Recommendation: The Director of BLM should evaluate its temporary royalty relief program, including the extent to which the policy met BLM's objectives—conserving oil and gas resources from becoming unrecoverable—and likely costs, such as forgone revenues—to inform any royalty relief decisions it may make in the future under the ongoing regulatory authority. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of BLM should update BLM's 1995 royalty handbook to provide specific, consistent, and transparent policies and procedures for royalty relief. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The NMFS Assistant Administrator for Fisheries should work with the South Atlantic and Gulf of Mexico councils, and other councils as appropriate, to develop documented processes for conducting allocation reviews. (Recommendation 1)

Agency: Department of Commerce: National Oceanic and Atmospheric Administration: National Marine Fisheries Service
Status: Open

Comments: Commerce and NOAA agreed with this recommendation and stated that NOAA's NMFS will work to implement it to the extent possible. We will continue to monitor NMFS' efforts to do so.

Recommendation: The NMFS Assistant Administrator for Fisheries should work with the South Atlantic and Gulf of Mexico councils, and other councils as appropriate, to specify how the councils will document their allocation reviews, including the basis for their allocation decisions, whether fishery management plan objectives are being met, and what factors were considered in the reviews. (Recommendation 2)

Agency: Department of Commerce: National Oceanic and Atmospheric Administration: National Marine Fisheries Service
Status: Open

Comments: Commerce and NOAA agreed with this recommendation and stated that NOAA's NMFS will work to implement it to the extent possible. We will continue to monitor NMFS' efforts to do so.

Recommendation: The Acting Director of BLM should develop a documented process to consistently implement the APD prioritization process outlined in Instruction Memorandum 2013-104 at all field offices. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The Department of the Interior, on behalf of BLM, did not concur with this recommendation. As of August 2020, BLM has not taken steps to address this recommendation.

Recommendation: The Acting Director of BLM should instruct agency staff to document formal change management processes for the rollout of future AFMSS II modules consistent with leading software development practices. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The Department of the Interior, on behalf of BLM, did not concur with this recommendation--although, it did state that it agreed with the premise of the need to further improve its formal change management procedures. As of August 2020, BLM has not taken actions to address this recommendation.

Recommendation: The Acting Director of BLM should document and implement an action plan that identifies potential corrective actions based on previous lessons learned to address any challenges with the rollout of future AFMSS II modules. (Recommendation 3)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The Department of the Interior, on behalf of BLM, agreed with this recommendation. In its agency comment letter, the Department said that the BLM AFMSS team would implement adjustments and improvement based on the collected lessons learned. They also stated that upon completion of the last Field Office implementation and conversion to AFMSS II, BLM will conduct a formal program review and an annual operational assessment, which will also present opportunities for annual corrective actions and additional lessons learned considerations. As of August 2020, BLM has not taken actions to address this recommendation.

Recommendation: The Director of BLM should establish outcome-oriented performance measures to assess the effectiveness of the reorganization. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The department neither agreed nor disagreed with our recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of BLM should develop an implementation plan for the reorganization that includes milestones and deliverables to track and communicate implementation progress. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The department neither agreed nor disagreed with our recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of BLM should complete a strategic workforce plan that addresses how it will recruit for and fill vacant positions resulting from the relocations. (Recommendation 3)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The department neither agreed nor disagreed with our recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Interior should ensure its bureau leadership incorporates key practices for effective agency reforms prior to implementing reorganization activities at other Interior bureaus. (Recommendation 4)

Agency: Department of the Interior: Office of the Secretary
Status: Open

Comments: The department neither agreed nor disagreed with our recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Agriculture should direct Departmental Administration to work with the mission areas to develop department-level outcome-oriented performance goals and related measures for the business centers, and use them to assess the effectiveness and impact of the business center reforms. (Recommendation 1)

Agency: Department of Agriculture
Status: Open

Comments: In January 2020, USDA officials agreed with our recommendation and stated that the department is evaluating options for the development of performance metrics and inclusion of these metrics and related information as part of the regular and recurring reviews by the department's Deputy Secretary who is identified as the Chief Operating Officer.

