.

Recommendation: The Assistant Administrator for Water should direct EPA's Office of Water to amend its Safe Drinking Water Act and Clean Water Act inspection guidance documents to add questions on strategic workforce planning topics--such as the number of positions needed in the future, skills needed in the future, and any potential gaps in water operator positions. (Recommendation 1)

Agency: Environmental Protection Agency
Status: Open

Comments: In June 2020, EPA Office of Water said that it had revised guidance for conducting Sanitary Surveys for drinking water plants, adding questions related to workforce needs to the "utility management" section of the guidance manual (see Sanitary Survey Learner's Guide (https://www.epa.gov/sites/production/files/2019-08/documents/sanitary_survey_learners_guide_508_8.27.19.pdf), which includes questions on strategic workforce planning topics in section 14.7. As the recommendation applies to wastewater utilities, EPA did not provide an update. In August 2020, EPA officials stated that they plan to incorporate strategic planning questions into its existing guidance documents. According to EPA, it has taken other actions to support the water workforce by announcing a "Water Workforce Initiative," the goal of which is to provide federal leadership and increase public awareness of water sector careers. We will continue to follow-up with EPA Office of Water to determine what actions have been taken in the wastewater area to add questions on workforce issues in inspection guidance.