FY 2007 Performance and Accountability Report Compliance with Legal

Document Sample
scope of work template
							     Compliance       T       his section of the report provides the
                              required information on the Department’s
                              compliance with the following legal and
                      regulatory requirements:
     with Legal and     u Federal Managers’ Financial Integrity Act

     Regulatory         u Federal Financial Management

     Requirements
                          Improvement Act

                        u Inspector General Act Amendments

                        u Federal Information Security Management Act

                        u Other key legal and regulatory requirements
                          including the following:

                            n   Prompt Payment Act

                            n   Debt Collection Improvement Act

                      In addition, this section includes summaries of the
                      Department’s financial management improvement
                      initiatives regarding:

                        u Audited financial statement results

                        u Major management challenges facing Interior

                        u Financial management systems

                        u Financial management human capital

                        u Financial data stewardship


                      Federal Managers’
                      Financial Integrity Act
                      The Department believes that maintaining integrity
                      and accountability in all programs and operations:
                      (1) is critical for good government; (2) demonstrates
                      responsible stewardship over assets and resources;
                      (3) ensures high-quality, responsible leadership;
                      (4) ensures the effective delivery of services to
                      customers; and (5) maximizes desired program
                      outcomes. Interior has developed and implemented
                      management, administrative, and financial system
                      controls that reasonably ensure:

                        u Programs and operations achieve intended
                          results efficiently and effectively;


86
                                                  Compliance with Legal and Regulatory Requirements


  u Resources are used in accordance with the
    mission;                                               FY 2007 ASSURANCE STATEMENT
                                                           Interior’s management is responsible for
  u Programs and resources are protected from              establishing and maintaining effective internal
    waste, fraud, and mismanagement;                       control and financial management systems that
                                                           meet the objectives and requirements of the
  u Laws and regulations are followed; and                 Federal Managers’ Financial Integrity Act of
                                                           1982. Interior conducted its annual assessment
  u Timely, accurate and reliable data are                 of the effectiveness of internal control over the
    maintained and used for decision-making at             effectiveness and efficiency of operations and
    all levels.                                            compliance with applicable laws and regulations
                                                           in accordance with the requirements of the Office
Interior’s internal control program is designed to         of Management and Budget (OMB) Circular
ensure full compliance with the goals, objectives,         No. A-123, Management’s Responsibility for Internal
and requirements of FMFIA and OMB Circular No.             Control. Based on the results of this evaluation,
A-123, Management’s Responsibility for Internal            Interior can provide reasonable assurance that its
Control, including Appendix A, Internal Control over       internal control over the effectiveness and efficiency
Financial Reporting; OMB Circular No. A-127,               of operations and compliance with applicable
Financial Management Systems, and OMB Circular             laws and regulations as of September 30, 2007,
No. A-130, Management of Federal Information               was operating effectively and that no material
Resources.                                                 weaknesses were found in the design or operation
                                                           of the internal controls.
Management Assurances
FMFIA requires agencies to provide an annual               In addition, Interior conducted its assessment
statement of assurance regarding the effectiveness         of the effectiveness of internal control over
of internal and accounting controls over financial          financial reporting, which includes safeguarding of
systems. Agencies are also required to provide an          assets and compliance with applicable laws and
assurance statement on management’s assessment             regulations, in accordance with the requirements of
of the effectiveness of internal control over financial     Appendix A of OMB Circular No. A-123. Based on
reporting as of June 30 each fiscal year. During            the results of this evaluation, Interior can provide
FY 2007, the Office of Financial Management                 reasonable assurance that its internal control
conducted comprehensive site visits and otherwise          over financial reporting as of June 30, 2007, was
provided oversight with regard to risk assessments,        operating effectively and no material weaknesses
internal control reviews, assessments of internal          were found in the design or operation of the internal
control over financial reporting, and progress in           control over financial reporting. Further, subsequent
implementing audit recommendations. Interior’s             testing through September 30, 2007, did not identify
FY 2007 Annual Assurance Statement is highlighted          any reportable changes in key financial reporting
to the right. The basis for the assurance statement        internal controls.
conclusions are discussed below.
                                                           Also, Interior can provide reasonable assurance
Internal Control Assessments                               that its financial systems substantially comply with
Interior conducts annual assessments of the                the Federal Managers’ Financial Integrity Act and
effectiveness of management, administrative, and           with the component requirements of the Federal
accounting systems controls in accordance with             Financial Management Improvement Act.
FMFIA and OMB guidelines. The conclusions in
the Secretary’s FY 2007 Annual FMFIA Assurance
Statement are based on the results of 512 internal
control reviews of programs and administrative
functions conducted by bureaus and offices,
                                                           Dirk Kempthorne
including an assessment of internal control over
                                                           Secretary of the Interior
financial reporting; 48 Office of Inspector General          November 13, 2007
program audits; 21 Government Accountability


                                                                                                                   87
  Compliance with Legal and Regulatory Requirements

                            FIGURE 1-62
                                                                         challenges and on components of the President’s
                                                                         Management Agenda. Figure 1-63 presents a
                                                                         crosswalk of those activities.


                                                                         FMFIA Material Weaknesses and
                                                                         Accounting System Nonconformances
                                                                         OMB Circular No. A-123 requires that each agency
                                                                         identify and report on material weaknesses affecting
                                                                         the agency. Interior has adopted the OMB guidelines
                                                                         for material weakness designations. These
                                                                         guidelines are highlighted on the next page. Interior
                                                                         recognizes the importance of correcting material
                                                                         weaknesses in a timely manner. The Office of
                                                                         Financial Management and senior program officials
                                                                         continuously monitor corrective action progress
Office program audits; and the 9 financial statement                       for all material weaknesses. At the beginning of
audits conducted by the independent public                               FY 2007, Interior had no department-level FMFIA
accounting firm, KPMG LLP, under the auspices                             material weaknesses pending correction carried
of the Chief Financial Officers Act of 1990 and the                       forward from the previous year.
Government Management Reform Act of 1994
(see Figure 1-62). As in prior years, internal control                   The Department has a reporting practice consistent
reviews performed by the Department and its                              with the December 2004 revision to OMB Circulars
bureaus provided the majority of the support (86%)                       No. A-123 and No. A-136, Financial Reporting
for the Annual Assurance Statement. In addition,                         Requirements, to report only department-level
many of Interior’s internal control reviews and                          material weaknesses in the Performance and
related accountability and integrity program activities                  Accountability Report. Bureau-level material
focused on areas identified as major management                           weaknesses continue to be reported internally

                                                               FIGURE 1-63

                                 Crosswalk of Activities Related to Major Management Challenges
                                                                                                                                                                                                                                                                                                                                                                                 President's
                                                                                          Interior's Major Management Challenges
                                                                                                                                                                                                                                                                                                                                                                             Management Agenda
                                                                                                                                                                                                         Responsibilities to Indian and Insular Affairs
                                                                                                                                  Health, Safety, and Emergency Management




                                                                                                                                                                                                                                                                                                                                                                                  Strategic Management of Human Capital
                                                                                                                                                                                                                                                          Resource Protection and Restoration




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           Budget and Performance Integration
                                                                                                                                                                                                                                                                                                                      Procurement, Contracts, and Grants




                                                                                                                                                                                                                                                                                                                                                                                                                          Expanded Electronic Government

                                                                                                                                                                                                                                                                                                                                                                                                                                                           Improved Financial Management




        Management Accountability and Integrity Program Activities in FY 2007
               Related to Interior's Major Management Challenges
                                                                                                                                                                             Maintenance of Facilities




                     and President's Management Agenda
                                                                                                         Information Technology
                                                                                  Financial Management




                                                                                                                                                                                                                                                                                                                                                           Competitive Sourcing
                                                                                                                                                                                                                                                                                                Revenue Collections




Internal Control Reviews/Management Studies and Initiatives


  OIG Audits
      - Program Audits Completed
      - Financial Statement Audits Completed