Recommendation: The Assistant Secretary of the Army for Civil Works should direct the Chief of Engineers and the Commanding General of the U.S. Army Corps of Engineers to strengthen the Corps' internal review process for feasibility studies by including steps to ensure consistency with best practices for transparency, such as verifying that all of the important assumptions and limitations in models and their implications for the economic analysis are consistently, clearly, and fully described. (Recommendation 1)

Agency: Department of Defense: Department of the Army: Office of the Assistant Secretary (Civil Works)
Status: Open

Comments: In its letter dated January 14, 2020, the Department of Defense concurred with GAO's recommendation and provided a corrective action plan in response to the recommendation. According to the corrective action plan, the Corps estimates that guidance will be issued to ensure that Corps reports adequately describe and justify the models, analytical choices, assumptions, and data used such that it is consistent with best practices by December 31, 2020.

Recommendation: Congress should consider giving BLM the authority to obtain funds from operators to reclaim orphaned wells, and requiring BLM to implement a mechanism to obtain sufficient funds from operators for reclaiming orphaned wells. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: Congress has not taken action as of April 2020.

Recommendation: The Director of BLM should take steps to adjust bond levels to more closely reflect expected reclamation costs, such as by increasing regulatory minimums to reflect inflation and incorporating consideration of the number of wells on each bond and their characteristics. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In a August 2019 letter to GAO, BLM noted Instruction Memorandum 2019-014, "Oil and Gas Bond Adequacy Reviews", related to the agency's response to this recommendation. The Instruction Memorandum does not increase regulatory minimums to reflect inflation or incorporate the consideration of the number of wells on each bond and their characteristics, but BLM is collecting data to determine the effectiveness of this Instruction Memorandum. BLM noted any further action will depend on the results of the data analysis, expected to be continued through the first quarter of Fiscal Year 2021. As of April 2020 this recommendation remains open.

Recommendation: The Secretary of the Interior should direct BLM to modify its computer program that generates its Bond Review Report to identify all instances in which a state office needs to develop a corrective action plan to address deficiencies, such as an inadequate financial assurance, a late review, or missing data. (Recommendation 1)

Agency: Department of the Interior
Status: Open

Comments: In May 2020, BLM officials stated that they will revise the LR2000 Bond Review Report to identify all instances in which a state office needs to develop a corrective action plan in accordance with BLM policy. They estimate this will be completed by June 2021.

Recommendation: The Secretary of Agriculture should direct the Forest Service to develop a centralized mechanism to record the current estimated cost of reclamation for a mining operation so that this information is readily available for comparison with the financial assurance held. (Recommendation 2)

Agency: Department of Agriculture
Status: Open

Comments: As of July 2020, the agency has made progress in implementing this recommendation. Specifically, the agency has modified the bonding portion of the Natural Resource Manager data system to include required data fields to record the initial bond received, adjustments made to required bonding amount, and date of last annual review when a needed adjustment was determined. The agency has also added a remarks field to record any increase or decrease in the estimated cost of reclamation that resulted in the revised required bond amount. The agency is currently working to update its internal guidance so that staff are aware of the requirement and process to document these items. We agreed to check back on the status of that guidance in early 2021 and will update the recommendation status at that time.

Recommendation: The Director of ONRR should establish an accuracy goal (e.g., identifying the number of companies or percentage of royalties subject to compliance activities over a set period of time) that aligns with the agency's mission of collecting, accounting for, and verifying royalty payments. In doing so, ONRR should track the extent to which each compliance activity (audits, compliance reviews, and data mining) contributes toward achieving this goal. (Recommendation 1)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by December 31, 2021.

Recommendation: The Director of ONRR should develop a documented case selection process that includes procedures for how to select all compliance cases. (Recommendation 2)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by April 30, 2021.

Recommendation: The Director of ONRR should develop performance measures (e.g., having a specified percentage of compliance cases identify findings of royalty noncompliance or total additional royalties) that assess whether the cases the agency is selecting are helping it achieve its compliance goals. (Recommendation 3)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by December 31, 2022.

Recommendation: The Director of ONRR should periodically analyze whether the risk model is effectively identifying potential royalty noncompliance and whether the model's results are being effectively used to assist in case selection, and should use this analysis to make changes to the model (e.g., updating it) or develop a new model. (Recommendation 4)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by June 30, 2021.