  GAO Audits Completed




88
                                                 Compliance with Legal and Regulatory Requirements


and are actively monitored by the bureau and the
Office of Financial Management for timely corrective           Material Weakness Guidelines
action. The FMFIA material weakness, (Indian Trust
                                                          OMB and the Department define a material
Assets) shown in Figure 1-64, was downgraded
                                                          weakness as follows:
in FY 2006. Interior has no department FMFIA
material weaknesses to carry over to FY 2008 for           t A control deficiency, or combination of
management’s reporting purposes.                             control deficiencies, that in management’s
                                                             judgment, should be communicated because
A summary of the Department’s financial                       they represent significant weaknesses in the
statement audit material weaknesses, FMFIA                   design or operation of internal control that
material weaknesses and accounting system                    could adversly affect the organization’s ability
nonconformances is presented in Figures 1-65                 to meet its internal control objective which
and 1-66.                                                    the agency head determines to be significant
                                                             enough to report outside the agency.
Internal Control over Financial Reporting                  t A material weakness in financial reporting is a
Revised OMB Circular No. A-123, Appendix A,                  significant deficiency- i.e., one that adversely
strengthens internal control requirements over               affects the ability to initiate, authorize, record,
financial reporting in Federal agencies. The revised          process, or report financial data reliably
circular provides updated internal control standards         and in accordance with Generally Accepted
and requirements for conducting management’s                 Accounting Principles - or a combination of
assessment of the effectiveness of internal controls         significant deficiencies, that results in more
over financial reporting.                                     than a remote likelihood that a material
                                                             misstatement of the financial statements will
                                                             not be prevented or detected.
In FY 2007, the Department completed its second
assessment of the effectiveness of internal               The Department will report a material weakness
control over financial reporting. The results of the       corrected or downgraded when the following
assessment revealed that adequate controls exist          occurs:
and that financial reporting can be relied upon by
senior management when used in conjunction with            t Senior management has demonstrated
                                                             its commitment to resolving the material
other decision-making processes. The assessment
                                                             weakness as evidenced by resource
did not disclose any material weaknesses in the              deployment and frequent and regular
Department’s financial reporting activities. Although         monitoring of corrective action progress;
deficiencies were found in some financial reporting
business processes, corrective actions are expected        t Substantial and timely documented progress
to correct the deficiencies. The Department’s                 in completing material weakness corrective
internal controls over financial reporting reasonably         actions is provided;
ensure the safeguarding of assets from waste, loss,
                                                           t Corrective actions have been substantially
and unauthorized use or misappropriation, as well            completed, the remaining actions are minor in
as reasonably ensure compliance with laws and                scope, and the actions will be completed within
regulations pertaining to financial reporting (See            the next fiscal year;
FY 2007 Assurance Statement, paragraph 2).
                                                           t Implemented corrective actions have
Departmental policy-makers and program managers              eliminated or minimized the root cause(s) of
continuously seek ways to achieve missions, meet             the material weakness; and
program goals and measures, enhance operational            t Substantial validation of corrective action
processes, and implement new technological                   effectiveness has been performed.
developments. The OMB requirement to assess
control over financial reporting strengthens
accountability of Departmental managers regarding
internal controls and improves the quality and
reliability of the Department’s financial information.



                                                                                                                   89
  Compliance with Legal and Regulatory Requirements

                                                                    FIGURE 1-64


                                       FMFIA Material Weaknesses Previously Downgraded
                                                                                                                           FY 2006
                                                                                                                             PAR
         Description                      Corrective Actions                          FY 2007 Progress                                  Status
                                                                                                                            Target
                                                                                                                             Date

 Bureaus:                          Departmental trust policies,           Indian Affairs - has: (1) closed 9,400 probate   FY 2008   Interior
 IA/OST/OS/OHTA                    procedures, systems and internal       cases; (2) assisted the Department’s                       downgraded
                                   control will continue to be improved   regulatory initiative team in drafting                     to Significant
 First Reported: FY 1991           and training provided to achieve the   regulations for probate, owner managed                     Deficiency in
                                   goals of the Comprehensive Trust       leasing, consolidation by sale, and ownership              2006.
 Indian Trust Assets: The          Management Plan.                       information; (3) deployed Trust Asset and
 Office of the Special Trustee                                            Accounting Management System and data                      Downgrade
 for American Indians’                                                    conversion at 45 agency field offices in 12                validated by
 conversion to a commercial                                               regions; (4) published program procedural                  financial
 trust fund accounting system                                             handbooks for the Trust land and natural                   statement
 and the implementation of                                                resource management programs; and (5)                      auditors in
 enhanced OST management                                                  issued policies on Life Estates/Dowers,                    2007.
 controls ensure that all                                                 Witnesses, Timber Sales, Minerals, and
 collected trust funds are                                                Rounding.
 properly accounted for. The
 remaining items to correct this                                          OHTA has completed to date, historical
 material weakness includes:                                              accounting that supports several significant
 Office of Historical Trust                                               conclusions: (1) a very high percentage of
 Accounting’s historical                                                  records exist and can be located; (2)
 accounting; strengthening the                                            differences between supporting records and
 existing system of controls to                                           recorded transactions are few in number,
 ensure that Indian Affairs                                               small in size, and not systemic; (3) there is
 ownership and distribution                                               no evidence historical records have been
 information is correct.                                                  altered; and (4) there is ample evidence that
                                                                          monies collected were distributed to the
                                                                          correct recipients.

                                                                          The Office of the Secretary coordinated
                                                                          efforts with IA, OHTA, and OST to assess the
                                                                          Trust weaknesses identified as potential
                                                                          findings in subsequent audit reports.

                                                                          OST completed the implementation of a
                                                                          centralized commercial lockbox process that
                                                                          was initiated in FY 2005; this process
                                                                          included policies, procedures and training.
                                                                          OST Regional Trust Administrators are taking
                                                                          the lead in concert with Bureau of Indian
                                                                          Affairs regional directors to oversee the
                                                                          leasing module conversions to the TAAMS.
                                                                          Regarding these conversions 100% of
                                                                          recurring Individual Indian Monies income
                                                                          and 100% of IIM accounts were converted to
                                                                          the leasing module of the TAAMS.

                                                                          Beneficiaries serviced by the various
                                                                          agencies that have been converted to the
                                                                          leasing module for TAAMS are receiving
                                                                          quarterly performance statements that
                                                                          provide information regarding source of
                                                                          funds, encumbrance information (who is
                                                                          leasing their property, duration and payment
                                                                          terms of lease), and a listing of the trust
                                                                          property they own.




Federal Financial Management                                                  the Governmentwide U.S. Government Standard
Improvement Act                                                               General Ledger; and, 3) Federal financial
                                                                              management system requirements that support full
FFMIA builds upon and complements the CFO                                     disclosure of Federal financial data, including the
Act, Government Performance and Results Act,                                  cost of Federal programs and activities.
and Government Management Reform Act. FFMIA
requires that Federal agencies substantially comply                           Federal agencies are required to address
with: 1) applicable Federal accounting standards; 2)                          compliance with the requirements of FFMIA in


90
                                                   Compliance with Legal and Regulatory Requirements


the representation letter to the financial statement           overseeing the implementation, documenting and
auditor. The auditor is required to report on the             closing of audit recommendations; and monitoring
agency’s compliance with FFMIA requirements                   the recovery of disallowed costs.
in the Independent Auditors’ Report. If an agency
is not in compliance with the requirements of the             Departmental Goal for Timely
FFMIA, the agency head is required to establish a             Implementation of Audit Recommendations
remediation plan to achieve substantial compliance.           To further underscore the importance of
                                                              timely implementation of OIG and GAO audit
Although the FY 2007 Department financial                      recommendations, Interior has established an
statement audit report did identify a deficiency               aggressive performance goal to implement 85%
concerning noncompliance with the Single Audit Act            of all GAO and OIG recommendations where
Amendments of 1996 and OMB Circular No. A-133,                implementation was scheduled to occur during
the Department substantially complies with the                the year or in previous years. Financial audit
FMFIA and FFMIA.                                              recommendations issued in FY 2007 were also
                                                              included in the goal base.