Recommendation: The Director of ONRR should include requirements in ONRR's agreements with State and Tribal Royalty Audit Committee (STRAC) members to develop a documented case selection process, including procedures for how to select compliance cases and how to document which factors were considered in selection decisions. (Recommendation 5)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by November 30, 2020.

Recommendation: The Director of ONRR should require STRAC members to describe in their annual work plans how their compliance activities would align with ONRR's current compliance goals. (Recommendation 6)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by November 30, 2020.

Recommendation: The Director of ONRR should track the performance of the compliance work of each state STRAC member and the contribution that each state makes to ONRR's compliance goals. (Recommendation 7)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by March 31, 2021.

Recommendation: The Director of BLM should identify the reasons internal control reviews were not completed (e.g., human capital and workforce), develop and implement a plan to address those reasons, and monitor state offices' progress toward completing required reviews. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. Specifically, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook or Instruction Memorandum. BLM also wrote that it is establishing teams to conduct internal control reviews, monitoring the status of any past-due reviews and actively engaging across its multiple state offices to ensure timely resolution. In late August 2020, BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: The Director of BLM should develop and document procedures for implementing internal control reviews under the July 2012 oversight policy. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In responding to our report, BLM stated that its July 2012 oversight policy, which expired in September 2013, should not have been allowed to lapse and given the importance of internal control reviews, the bureau will continue to use the July 2012 policy to conduct future reviews. In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. In addition, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook, or Instruction Memorandum. In late August 2020. BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: The Director of BLM should implement a risk-informed approach to scheduling and conducting internal control reviews that takes into account the risks to BLM's mission, such as those inherent in field offices' workload and workforce. (Recommendation 3)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. Specifically, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook, or Instruction Memorandum. In addition, BLM noted that the guidance will help ensure that the bureau completes internal control reviews in a timely manner using a consistent risk-based approach. In late August 2020. BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: The Commandant of the U.S. Coast Guard should direct the chair of the Interagency Coordinating Committee on Oil Pollution Research, in coordination with member agencies, to systematically review its membership to determine whether any additional agencies should be involved in coordinating oil spill research and that the most appropriate offices within member agencies are represented. (Recommendation 1)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: In October 2020, the U.S. Coast Guard informed GAO that the Interagency Coordinating Committee on Oil Pollution Research (ICCOPR) review of non-member agencies was complete and that the formal process to invite the U.S. Geological Survey (USGS) for membership has been initiated. To formalize membership, a majority of current ICCOPR members must approve USGS by vote, which is expected. This will be followed by a letter of invitation from the Coast Guard Commandant to USGS making the membership official.

Recommendation: The Commandant of the U.S. Coast Guard should direct the chair of the Interagency Coordinating Committee on Oil Pollution Research, in coordination with member agencies, to coordinate with the relevant Natural Resource Damage Assessment trustee councils to help ensure that the interagency committee's research informs and supports the councils' damage assessment and restoration efforts. (Recommendation 2)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: In October 2020, the Coast Guard informed GAO that the ICCOPR FY 2022-2027 Research and Technology Plan will include a process to engage Natural Resource Damage Assessment (NRDA) trustees. Once updated and finalized, ICCOPR will execute this plan to coordinate with the NRDA trustee councils.

Recommendation: The Chief of the Forest Service should determine whether new regulations governing timber export and substitution are appropriate. If the agency determines new regulations are appropriate, it should issue them in accordance with the 1997 act, in consultation with BLM. Otherwise, the agency should seek legislative relief from the act's requirement. (Recommendation 1)

Agency: Department of Agriculture: Forest Service
Status: Open

Comments: In its May 15, 2020 correspondence, the Forest Service stated that it is putting together a Corrective Action Plan for addressing the recommendation. It expects leadership review of the plan to be completed in June 2020.

Recommendation: The Director of the BLM should determine whether new regulations governing timber export and substitution are appropriate. If the agency determines new regulations are appropriate, it should issue them in accordance with the 1997 act, in consultation with the Forest Service. Otherwise, the agency should seek legislative relief from the act's requirement. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In its April 9, 2020 correspondence, BLM stated that a proposed rule continues to be reviewed by Departmental officials. BLM identified December 31, 2020 as a new target date for completing this recommendation.

Recommendation: The Chief of the Forest Service should review agency policies for continued relevance and effectiveness in addressing the risk of illegal timber export and substitution, and based on that review--and in accordance with applicable regulations--should issue new policies as necessary. (Recommendation 3)

Agency: Department of Agriculture: Forest Service
Status: Open

Comments: In its May 15, 2020 correspondence, the Forest Service stated that it is putting together a Corrective Action Plan for addressing the recommendation. It expects leadership review of the plan to be completed in June 2020.

Recommendation: The Director of the BLM should review agency policies for continued relevance and effectiveness in addressing the risk of illegal timber export and substitution, and based on that review--and in accordance with applicable regulations--should issue new policies as necessary. (Recommendation 4)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In its April 9, 2020 correspondence, BLM stated that any action to address this recommendation is contingent upon the completion of Recommendation #2. Once BLM's response to that recommendation is completed, the agency will address this recommendation.

Recommendation: The Director of BLM should require cognizant officials in headquarters and state offices to conduct top-level reviews of field offices' monitoring of oil and gas lease suspensions, as well as of official lease files and databases to ensure they are current and complete. (Recommendation 3)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM concurred with this recommendation. However, the Bureau has yet to provide information concerning the current status of this recommendation. We will update the recommendation's status when we receive such information.

Recommendation: The Director of BLM should systematically and comprehensively track the actual costs BLM incurs when reclaiming orphaned wells and the information, including the number of orphaned wells and inactive wells over time, necessary to determine the agency's potential liabilities. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM concurred with this recommendation and, in July 2019, the agency developed a new funding code to track the costs incurred when reclaiming orphaned wells and issued written guidance to state and field offices in order to implement the bureau-wide use of the code. Also in July 2019, BLM officials stated that the agency will expand existing reporting capabilities to provide the ability to track orphaned and inactive well records over time. As of September 2020, we are working to confirm what actions BLM has taken to track the number of orphaned and inactive wells over time, and we will provide updated information when we obtain it.

Recommendation: The Director of BLM should develop a resource management plan addressing resources needed for conducting well and bond adequacy reviews and reclaiming orphaned wells. (Recommendation 6)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM officials stated that the agency conducts annual work planning processes which facilitates the decisions regarding the allocation of agency resources. In July 2019, BLM included additional language in its annual work plan that underscores the importance and relevance of well and bond adequacy reviews. The agency also developed a new fund code to track the actual reclamation costs incurred from reclaiming orphaned wells. The annual work plan also lists identifying and cataloging orphaned wells as a performance goal and the plan states that BLM is working with state regulatory agencies to plug wells within funding levels and state agreements. However, as of September 2020, absent identification of funds needed to reclaim orphaned wells and where those funds will come from, BLM does not have a plan to reclaim wells that are currently orphaned.

Recommendation: The Director of OMB should provide, concurrent with any future climate change funding reports to Congress, funding information for federal programs with fiscal exposure to climate change. This information should include costs to repair, replace, and improve the weather-related resilience of federally-funded property and resources; costs for federal flood and crop insurance programs; and costs for disaster assistance programs. (Recommendation 1)

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

Comments: In a July 2018 letter, OMB reiterated its disagreement with this recommendation, as described in the Agency Comments and Our Evaluation section of the report. OMB also stated that it does not anticipate providing funding information for federal programs with fiscal exposure to climate change concurrent with future climate change reports to Congress. We continue to believe that OMB would have better assurance that it was providing policymakers with the information necessary to make climate change spending trade-offs, if in addition to the funding information for science, technology and international assistance it has previously reported to Congress, OMB also reported funding information for programs whose costs were likely to increase due to climate change impacts. In July 2019, the Disclosing Aid Spent to Ensure Relief Act or the DISASTER Act passed the House and was referred to the Senate. If enacted, this legislation would require OMB to annually report to Congress on all disaster-related assistance provided by the federal government, which includes all federal obligations related to disaster response, recovery, mitigation efforts, and administrative costs associated with these activities for specified agencies and programs. As of October 2020, the legislation has not progressed in the Senate. We will provide updated information regarding this recommendation when it becomes available.