Inspector General Act Amendments                              In FY 2007, Interior exceeded its performance
(Audit Follow-up)                                             goal with a composite implementation rate of 89%
                                                              (Figure 1-67). Interior’s success in achieving the
Interior believes that the timely implementation              performance goal for the fifth consecutive year
of OIG and Government Accountability Office                    was due primarily to DOI’s aggressive monitoring
audit recommendations is essential to improving               process. Monthly and quarterly scorecards on status
efficiency and effectiveness in its programs and               of program internal control reviews and of audit
operations, as well as to achieving integrity and             recommendation implementation were prepared for
accountability goals. As a result, DOI has instituted         each bureau and office to ensure commitments are
a comprehensive audit follow-up program to ensure             being met, and that senior management attention
that audit recommendations are implemented in a               was directed immediately to slippage when it
timely and cost-effective manner and that disallowed          occurred. This same progress monitoring will
costs and other funds due from contractors and                continue in FY 2008 to ensure achievement of next
grantees are collected or offset. In FY 2007, Interior        year’s performance goal.
monitored a substantial number of new Single
Audit (293), OIG (67), and GAO (52) audit reports.            Audits Performed Under the Single Audit Act
Audit follow-up actions include analyzing audit               Interior provides over $2 billion each year in funding
reports referred; advising grantors of single audit           for: grants, cooperative agreements, Indian self-
findings; tracking, reviewing, and validating program          determination contracts, and self-governance
and financial audit recommendations; developing                compacts to state and local governments; Indian
mutually acceptable and timely resolution of                  tribes, colleges and universities; and other not-for-
disputed audit findings and recommendations;                   profit organizations. Under the provisions of the

                                                    FIGURE 1-65


                                  Summary of FY 2007 Financial Statement Audit
                  Audit Opinion                                            Unqualified

                   Restatement                                                 No


                                            Beginning
      Material Weaknesses                                New        Resolved        Consolidated   Ending Balance
                                             Balance

      Control over Trust Funds                                         1
                                               1          0                              0               0
      (IA, OST, & DO)                                             (Downgraded)

      Total Material Weaknesses                1          0            1                 0               0




                                                                                                                    91
  Compliance with Legal and Regulatory Requirements

                                                              FIGURE 1-66

                    Effectiveness of Internal Control over Financial Reporting (FMFIA § 2)
           Statement of Assurance                                                   Unqualified


                                            Beginning                                                              Ending
            Material Weaknesses                                New      Resolved     Consolidated   Reassessed
                                             Balance                                                               Balance


         Total Material Weaknesses               0              0           0                0           0           0



                           Effectiveness of Internal Control over Operations (FMFIA § 2)
           Statement of Assurance                                                   Unqualified


                                            Beginning                                                              Ending
            Material Weaknesses                                New      Resolved     Consolidated   Reassessed
                                             Balance                                                               Balance


         Total Material Weaknesses               0              0           0                0           0           0



                Conformance with Financial Management System Requirements (FMFIA § 4)
      Statement of Assurance                         Systems Conform to Financial Management System Requirements


                                     Beginning                                                                      Ending
        Non-Conformances                                New          Resolved      Consolidated     Reassessed
                                      Balance                                                                       Balance


     Total of Non-Conformances          0                 0             0                0                0            0




                 Compliance with Federal Financial Management Improvement Act (FFMIA)
                                                       Agency                                         Auditor

 Overall Substantial Compliance                          Yes                                           Yes

 1. System Requirements                                                            Yes

 2. Accounting Standards                                                           Yes
 3. U.S.Standard General
                                                                                   Yes
 Ledger at Transaction Level


Single Audit Act, grantees’ financial operations,                       distribution to the appropriate bureaus for audit
internal control structures, and levels of compliance                  follow-up, resolution and tracking. Each bureau
with applicable laws and regulations must be                           is responsible for meeting with grantees and
audited each year. All Single Audit reports are                        negotiating a resolution to the deficiencies identified
forwarded to and screened by the Federal Single                        in the audit reports, as well as for determining the
Audit Clearinghouse. Those Single Audit reports                        allowability of any expenditure of Federal funds that
with findings and recommendations requiring audit                       has been questioned by the auditors.
follow-up are forwarded to the Department’s Office
of Inspector General, who, in turn, forwards those                     Interior closed 234 of 293 audits under the Single
reports to the Office of Financial Management for                       Audit Act (80%) in tracking during FY 2007. As in


92
                                                  Compliance with Legal and Regulatory Requirements


previous years, the Department plans to continue        Audited Financial Statement Results
its monitoring and follow-up activities during
FY 2008 to close audit reports including those          As required by GMRA, Interior prepares
with disallowed costs.                                  consolidated financial statements. These financial
                                                        statements have been audited by KPMG LLP, an
Performance and Financial Audits                        independent public accounting firm, since FY 2001
Performance and Financial Audits are OIG                (the OIG audited the financial statements prior to
conducted audits of Interior’s programs,                FY 2001). Additionally, certain bureaus prepare
organizations, and financial and administrative          financial statements that are also audited.
operations. During FY 2007, 67 OIG audits with 443
recommendations were tracked; 393 (89%) were            The preparation and audit of financial statements
completed or closed.                                    are an integral part of the Department’s centralized
                                                        process to ensure the integrity of financial
Some OIG audit reports contain recommendations          information maintained by Interior.
to improve efficiency and assert that funds could
have been put to better use. For the 12 months          The results of the FY 2007 financial statement audit
ending September 30, 2007, the OIG issued 4 audit       are summarized in Figure 1-65. As shown in the
reports (excluding audits of contracts and grants,      table, Interior again achieved an unqualified audit
discussed below) with $13.8 million of FBU. During      opinion, the eleventh in a row, for the Department’s
the period, management agreed to and closed             consolidated financial statements.
recommendations in 8 reports with $4.3 million of
reported FBU.                                           In FY 2006, the Department did not agree with the
                                                        auditors that Indian Trust Assets was a department-
Audits of Contracts and Grants                          level material weakness. A variety of actions were
For the 12 months ending September 30, 2007,            taken in FY 2006 and 2007 to significantly improve
the OIG reported issuing 27 audit reports that          internal controls and systems for Indian trust. An
contained $5.6 million in questioned costs, $4.6        extensive amount of documentation was provided
million in unsupported costs, and $1.9 million of       to the auditors during the FY 2007 audit cycle.
FBU. During the period, management agreed to and        As a result of these actions, the auditors have
closed recommendations in 12 reports with $4.7          downgraded Indian Trust Assets from a department-
million of questioned costs, including $2 million of    level material weakness to a significant deficiency.
unsupported costs.
                                                        Figures 1-69 and 1-70 summarize the status of
GAO Audits                                              material weaknesses and noncompliance issues
GAO audits are a major component of Interior’s audit    reported in the FY 2007 and FY 2006 financial
follow-up program workload and cover a variety of       statement audit. As noted previously, Interior reports
programs, operations, and activities. A total of 31     only department-level material weaknesses and
GAO reports with 79 recommendations were carried        noncompliances. The Department has established
over from FY 2006. During FY 2007, GAO issued a         an internal goal of completing corrective actions for
total of 23 new reports with 29 recommendations.        material weaknesses and noncompliance issues
The Department was successful in closing 26 of the      by the end of the following fiscal year, unless
54 reports and 41 of the 108 recommendations in         the magnitude of the corrective action involves a
tracking during FY 2007 (Figure 1-68).                  multiyear effort.
                              FIGURE 1-67
                                                                        The FY 2006 auditor’s report
       FY 2007 DEPARTMENTAL PERFORMANCE GOAL FOR                        identified 3 instances of
  IMPLEMENTATION OF OIG AND GAO AUDIT RECOMMENDATIONS
                                                                        noncompliance with laws and
             Recommendations                                            regulations. The Department fully
                  Meeting           Recommendations      Percentage
  Agency
             Deptartmental Goal       Implemented       Implemented     concurred with only one of the
                  Criteria                                              findings (See Figure 1-70). During
                                                                        FY 2007, the Department corrected
 DOI TOTAL          490                     434             89
                                                                        2 noncompliance issues reported in


                                                                                                           93
  Compliance with Legal and Regulatory Requirements

                                                               FIGURE 1-68

                SUMMARY OF ACTIONS TAKEN IN FY 2007 ON AUDIT REPORTS ISSUED BY THE GAO
                                                                                                 Number of         Number of
                                                                                              Recommendations       Reports
       In tracking as of October 1, 2006                                                              79              31
       FY 2007 audits added to tracking system after October 1, 2006                                  29              23
       Subtotal                                                                                      108              54
       Closed during FY 2007                                                                          41              26
       In tracking as of September 30, 2007                                                           67              28
                                                              Number of           Number of
         Code       Status of final reports in tracking
                                                           Recommendations         Reports
           D1       Mgmt decisions < 1 yr old                      42                19
           D2       Mgmt decisions > 1 yr old                      25                 9
           D3       Mgmt decision under formal appeal                  0              0




the FY 2006 audits. The third issue, Single Audit Act                      identified the following priorities for improving its
Amendments of 1996, is the only noncompliance                              overall information security posture:
issue carried over to the FY 2007 audit, and
management concurs with it.                                                  u Continuing improvements in revising
                                                                               Department Certification and Accreditation
                                                                               documentation and execution processes,
Major Management Challenges                                                    to include OMB requirements for protecting
Confronting Interior                                                           personally identifiable information.

The OIG and the GAO annually advise Congress                                 u Further improving the Department’s security
on what they consider to be the major management                               configurations in accordance with emergent
challenges facing the Department. Appendix A                                   Security Technical Implementation Guides as
presents a summary of the major management                                     directed by OMB.
challenges identified by the OIG and GAO. Appendix
B contains the Department of the Interior’s response                         u Refining the Department’s compliance effort
to the challenges identified.                                                   in meeting the requirement to report system
                                                                               weaknesses through the Plans of Action and
                                                                               Milestones process.
Federal Information Security
Management Act                                                               u Implementing automated tools to verify and
                                                                               validate system security configurations.
FISMA provides a framework and relevant agency
roles for ensuring the effectiveness of security                             u Integrating processes into life cycle
controls with regard to information resources                                  management.
that support Federal operations and assets. The
law gives latitude for OMB and the Department                              By focusing on these priorities, the Department
of Commerce through the National Institute of                              was able to continue to make significant progress
Standards and Technology to identify minimum                               in improving and strengthening its overall security
standards for operating information systems within                         posture during FY 2007. In addressing the priorities
the Federal Government.                                                    listed above, the following actions were achieved:

Information security is an ongoing process                                   u C&A packages were completed for 96 percent
of continuous improvement. Challenges are                                      of bureau systems in the Department’s
constantly present from evolving requirements and                              inventory. The content of C&A packages
technologies. During FY 2007, the Department                                   created or updated in FY 2007 was



94
                                                               Compliance with Legal and Regulatory Requirements

                                                                FIGURE 1-69

                                FY 2007 and 2006 Audited Financial Statements
                      Material Weakness Corrective Action Plan (as of September 30, 2007)
                                                                                          Fiscal Year
              Material                                                                                  Original
Bureau       Weakness                            Corrective Action                        2006   2007   Target
             Description                                                                                 Date        Status
DEPT
            Control Over      FY 2006 – Develop and implement procedures and
IA          Trust Funds       internal controls to address the deficiencies in controls    X            11/30/07   Downgraded
DO                            related to Indian Trust Funds.
OST


                                                                  FIGURE 1-70

                               FY 2007 and 2006 Audited Financial Statements
                        Noncompliance Corrective Action Plan (as of September 30, 2007)
                                                                                          Fiscal Year
                                                                                                        Original
           Noncompliance
Bureau                                           Corrective Action                        2006   2007   Target       Status
            Description
                                                                                                         Date
DEPT
IA             Federal
                              FY 2006 – Improve procedures and internal controls to
BLM           Financial
                              ensure that the financial statements and related
BOR          Management                                                                    X            9/30/06     Completed
                              disclosures are prepared in accordance with the
DO         Improvement Act
                              federal accounting standards.
FWS            (FFMIA)
NPS
               Potential
           Noncompliance
                with the
DEPT                          FY 2006 – Investigate and resolve potential
            Anti-Deficiency
                              noncompliance with the Anti-Deficiency Act,
DO         Act, Acquisition                                                                X            6/30/07     Completed
                              procurement regulations, and leasing laws and
NBC          Regulations,
                              regulations to ensure compliance with the Act.
             and Leasing
                 Laws
           and Regulations

                              FY 2006 – Improve grantee monitoring processes to
                              ensure compliance with the Single Audit Act
DEPT                          Amendments and obtain necessary audit reports in a
DO                            timely fashion to meet the requirements of the Act.
           Single Audit Act
BOR         Amendments                                                                     X       X    9/30/06     Carryover
FWS                           FY 2007 – Obtain Single Audit, Financial Status, Grant
               of 1996
NPS                           Performance, and Annual Reports and issue
USGS                          management decisions on audit findings in accordance
                              with the requirements of the Single Audit Act
                              Amendments.




      standardized along NIST Special Publication                                   on the Federal Desktop Core Configuration
      800-37 and related standards and guidelines                                   consistent with the memorandum to agency
      associated with the C&A of information                                        Chief Information Officers; establishment of
      systems.                                                                      Windows XP and VISTA Virtual Machine and
                                                                                    Procedures for Adopting the Federal Desktop
u A STIG Working Group was established                                              Core Configurations, issued by OMB on July
  to coordinate and approve common,                                                 31, 2007; and, NIST Special Publication 800-
  Department- wide security configurations.                                          68, Guidance for Securing Microsoft Windows
  The working group most recently addressed:                                        XP Systems for IT Professionals: A NIST
  OMB guidance on standard configurations                                            Security Configuration Checklist.
  for the Windows XP Operating System based




                                                                                                                                95
  Compliance with Legal and Regulatory Requirements


  u The Plans of Action and Milestones process             under OMB’s Information Systems Security
    implemented last year were reviewed and                Line of Business. By implementing the CSAM
    found to significantly improve the involvement          solution Interior expects to realize significant
    of senior level management, a key goal.                improvements to the C&A process through the
    Additional guidance was distributed to further         increased standardization of C&A processes,
    improve the completion of corrective actions           consistency and quality of documentation,
    and their documentation. The guidance also             and efficiencies through integration between
    helped ensure FISMA compliance.                        those three related program components.
                                                           During FY 2007, Interior also re-certified
Specific actions, initiated and/or completed, in            and re-accredited approximately 56 percent,
FY 2007 include:                                           or 84, of its General Support Systems and
                                                           Major Applications.
  u Department of the Interior IT Security and
    Privacy Program – The program is in the          Senior management commitment towards ensuring
    final process of completing the Department’s      FISMA compliance and continuous improvement
    IT Security Policy Handbook to align             with regard to assessing risk, demonstrating
    Departmental policies with the NIST Special      commensurate controls, and documenting agency
    Publication 800-53 families of controls, and     official approval of operations is demonstrated by
    of implementing OMB’s requirements for the       Interior’s C&A performance metrics in Figure 1-71.
    protection of sensitive agency information,
    including personally identifiable information,    Plans of Action and Milestones – The POA&M is
    by deploying appropriate encryption              the OMB-required, authoritative format for tracking
    solutions and technology to remote laptops       identified weaknesses in IT security programs and
    and workstations. Interior completed and         systems. Designated Approving Authorities, CIOs,
    promulgated the Department’s Privacy Loss        and System Owners must review the POA&M and
    Mitigation Strategy in accordance with the       determine reasonable remediation milestones,
    OMB Memoranda on Recommendations                 schedules, resources, and priorities within their
    for Identity Theft Related Data Breach           system release plans. The CSAM solution described
    Notification, issued on September 20, 2006,       above will enable automating various aspects of
    and Safeguarding Against and Responding          Interior’s POA&M tracking, management, and
    to the Breach of Personally Identifiable          reporting processes. This FISMA automated
    Information (M-07-16), issued on May 22,         reporting solution will provide bureaus and offices
    2007. Interior also completed the Identity       greater simplicity in entering and managing
    Theft Task Force charter, established the        their known security weaknesses. Department-
    Department’s ITTF, and promulgated Office of      level reporting will also be greatly enhanced to
    the Chief Information Officer Directive 2007-     provide the most accurate reporting possible and
    005, Departmental Strategy to Safeguard          minimize workload. This more efficient reporting
    Personally Identifiable Information and           mechanism enables constrained staff resources to
    Reduce the Collection and Uses of Social         focus on the adequacy of weakness descriptions,
    Security Numbers.                                appropriateness of resolution plans, accuracy
                                                     of corrective action status, and enable greater
  u Certification and Accreditation Process –         prioritization of resources to perform increased
    In FY 2007 Interior established a                compliance oversight. The CSAM solution will also
    Memorandum of Agreement with the                 enable the prioritization of some of the most critical
    Department of Justice and initiated a project    corrective actions at the Departmental level.
    to begin deploying the Cyber Security
    Assessment and Management solution               Information Security Controls – The Department
    in support of improvements to Interior’s         established a cross-DOI Internal Security
    Certification and Accreditation, POA&M’s          Improvement Team working group to develop an
    and Internal Control Review processes. The       IT Security Defense-in-Depth Strategic Plan that
    DOJ is a Shared Service Center provider          included approximately 40 recommendations to