Recommendation: The Director of OMB should provide, concurrent with any future climate change funding reports to Congress, a detailed analysis of federal climate change programs it considers to be fragmented, overlapping, or duplicative. (Recommendation 2)

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

Comments: In a July 2018 letter, OMB reiterated its disagreement with this recommendation, as described in the Agency Comments and Our Evaluation section of the report. OMB also stated that it does not anticipate providing a separate, detailed analysis of federal climate change programs that it considers to be fragmented, overlapping, or duplicative. We continue to believe that because OMB collects and reports information on federal climate change funding, OMB is uniquely situated to conduct an assessment of potentially fragmented, overlapping, or duplicative programs across the full range of agencies engaged in climate change activities and that by providing this information to Congress in conjunction with future funding reports, OMB could help decision makers more effectively target limited resources. As of October 2020, OMB has not provided a climate change funding report to Congress since the issuance of our April 2018 report.

Recommendation: To help achieve EQIP's purpose of optimizing environmental benefits, the Secretary of Agriculture should direct the Chief of the Natural Resources Conservation Service to direct EQIP program managers to coordinate with the leaders of USDA's CEAP to help ensure that CEAP studies consider the practical limitations and trade-offs faced by program managers and to provide program managers with better information to target EQIP funds where they will optimize environmental benefits.

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, the agency has not taken action. When we obtain information from the agency, we will update the status of this recommendation.

Recommendation: To help achieve EQIP's purpose of optimizing environmental benefits, the Secretary of Agriculture should direct the Chief of the Natural Resources Conservation Service to revise guidance on state offices' EQIP allocation processes, stipulating that data on environmental concerns, where available, should be a primary factor influencing allocations within states.

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, the agency has not taken action. When we obtain information from the agency, we will update the status of this recommendation.

Recommendation: To help achieve EQIP's purpose of optimizing environmental benefits, the Secretary of Agriculture should direct the Chief of the Natural Resources Conservation Service to establish a review process at the regional level for review and concurrence of EQIP payment rates above a threshold (e.g., rates greater than 50 percent, with justification).

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, the agency has not taken action. When we obtain information from the agency, we will update the status of this recommendation.

Recommendation: To help achieve EQIP's purpose of optimizing environmental benefits, the Secretary of Agriculture should direct the Chief of the Natural Resources Conservation Service to modify guidance and ranking tools so that they more accurately value an EQIP application's anticipated environmental benefits relative to estimated costs.

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, the agency has not taken action. When we obtain information from the agency, we will update the status of this recommendation.

Recommendation: The Secretary of Energy should designate a career senior-level federal government employee to serve as co-chair of the White House Council on Native American Affairs' Energy Subgroup.

Agency: Department of Energy
Status: Open

Comments: In June 2013, an executive order established the White House Council on Native American Affairs. However, the Council did not convene under the current Presidential administration until mid-2020. We will follow-up with DOE in fiscal year 2021 regarding this recommendation.

Recommendation: The Secretary of the Interior, as Chair of the White House Council on Native American Affairs, should direct the co-chairs of the Council's Energy Subgroup to establish formal agreements with all agencies identified for inclusion in the Subgroup to encourage participation.

Agency: Department of the Interior
Status: Open

Comments: In June 2013, an executive order established the White House Council on Native American Affairs. The Tribal Energy Subgroup's efforts were to focus on creating a coordinated effort among the federal agencies to promote energy and energy infrastructure development in Indian Country. The Council convened under the current administration in mid-2020. We believe Interior should still pursue this collaboration and agreements with these agencies and will monitor the agency's progress.

Recommendation: The Secretary of the Interior should direct the Director of the Bureau of Indian Affairs to incorporate effective workforce planning standards by assessing critical skills and competencies needed to fulfill BIA's responsibilities related to energy development and by identifying potential gaps.

Agency: Department of the Interior
Status: Open

Comments: In September 2019 BIA officials stated that they had begun to identify the critical skills and competencies necessary for select Indian energy-related occupations. BIA officials told us that, once complete, agency officials will be able to use the catalog of necessary skills and competencies to identify training needs for existing staff. To fully implement this recommendation, BIA needs to 1) assess the critical skills and competencies needed to fulfill BIA's responsibility related to energy development and 2) identify potential gaps. As of January 2020, BIA is in the early stages of identifying necessary skills and competencies, and BIA officials told us that they expect to complete the catalog of skills and competencies by the end of fiscal year 2020.