96
                                                    Compliance with Legal and Regulatory Requirements


address risks associated with insider threats to              u Level 4 – procedures and security controls are
Interior’s information and information systems. Initial         tested and reviewed.
recommendations from this team were provided
on July 19, 2007, and Interior expects to make final           u Level 5 – procedures and security controls are
decisions regarding implementation strategy by                  fully integrated into a comprehensive program.
November 2007. A number of key recommendations
included in that plan are being integrated into             Based on the results of these reviews, Interior
Interior’s IT Roadmap initiative to appropriately           has achieved an overall Level 4.51 maturity when
prioritize and align these initiatives with other related   measured against the assessment criteria.
and planned initiatives.
                                                            Enterprise Resource Management Program –
As part of Interior’s self-assessments performed            Key goals are to align the Department’s major IT
under annual ICRs, Interior measures the progress           investments with its enterprise architecture, improve
of implementing required security controls consistent       security through more consistent and efficient
with NIST FIPS Pub. 200 and SP 800-53, and                  products and services, and better manage IT
assessed in accordance with NIST SP 800-                    resources to reduce costs.
53A, for information systems using five levels of
effectiveness with the following maturity levels:           Minimum Standards for Security Configurations –
                                                            Interior maintains an inventory of approved STIGS
  u Level 1 – control objective documented in a             for critical IT security components, such as operating
    security policy.                                        systems, router configuration, database hardening,
                                                            etc. This effort requires constant attention due to
  u Level 2 – security controls documented as               changes taking place in the field of information
    procedures.                                             technology and requirements of OMB for standard
                                                            configurations. Interior’s STIG Working Group
  u Level 3 – procedures have been implemented.             recently adopted OMB’s STIG for the Windows XP



                                                     FIGURE 1-71

                                   Certification and Accreditation Activities




                                                                                                               97
  Compliance with Legal and Regulatory Requirements


Operating System and will begin implementing those        Compliance with Key Legal and
standard secure configurations in the first quarter of      Regulatory Requirements
FY 2008, resulting in improved security for end-user
computers and a more manageable environment.              Interior is required to comply with several key legal
                                                          and regulatory financial requirements, including
Portfolio Management Program – Seventy                    the PPA, the DCIA, and the Independent Offices
percent of actions required in FY 2007 to attain          Appropriation Act.
Level 3 maturity along GAO’s IT Investment
Management framework will be completed. In                Based on the results of the FY 2007 independent
addition, 100 percent of IT investment expenditures       financial statement audit, Interior was determined
will be reviewed through the Capital Planning             to be compliant with legal and regulatory financial
and Investment Control process and emphasis               requirements and the USSGL components of the
will be placed on ensuring that 95 percent of             FFMIA. As noted earlier in this section, Figure 1-66
the Department’s IT investments are within ten            presents a summary of the Department’s areas
percent variance of established cost, schedule,           of compliance reported in the FY 2007 financial
and performance baselines. Building on these              statement audit opinions.
accomplishments, the program goal for 2008 is to
fully attain Level 3 maturity, synchronize capital        Prompt Pay, Debt Collection,
planning activities with enterprise architecture and      and Electronic Funds Transfer
IT security, and build upon the implementation of the     The Department is continuing to improve
Project Management Information System.                    performance under the requirements of the PPA and
                                                          the DCIA. The PPA requires that payments be made
Skilled Workforce – Programs are not successful           within 30 days of receipt of invoice; otherwise, the
unless they are managed by a skilled workforce.           Federal Government is required to pay interest. The
To develop the best possible information security         DCIA requires any non-tax debt owed to the United
programs within the Department, it has developed a        States that has been delinquent for a period of over
staffing pattern that allows for the full implementation   180 days be turned over to the Department of the
of an Information Security Program commensurate           Treasury for collection. Electronic Funds Transfer,
with its size and balancing the appropriate mix           a provision of the DCIA, mandates all recipients of
of Federal employees and contractors. Several             Federal payments, except tax refunds, receive their
key positions have already been filled and more            payments electronically.
hiring actions are in progress to fill positions that
were formerly contract employees with Federal             The Department’s FY 2007 performance resulted
employees.                                                in achieving goals for the PPA (Figure 1-72),
                                                          the DCIA (Figure 1-73), and payments made by
The annual FISMA evaluations of both the OIG              EFT (Figure 1-74).
and CIO concluded that IT security at Interior
needs improvement, risks and vulnerabilities
remain, and improvements can be made. Interior            Financial Management
believes the policies and processes in place to           Improvement Initiatives
address those risks are present, that improvements
have been and will continue to be made in a               The Department is moving forward to fully comply
timely and cost-effective manner, and that DOI            with the E-Gov Travel initiative. During FY 2007,
substantially complies with FISMA.                        Interior began to roll out an end-to-end automated
                                                          travel management system providing booking/
                                                          reservations, travel authorization, and travel
                                                          voucher processing services under one system.
                                                          The system will be interfaced with the current
                                                          finance system, Federal Financial System, and
                                                          will be integrated with the Financial and Business
                                                          Management System as it is deployed throughout
                                                          the Department.


98
                                                 Compliance with Legal and Regulatory Requirements

                                                                          FIGURE 1-72
Improved Cost Information
The Department continues enhancement of the
Management Cost Accounting system and its
integration with the financial accounting system.
This integration has focused on providing valid
and useful information related to performance
measurement and budgeting to all levels of
management throughout the organization.
This requires cost information aggregation and
reconciliation that support bureau program
managers as well as Departmental management’s
strategic goals and objectives. We have
accomplished alignment in the Statement of Net
Cost by building an organizational structure that
captures cost transactions at the Mission Area and
the End Outcome Goal level while allowing the
bureaus to adopt flexible goals and activities that                         FIGURE 1-73

support these outcomes. These flexibilities have led
to some criticism by GAO that we have no single
integrated information system to obtain the MCA
data. However, we have begun addressing this
concern by implementing FBMS in two bureaus this
fiscal year. Full implementation of this system will
facilitate the single data source solution and ensure
consistency across each entity. This fiscal year we
focused on identifying representative measures
within each mission area and identifying the
expense data for these measures as they are built
into the Statement of Net Cost model.

Financial Management Systems
The Department shares the view of the government-
wide CFO Council that a key to improved financial
and program management is improved financial                              FIGURE 1-74
management systems. Improving financial
management systems will provide for and strengthen
decision-making capabilities and enable Interior
program and financial managers to more effectively
achieve the Department’s missions. The Department
recognizes the importance of its financial
management systems as a part of its capital assets
portfolio and uses sound information technology
investment management principles to plan and
monitor these systems. With FBMS, Interior’s goal
is to achieve and maintain the objective stated in
OMB Circular No. A-127, Financial Management
Systems, for each agency to establish a single,
integrated financial management system. In pursuing
this goal, the Department will follow the information
technology investment management practices
and principles identified in the Clinger-Cohen Act
of 1996.


                                                                                                 99
  Compliance with Legal and Regulatory Requirements


Financial Management Systems                                  maintaining quality financial management
Improvement Strategy                                          systems. One of the major IT infrastructure
                                                              efforts is the Interior Enterprise Architecture
The Department’s goal is to continue to improve               Program.
financial transaction processing and to enhance
financial management systems support through an
effective partnership of program, information system,   Financial and Business
and financial managers.                                  Management System
                                                        The Department of the Interior is in the third phase
The Department relies on financial management            of implementing FBMS resulting in the Department’s
systems planned for, managed together, and              business transformation over the next few years.
operated to collectively support program and            Interior has developed an Interior-wide strategic plan
financial managers. These systems are managed at         for the first time in the Department’s history to guide
various levels within the Department. Some of these     efforts to deliver more programs and services in a
systems are managed on a Departmental level,            fiscally responsible manner — and FBMS is a major
others are maintained at a bureau or local level,       component of this strategic plan. This will require
and some are Government-wide systems on which           Interior to operate more as one Department and
the Department relies. Collectively, they represent     work towards being able to share resources across
the Department’s financial management systems            bureaus to maximize resources.
architecture.
                                                        When fully operational, FBMS will provide Interior
The Department has viewed the movement toward a         with standard business practices supported by a
single, integrated financial system as encompassing      single, integrated financial and administrative system
four interrelated elements: (1) improve internal        for all bureaus. FBMS is an integrated suite of
controls; (2) eliminate redundant data entry; (3)       software applications that will help Interior manage
enable end-to-end transaction processing; and (4)       a variety of business functions, including core
standardization of data for improved information        financials, acquisition, budget formulation, personal
quality.                                                property and fleet management, real property, travel,
                                                        financial assistance, and enterprise management
The Department’s current financial management            information.
system improvement efforts involve three major
thrusts:                                                The standardization and integration delivered
                                                        by FBMS will help facilitate more collaborative
  u FBMS. Define, carefully plan, and implement          relationships and establish a common approach
    a new generation of financial management             to financial and business management. As a
    systems to replace existing systems that            result, the Department will be positioned to deliver
    are no longer supported by their software           programs and services in a more efficient and
    companies;                                          effective manner. Benefits gained from implementing
                                                        this suite of applications will include:
  u Critical Programmatic/Financial
    Management Systems. Continue to improve               u Access to and sharing real-time, accurate
    certain critical bureau-based programmatic/             business information that supports effective
    financial management programs: Minerals                  business decisions for mission delivery;
    Revenue Management and American Indian
    Trust Funds; and                                      u Issuance of accurate financial reports and
                                                            analysis of core financial, acquisition, financial
  u Interior Enterprise Architecture Program.               assistance, and property data; and
    Continue to improve the Information
    Technology infrastructure supporting financial         u Retirement of outdated and legacy systems no
    systems. The IT infrastructure is critical to           longer supported by their software vendor.




100
                                                    Compliance with Legal and Regulatory Requirements


FY 2007 Accomplishments                                         personal property/fleet, and enterprise
Several necessary activities were accomplished                  management information for BLM, and
to ensure the successful 2007 phase of FBMS                     personal property/fleet for MMS and OSM;
implementation - the deployment of the acquisition
functionality integrated with the November 2006             u Developing and testing conversion and
deployment of core financials; financial assistance             interface programs for BLM, MMS and OSM;
functionality; and enterprise management
information and reporting for the Office of Surface          u Conducting integration and user acceptance
Mining and the Minerals Management Service.                   testing;
FBMS is being hosted by Interior’s National
Business Center. The NBC is an OMB-designated               u Conducting end-user training; and
Shared Service Provider. Some of the activities
included the following:                                     u Developing the final FBMS cut-over plan for
                                                              Deployment 4.
  u Improved month-end processing now
    managed in a cooperative manner with the
    bureaus, the Project Management Office, and             Critical Programmatic Systems
    the NBC;                                               The Department has two critical programmatic
                                                           systems that process financial data. They are the
  u Completed system configuration, business                Minerals Revenue Management System and the
    process procedures, and test scripts for               American Indian Trust Funds Systems.
    acquisition functionality;
                                                              MMS Minerals Revenue
  u Developed and tested conversion and                       Management System
    interface programs, including external                    The Minerals Revenue Management program
    interfaces;                                               is responsible for ensuring that all mineral
                                                              revenues from Federal and Indian lands are
  u Developed final FBMS cut-over plan for                     efficiently, effectively, and accurately collected,
    acquisitions from Interior Department                     accounted for, verified, and disbursed to
    Electronic Acquisition System to Prism;                   recipients in a timely manner. These revenues
                                                              have averaged more than $9 billion annually
  u Conducted ongoing operation and                           over the last five years. To ensure revenues are
    maintenance of Deployments 1 and 2                        properly collected and disbursed, MMS utilizes
    (financial assistance, core financials, and                 a broad range of financial services and pursues
    enterprise management information system for              a comprehensive compliance strategy that
    OSM and MMS);                                             includes an automated compliance verification
                                                              program to validate the accuracy and timeliness
  u Planned for the fall 2008 deployment of core              of revenues paid. MRM also administers a
    financials, financial assistance, acquisition,              robust Royalty-In-Kind program, which utilizes
    property, and enterprise management                       an asset management approach to ensure the
    information for the Bureau of Land                        receipt of optimal value for mineral resources.
    Management and property for MMS and OSM.
                                                              FY 2007 Accomplishments
FY 2008 Planned Activities                                     u MMS continues to explore opportunities
Other necessary activities are planned to be                       for program application for the RIK
accomplished to ensure successful FBMS Phase 4                     program. As a result, the natural gas RIK
deployment in the fall of 2008. Activities will include:           business unit was expanded in the Gulf
                                                                   of Mexico and Wyoming. The crude oil
  u Completing all system configuration, business                   business unit remained relatively static
    process procedures and test scripts for core                   in size. In April 2007, MMS completed an
    financials, financial assistance, acquisition,                   analysis that examined the performance of



                                                                                                            101
 Compliance with Legal and Regulatory Requirements


          the RIK program during FY 2006.               u In response to the final OIG report
          A revenue gain of $26.2 million related         dated December 5, 2006, MMS
          to both the natural gas and crude oil           formally submitted an “Action Plan to
          business units was among the highlights         Strengthen Minerals Management Service
          of the report. Combined with an additional      Compliance Program operations” (Action
          revenue gain of $2.6 million in additional      Plan) to document the improvement
          interest earned on RIK revenues received        actions taken and planned. The Action
          5 to 10 days earlier than under the royalty     Plan sets forth specific actions to:
          in value program and $2.3 million in            (i) provide reliable data for managing
          cost avoidance by collecting offshore           and reporting on Compliance and Asset
          oil and gas in kind instead of in value,        Management program operations;
          a total revenue gain of $31.1 million was       (ii) strengthen the compliance review
          measured for the MMS RIK program in             process; and (iii) improve performance
          FY 2006.                                        measures to better reflect CAM program
                                                          operations.
      u The FY 2006 RIK Annual Report
        responded to Section 342(e)(2) of the           u MMS has completed processing the
        Energy Policy Act of 2005, requiring the          backlog of interest billings related to oil
        Secretary of the Interior to submit a report      and gas leases on Federal and American
        to Congress for each of fiscal years 2006 –        Indian lands. MMS billed more than $66
        2015 that describes the performance,              million of interest on late royalty payments
        benefits, and savings associated with              and is now regularly billing lessees for late
        the MMS RIK program. In FY 2006,                  payments on a monthly basis.
        while volumes taken in kind decreased
        due to effects of Hurricane Katrina, total      u Working in partnership with the BLM,
        revenues to the U.S. Treasury increased           IA, the Office of the Special Trustee
        when compared to the previous year.               for American Indians, and the U.S.
        A total of 72,279,559 barrels of oil              Geological Survey, the MMS is leading
        equivalent were taken in kind and sold            an effort to expand the number of
        by MMS in FY 2006. This volume is                 Indian outreach sessions provided by
        approximately 90% of the volumes taken            developing Indian oil and gas training that
        in kind for FY 2005. The value of RIK oil         covers all aspects of trust management
        and gas in FY 2006 was $4,087,885,440,            including land ownership, leasing,
        a 10% year-on-year increase in value—             drilling, production verification, lease
        the increase reflecting the effect of              inspection, royalty reporting, compliance,
        markedly higher energy commodity prices           royalty disbursement, and financial trust
        during FY 2006. As of the end of FY 2006,         accounts. The new training is tailored
        MMS took in kind approximately 72%                for tribes and Individual Indian Mineral
        and 45% of the crude oil and natural gas          Owners in the various regions where
        royalty volumes, respectively, produced           outreach is conducted as well as for
        daily in the Gulf of Mexico. In April 2006,       Department of the Interior employees who
        MMS, in consultation with the State of            are involved in Indian oil and gas activities.
        Wyoming, began taking natural gas in kind         The additional outreach sessions and
        for Federal gas production in Wyoming at          the joint agency training program will
        the rate of 30,000 Million British Thermal        provide Indian communities and Interior
        Units per day.                                    employees with opportunities to gain more
                                                          knowledge of the full spectrum of Indian
      u In July 2007, MMS began deliveries of             mineral resources.
        royalty oil to the Department of Energy at
        a rate of approximately 50,000 barrels per      u As a result of provisions of the EPAct
        day for the Strategic Petroleum Reserve.          governing the payment of royalty on
                                                          geothermal resources produced from