Recommendation: The Secretary of the Interior should direct the Director of the Bureau of Indian Affairs to establish a documented process for assessing BIA's workforce composition at agency offices taking into account BIA's mission, goals, and tribal priorities.

Agency: Department of the Interior
Status: Open

Comments: Our recommendation was based on our findings that the workforce composition of agency offices is not regularly reviewed to provide reasonable assurance that it is consistent with BIA's mission and individual tribes' priorities and goals. In December 2019, BIA officials told us that they were in the early stages of developing a process to regularly assess workforce composition at agency offices. BIA officials said that they drafted a data collection tool to collect workforce composition information, and that BIA would be developing a system to collect and analyze the data on an annual basis. According to BIA officials, BIA intends to use the workforce composition data to identify BIA's staffing needs and inform BIA budget requests. BIA officials said that they aim to complete the documented process for assessing workforce composition by the end of February 2020.

Recommendation: To help improve reporting of emissions data on the OGOR, the Secretary of the Interior should direct BLM to provide additional guidance on how to estimate natural gas emissions from federal oil and gas leases.

Agency: Department of the Interior
Status: Open

Comments: In November 2018, BLM's "Waste Prevention, Production Subject to Royalties, and Resource Conservation; Rescission or Revision of Certain Requirements" rule (43 C.F.R. 3179.301) took effect, revising the 2016 rule. According to BLM in July 2020, the revision satisfies the intent of the recommendation because the rule specifies the acceptable means of estimation or measurement of vented or flared gas. The rule says the operator may estimate or measure vented gas in accordance with applicable state or tribal regulatory agency rules or regulations, estimate using the gas to oil ratio (GOR) test (which, during GAO's review, some BLM officials said was not accurate), or to "measure" the volume of the flared gas. We do not believe the revised rule provides sufficient additional specificity on how natural gas emissions should be estimated by operators.

Recommendation: To help improve reporting of emissions data on the OGOR, the Secretary of the Interior should direct ONRR to provide additional guidance on how to differentiate between combusted and noncombusted lease use volumes reported on the OGOR, which could assist Interior in measuring its progress toward greenhouse gas reduction goals.

Agency: Department of the Interior
Status: Open

Comments: In July 2020, ONRR reported that it developed and implemented two disposition codes--one for the royalty-bearing flaring of gas and another for the royalty-bearing venting of gas volumes. ONRR did not develop additional disposition codes because, according to BLM, other disposition codes would not be required due to BLM's 2018 revision of the methane rule. However, we do not believe the measurement provisions in the revised methane rule contain any specific provisions requiring reporting for combusted and non-combusted lease use gas. Gas could be used on lease in pneumatic valves, which is released into the atmosphere as methane; or combusted to power up generators, where it's released as carbon dioxide. Knowing whether the emissions are in the form of methane or carbon dioxide is critical to helping Interior accurately estimate greenhouse gas emissions.

Recommendation: To further improve its production verification efforts and to provide greater assurance that BLM staff are consistently applying the new guidance to commingling agreement requests and determine whether the guidance corrected deficiencies and produced improvements, the Secretary should direct BLM to schedule and complete the internal review as expeditiously as possible.

Agency: Department of the Interior
Status: Open

Comments: In July 2019, Interior officials stated BLM will not be conducting a separate internal review of the guidance for commingling agreement requests issued in July 2013. However, officials stated they are committed to performing the internal review as part of the internal review on its inspection and enforcement program and believed their pending actions related to implementing the recommendations in the GAO report "Oil and Gas Development: Actions Needed to Improve Oversight of the Inspection and Enforcement Program" (GAO-19-7) would also address this recommendation. Interior officials stated the target date for implementing this recommendation is June 30, 2021.

Recommendation: To enhance the usefulness of NNSA's future reports to Congress describing the costs and benefits of its competition of M&O contracts under the requirements contained in Section 3121 of the National Defense Authorization Act for fiscal year 2013, as amended, the NNSA Administrator should take steps to ensure that future reports reflect DOE's information quality guidelines, federal cost accounting standards, and GAO's best practices guidance relevant to the clear and complete presentation of information on each of the required topics. In particular, future reports should clearly and completely describe costs and benefits, including the agency's expectations, as well as the associated analysis, assumptions, information sources, and key limitations and uncertainties about costs and benefits described. The description of uncertainties should include key excluded or unspecified costs and benefits, such as those that are anticipated but not fully known at the time of report writing.

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: NNSA believes it has met the requirements of the recommendation and considers it closed. In our March 2015 report--which examined NNSA's report on the contract to manage and operate the Pantex Plant and the Y-12 National Security Complex under a single management and operating (M&O) contract with Consolidated Nuclear Services (CNS)--we recommended that NNSA enhance the clarity and completeness of its future reports on the costs and benefits of M&O contract competitions. While NNSA demonstrated progress in implementing this recommendation in its September 2017, August 2018, and April 2019 reports to Congress on the costs and benefits of the contract competitions for the Sandia, Nevada, and Los Alamos sites respectively, NNSA did not provide clear and complete information on all required elements of these reports. Specifically, for the Sandia National Laboratories M&O contract, in our August 2018 report we found that NNSA addressed most but not all reporting requirements. For example, NNSA's report addressed all requirements pertaining to cost savings, other benefits, and disruptions or delays, but only partially addressed the reporting requirements on the limitations or uncertainties about cost savings and on the immediate costs of competition and over the life of the contract. NNSA issued a report in August 2018 on the costs and benefits of its competition of the M&O contract for the Nevada National Security Site. In our April 2019 report on NNSA's cost-benefit analysis of that contract competition, we found that, of the five required reporting elements, NNSA's report addressed one with detail but addressed the other four without detail. In April 2019 NNSA issued its cost-benefit analysis of the competition for the Los Alamos National Laboratory contract. In our January 2020 report on NNSA's cost-benefit report for that contract competition, we found that it addressed five reporting elements on costs and disruption during contract transition with detail, partially addressed two reporting elements on uncertainties and benefits, and did not address one reporting element on activities to be covered by the M&O contractor. Since our 2015 recommendation, NNSA's cost-benefit reports on M&O contract competitions have generally provided clearer and more complete information on most of the required reporting elements, but they have not provided clear and complete information on all required reporting elements. In June 2020, NNSA announced that it would end the current CNS contract for Pantex and Y-12 management and operations instead of awarding the contractor its final option term. This will result in a new contract competition and award by the end of the current contract's term on September 30, 2021. The NNSA report on the costs and benefits of that competition may give us another opportunity to assess the quality of NNSA's reports for clarity and completeness on the required reporting elements.

Recommendation: To better inform Congress in the future about crop insurance program costs, reduce present costs, and ensure greater actuarial soundness, the Administrator of the U.S. Department of Agriculture's Risk Management Agency should monitor and report on crop insurance costs in areas that have higher crop production risks.

Agency: Department of Agriculture: Risk Management Agency
Status: Open

Comments: As of May 2020, the Department of Agriculture has not taken action to implement this recommendation.

Recommendation: To better inform Congress in the future about crop insurance program costs, reduce present costs, and ensure greater actuarial soundness, the Administrator of the U.S. Department of Agriculture's Risk Management Agency should, as appropriate, increase its adjustments of premium rates in areas with higher crop production risks by as much as the full 20 percent annually that is allowed by law.

Agency: Department of Agriculture: Risk Management Agency
Status: Open

Comments: As of May 2020, the Department of Agriculture has not taken action to implement this recommendation.

Recommendation: To promote forward-looking construction and rebuilding efforts while FEMA phases out most subsidies, the Secretary of the Department of Homeland Security should direct FEMA to consider amending NFIP minimum standards for floodplain management to incorporate, as appropriate, forward-looking standards, similar to the minimum standard adopted by the Hurricane Sandy Rebuilding Task Force.

Agency: Department of Homeland Security
Status: Open

Comments: In August 2019, a FEMA official stated that FEMA intends to implement the recommendation in full eventually, but it is unlikely that it will happen as a cohesive effort in 2020, given other ongoing flood insurance reforms. As of August 2020, the status of this recommendation remains unchanged.

Recommendation: The Secretary of the Interior should direct the Director of the Bureau of Land Management to take steps, including making changes to AFMSS, and in any new system that replaces AFMSS, to improve the ability of staff to identify wells that are a high priority for environmental inspection and to incorporate information on the inspection history of wells into the environmental inspection prioritization process.