102
                                              Compliance with Legal and Regulatory Requirements


      Federal leases and the payment of direct-         balances; providing adequate controls over
      use fees in lieu of royalties, the MMS            receipts and disbursements; providing periodic,
      published a final rule on Geothermal               timely account reconciliations; determining
      Valuation in May 2007. The EPAct                  accurate cash balances; and preparing periodic
      provisions amended the Geothermal                 statements of account performance and
      Steam Act of 1970. The final rule amends           balances. The Act also addressed the need for
      the current MMS geothermal royalty                developing systems for accounting and investing
      valuation regulations and simplifies the           funds, for reporting to account holders, and for
      royalty and direct-use fee calculations for       maintaining accurate data on ownership and
      geothermal resources for leases issued            leasing of Indian lands.
      under the EPAct and leases whose terms
      are modified under the EPAct.                      In FY 2001, the Department commissioned
                                                        an independent review which concluded
FY 2008 Planned Activities                              that the previous reform results were not
 u Implement an effective risk metrics                  accomplishing the intended comprehensive
     program to quantitatively identify                 result. Accordingly, the Department developed a
     exposures and inform commercial                    more comprehensive and integrated approach—
     decision-making within the RIK Program.            the Comprehensive Trust Management Plan,
                                                        dated March 28, 2003—that sets forth a
  u Expand RIK portfolio through                        strategic framework, including six strategic goals
    diversification, after enhancing internal            (and various objectives) for the Department to
    controls, risk policy frameworks, and               meet in fulfilling its obligations to its fiduciary
    human resource skill sets.                          trust beneficiaries:

  u Establish a new risk-based compliance                 u Beneficiary services that are trusted,
    strategy.                                               accurate, and responsive;

  u Continue to implement the Strategic                   u Tribal self-governance and self-
    Business Plan.                                          determination that increase participation in
                                                            managing assets;
  u Publish a proposed Takes versus
    Entitlements Rule.                                    u Ownership information that is accurate,
                                                            timely, and reliable;
  u Publish a proposed rule for Prepayment
    of Royalties on Marginal Properties.                  u Land and natural resources management
                                                            that maximizes return while meeting
  u Publish final rules on Indian Oil Valuation              beneficiary desires (constrained by
    and Reporting Amendments                                beneficiary preferences on other factors);

  u Publish proposed rules on Coal Valuation              u Trust fund assets management that meets
    and Debt Collection.                                    fiduciary standards; and,

American Indian Trust Fund Systems                        u Administrative services that: (1) enable
The American Indian Trust Fund Management                   and empower the organization and
Reform Act of 1994 identified some of the                    workforce to be an effective fiduciary
Secretary’s core responsibilities for trust fund            trustee; and (2) provide modern,
management and established the Office of                     appropriate systems and tools to manage
Special Trustee for American Indians. The Act               the fiduciary trust.
identified actions required for the Secretary’s
proper discharge of trust responsibilities,             The CTMP identifies three primary business
including providing adequate systems for                lines: (1) beneficiary trust representation, (2)
accounting for and reporting trust fund                 trust financial management and stewardship,


                                                                                                          103
 Compliance with Legal and Regulatory Requirements


  and, (3) management of land and natural              leasing system, Indian trust beneficiaries began
  resources. Each business line represents             receiving quarterly statements that include
  a distinct group of products or services             more detailed information on trust assets and
  for comprehensive trust management and               trust income. Other selected accomplishments
  encompasses related processes, products,             include:
  and services within its scope. Strategic goals
  and specific related objectives fit within these         u Continued implementation of the FTM,
  business lines.                                          including the migration of automated
                                                           systems that are integrated in order to
  In June 2007, the Department released the                support the FTM trust business processes
  2007 Historical Accounting Plan for Individual           and fulfill beneficiary needs and fiduciary
  Indian Money accounts. The 2007 plan reflects             requirements.
  what has been learned in 4 years of historical
  accounting. The Department’s plan includes             u Utilized information from the MRM, an
  the provision of historical accountings for about        MMS program for collecting, accounting
  371,000 IIM accounts open on or after October            for, and distributing mineral revenues from
  25, 1994, that had balances. Implementation of           both Federal and Indian mineral leases,
  the plan is estimated to cost $335 million.              to disburse lease revenues to individual
                                                           Indian beneficiaries at the converted
  FY 2007 Accomplishments                                  agencies.
  Through the Office of the Special Trustee for
  American Indians, the Department of the Interior       u Distributed $21.8 million to individual
  is in its third year of implementing the Fiduciary       Indian trust account holders who
  Trust Model. The FTM is designed to enhance              were previously on the “Whereabouts
  beneficiary services for tribes and individuals,          Unknown” list through collaborative efforts
  with better information about ownership, land            between OST, IA, and tribal governments.
  and natural resource assets, trust fund assets,
  Indian self-governance and self-determination,         u Safeguarded millions of Indian trust
  and administrative services. When fully                  records at the American Indian Records
  implemented, the FTM will transform current              Repository, in Lenexa, Kansas. So far,
  trust processes into more efficient, integrated,          more than 162,321 boxes containing
  and fiscally-responsible business processes               almost 406 million pages of Indian records
  that better meet the needs of beneficiaries and           have been electronically indexed and
  employees.                                               stored at the state-of-the-art storage
                                                           facility.
  Transitioning from the approximately 56 non-
  integrated Trust-related information systems           u Provided records management training for
  to an integrated trust data environment is the           697 IA and OST records contacts and 295
  cornerstone of the FTM. By the close of FY               tribal employees.
  2007, OST and IA achieved a milestone in trust
  management reform through conversion to a              u Increased direct deposit by 3,508 IIM
  new leasing system which is integrated with the          account holders, thus avoiding lost checks
  land title system and interfaces with the Trust          and providing timely delivery of funds.
  Funds Accounting System. With the Exception
  of Compact/Contract Tribe encumbrance data,            u Worked with 43 tribes that performed or
  this conversion provides a single repository             sought to perform OST programs and
  of ownership for DOI-processes Indian Trust              functions on behalf of their members,
  land conveyance and encumbrance data. As                 and worked to ensure that 75% of those
  of September 30, 2007, all locations were                tribes had program standards for the OST
  successfully converted to the new leasing                functions in place.
  system. As IA locations converted to the new



104
                                             Compliance with Legal and Regulatory Requirements


u Published informational brochures and                 u Revised, implemented, and conducted
  other material for Indian trust beneficiaries            training on standardized IA Handbooks
  to help educate and inform them about                   and OST Desk Operating Procedures in
  their trust accounts and assets.                        compliance with new regulations.

u Held outreach events and attended Indian              u Completed analysis of probate information
  country community events, such as pow-                  across all trust systems and implemented
  wows and meetings, across the country to                reconciliation recommendations.
  help inform Indian trust beneficiaries about
  their accounts and assets.                             u Moved decision-making on selected
                                                           transactions to the local level.
u Conducted assessments of business
  process workflows, integrated system                   u Completed Data Quality and Integrity
  support, and workforce plans at field                    project tasks for 50 IA agencies.
  locations.
                                                         u Implemented post-quality assurance
u Incorporated regulatory initiatives into                 review processes at 2 IA LTRO’s.
  operating procedures, manuals, and
  handbooks.                                             u Conducted 45 trust examinations and 42
                                                           records management assessments.
u Revised and enhanced training curriculum
  for the FTM standardized processes.                   u Enhanced IT security through
                                                          improvements to the vulnerability scanning
u Provided quarterly trust-related training               process and the re-certification and
  including: Trust fundamentals, orientation              accreditation of systems. OST’s General
  programs for OST Fiduciary Trust Officers                Support Systems was re-accredited in
  and Deputy Superintendents as well as                   FY 2007.
  new hires, Trust Fund Accounting System,
  lockbox operations, and other related trust           u Redesigned and updated the OST
  systems.                                                external Web site <http://www.doi.gov/ost>
                                                          to be interactive and informational for
u Certified 73 Interior employees as                       Indian Trust account holders.
  Certified Indian Fiduciary Trust Analysts
  and/or Specialists.                                    u Worked with a contractor to communicate
                                                           with Indian trust beneficiaries about the
u Aligned the Risk Management program                      services and products available to them
  with OMB Circulars No. A-123 and No.                     and how Indian trust management reforms
  A-130 for all OST locations and completed                affect them.
  a comprehensive risk management plan
  that identifies the schedule of internal                u Developed and implemented Cannon
  control reviews for all OST programs over                Financial Institute’s Certified Indian Trust
  the next 3 fiscal years.                                  Examiner certification program.

u Distributed an aligned risk management                 u Completed a Workforce and Diversity
  assessment tool that provides automated                  Plan that contributes to the achievement
  assessment and corrective action plan                    of program objectives by providing a
  development and maintenance.                             basis for justifying budget allocation and
                                                           workload staffing levels.
u Enhanced the lockbox operations for
  additional funds processing.