Agency: Department of the Interior
Status: Open

Comments: BLM concurred with the recommendation and has initiated action to update its application for permit to drill (APD) permit processing system. This new system will be known as AFMSS II and, when fully implemented, may address GAO's recommendations. Currently, BLM's actions are insufficient to close this recommendation because they have not completed the updates to AFMISS. Specifically, BLM has not completed its update of AFMSS II to cover environmental inspections. We will continue to follow up with BLM as the agency continues to take action to improve its well tracking system. BLM said it intends to update AFMSS II to cover environmental issues and projects that the remaining AFMSS II related tasks ensuring the system's full deployment will be completed by March 2020. In October 2019, we requested an update on BLM's timeframes.

Recommendation: The Secretary of the Interior should direct the Director of the Bureau of Land Management to take steps to ensure that environmental violations or problems and enforcement actions are documented in a consistent manner.

Agency: Department of the Interior
Status: Open

Comments: In August 2018, BLM informed us that the agency has taken several corrective actions to address the implementation of the recommendation, which will be accomplished related to the redesign of its Automated Fluid Minerals Support System (AFMSS). However, the agency reported that this system will not be completed until March 2020. In October 2019, we requested an update on BLM's timeframes.

Recommendation: To help improve its ability to oversee M&O contractor costs, including indirect costs, for its laboratories and make more effective use of DOE and contractor resources, the Secretary of Energy should take--or, as appropriate, direct the Administrator of NNSA to incorporate more specific benchmarking requirements into future laboratory contracts--similar to the benchmarking requirements used by DOE to assess and manage pension and post-retirement benefit costs--including which costs should be benchmarked, how frequently benchmarking should occur, and what process should be used to ensure corrective actions are taken, as needed.

Agency: Department of Energy
Status: Open

Comments: In April 2017, the Director of NNSA Office of Policy issued guidance to NNSA Laboratory Field Office Managers to update contracts to include a new clause requiring laboratory contractors to submit a strategic plan every year in accordance with guidance. Part of the annual plan requires contractors to discuss the costs of doing business and cost-increase factors at the sites, including overhead dollars. The annual strategic plan is due to the NNSA Office of Policy by August 15 each year. The annual strategic plans included information on indirect costs and cost drivers, but did not include benchmarking. We again requested information on the benchmarking requirements, if any, in July 2020.

Recommendation: To improve Interior's oversight of offshore oil and gas activities in the Gulf of Mexico, the Secretary of the Interior should enhance Interior's capacity for identifying and evaluating offshore oil and gas drilling operations according to risk, thereby allowing it to adjust and evaluate its oversight accordingly by (1) identifying and systematically collecting and maintaining reliable data on risk factors associated with drilling operations, (2) providing operators with clear definitions for significant events in the weekly well activity reports and developing a way to characterize and record these events systematically and reliably, and (3) using the risk factors and significant events data to develop a risk-based approach with clear criteria to prospectively evaluate and categorize drilling operations according to risk and retrospectively to evaluate the performance of oversight and risk mitigation activities in avoiding significant events.

Agency: Department of the Interior
Status: Open
Priority recommendation

Comments: Interior has taken steps to identify and evaluate drilling risks, and its work is ongoing. For example, according to BSEE officials, BSEE's SafeOCS program is one effort through which data is collected on risk factors associated with drilling. BSEE expanded the SafeOCS program in 2016 to include required reporting of well control equipment and barrier failure incidents. Additionally, in 2017, BSEE completed two retrospective analyses of factors associating with risk, however, according to BSEE officials, both analyses were limited by the quality of the data. In December 2019, Interior officials stated that the Gulf of Mexico Region's Office of District Operations Support (DOS) has been developing an approach to apply a secondary review to drilling permits deemed to be "high risk." According to these officials, this secondary review will be performed by pre-selected subject matter experts, identified because of their experience with certain aspects of drilling operations. To determine what drilling permits should receive a secondary review, DOS explored a variety of approaches before settling on a two-prong method. Because efforts remain ongoing, it is too soon to assess the extent to which these efforts will be successful. Until such policies are fully implemented and shown to be effective, Interior may not be able to adjust and evaluate its oversight--including inspections--in a cost-effective manner.