                                                                                                   105
 Compliance with Legal and Regulatory Requirements


      u Partnered with the Gallup Organization to        ensure that reporting requirements are
        conduct a Q-12 Employee Opinion Survey           incorporated into annual Memoranda of
        to gather information to create a more           Understanding.
        constructive and productive workplace.
                                                     u Assist compact/contract tribes that are
      u Created a Workforce Improvement Team           seeking access to the Department’s
        comprising approximately 40 program            TrustNet.
        office representatives to address areas
        identified in the 2006 Federal Human          u Align Activity-Based Cost/Management
        Capital Survey.                                System activity codes and outputs with
                                                       projected budgetary funding levels.
  FY 2008 Planned Activities
   u Certify additional Interior employees as        u Expand the scope of trust examinations
       Certified Indian Fiduciary Trust Analysts        to all Department offices performing trust
       and/or Specialists.                             functions, including the MMS and the
                                                       BLM.
      u Develop and provide job-specific training
        to Interior and tribal employees in FTM      u Complete 45 record management
        business processes (e.g., lockbox; tribal      assessments and 38 trust examinations.
        self-governance and self-determination;
        and trust accounting).                       u Collect and index 10,000 boxes of inactive
                                                       records and continue to maintain the Box
      u Respond to 90 percent of inquiries to the      Index Search System (BISS) that allows
        Trust Beneficiary Call Center within 2          for record retrieval on an as-needed basis
        business days and the balance of inquiries     for over 200,000 boxes of inactive records.
        within 30 days.
                                                     u Assist the National Indian Programs
      u Use the Indian Trust Appraisal Request         Training Center in designing curriculum,
        Tracking System to accurately track and        hosting, and presenting courses for Indian
        project Office of Appraisal Services cost       and tribal staff.
        and performance data.
                                                     u Resolve 25 percent of “Whereabouts
      u Strengthen the risk management program         Unknown” accounts.
        by: (1) increasing the frequency of self-
        assessment cycles; (2) improving OST         u Conduct post quality assurance review on
        staff expertise through additional risk        the encoding of Trust Asset Accounting
        management training; (3) expanding the         Management System leasing module
        Risk Management Assessment Tool to             data to ensure accuracy as well as timely
        include a section that addresses risks         interface with TFAS and the TAAMS title
        and associated internal controls at the        module.
        senior management level; and, (4) aligning
        RM-PLUS with regulatory and legislative      u Use Re-engineering Continuous
        requirements, in particular OMB Circular       Improvement Teams to identify the need
        No. A-123.                                     for revised business processes, enhanced
                                                       data systems, standard operating
      u Continue to work with other Interior           procedures, handbooks, validating
        bureaus and offices on regulatory               metrics, desk operating manuals, and new
        initiatives.                                   skills training.

      u Obtain appraisal backlog information from    u Interact with at least 300 tribal, individual
        compacted and contracted tribes and            Indian and Alaska Native beneficiaries
                                                       through local community outreach


106
                                                  Compliance with Legal and Regulatory Requirements


          programs regarding asset management            processes and information sharing, blueprints
          and trust reform initiatives.                  identify gaps and redundancies in Interior’s existing
                                                         IT portfolio that hamper successful achievement of
      u Actively engage tribal and individual Indian     strategic and programmatic goals.
        beneficiaries in the management of trust
        assets.                                          IEA also issued a policy on data resource
                                                         management which defines roles and responsibilities
      u Advocate the importance of estate                for data standardization and stewardship. IEA
        planning for individual Indian beneficiaries      issued an associated procedures document for
        to reduce the impact on fractionation of         data standardization, which provides a consistent
        trust land holdings.                             methodology for defining data standards to meet the
                                                         broadest organizational needs.

Interior Enterprise Architecture Program                 In efforts to further formalize data standardization,
For the last three years, Interior’s Enterprise          IEA has implemented performance measures
Architecture program exceeded established                for data quality for the Departmental Enterprise
maturity thresholds and therefore, achieved a rating     Architecture Repository. These measures will be
of green from OMB. In 2007, the IEA program              used to conduct quarterly evaluations of all bureau
was recognized as one of the top five enterprise          enterprise architecture programs.
architecture programs across all Federal agencies.
Agencies were evaluated on three factors of their EA     The Deputy Secretary of the Interior approved an
Program: completeness, use, and results.                 EA Governance Plan that describes the decision-
                                                         making processes used during the development of
At the end of FY 2006, Interior achieved the highest     segment architectures for Interior’s business areas.
rating from GAO in an assessment of 28 Federal           The Deputy Secretary also approved the annually-
agencies against the GAO Enterprise Architecture         updated Interior Enterprise Transition Strategy. The
Management Maturity Framework. This rating               ETS defines the sequencing for all modernization
indicated the IEA had fully achieved more of the         efforts across Interior. It also consolidates and
evaluation criteria, (i.e., 97%) than any of the other   coordinates the changes proposed in modernization
agencies assessed.                                       blueprints.

The IEA program has proven that its approach is          The Methodology for Business Transformation
indeed a valid one by demonstrating tangible results     has been revised and updated to MBT 1.5. MBT
from the program. In fact, in 2006, the President’s      provides guidance on the approach Interior uses
Management Agenda Initiative Recreation One Stop,        for conducting segment architecture analyses and
took a major step forward with the implementation        developing modernization blueprints. The new MBT
and deployment of the National Recreation                1.5 has been enhanced to include specific guidance
Reservation Service. The NRRS is featured at             integrating capital planners and appropriate EA
the all new Recreation.gov and provides one-stop         governance bodies in the process of creating the
shopping for the citizen’s recreation needs. This is     proposed investments for modernization blueprints.
a direct result of implementing Interior’s Recreation
Modernization Blueprint.                                 In addition to OMB scores and internal recognitions,
                                                         the IEA program was also noted externally by:
Interior has completed two new modernization
blueprints — one for Human Resources                       u 4th Annual E-Gov Institute as winner for the
Management and another for the cross-cutting                 2006 Excellence in Enterprise Architecture for
mission function of Land Management Planning                 Leadership in EA;
and National Environmental Policy Act. Both
modernization blueprints were approved by the              u Cited by the OMB Federal Enterprise
Interior Investment Review Board in accordance               Architecture Program Management Office as
with the IEA Governance Plan. In addition to                 a best practice for other Federal agencies to
recommendations to improve DOI’s business                    leverage in developing segment architectures;


                                                                                                            107
  Compliance with Legal and Regulatory Requirements


  u By request, the DOI Chief Architect and               security. The Department currently spends about
    members of the staff regularly speak about            $500 million on IT infrastructure investments per
    DOI’s EA program at the Federal Enterprise            year. Interior will take a two-pronged planning
    Architecture Certification Institute National          approach that will result in a tactical roadmap
    Defense University’s CIO and EA certification          and a strategic IT infrastructure modernization
    courses and the U.S. Department of                    blueprint. At the same time, Interior will be aligning
    Agriculture Graduate School; and                      it’s planning initiatives to comply with the OMB lead
                                                          IT infrastructure Line of Business. The ITI LoB will
  u Outreach and information sharing sessions             establish benchmarks for cost and performance
    with over 25 Federal, state, and local                that all Federal agencies are expected to meet.
    government agencies, as well as five foreign           Some of the areas that will be reviewed are end-
    governments, for sharing best practices and           user computing, desktop and support services,
    helping the EA community.                             data centers, networks and telecommunications.
                                                          Security concerns for all of these areas will also be
FY 2007 Accomplishments                                   addressed along with asset management.
 u Interior achieved the highest rating from the
     GAO in an assessment of 28 Federal agencies          As with all blueprints, the IEA program will work
     against the GAO Enterprise Architecture              closely with the appropriate business and IT
     Management Maturity Framework. This rating           representatives across Interior in the development
     indicated the IEA program had fully achieved         and eventual implementation of the IT infrastructure
     more of the evaluation criteria than any of the      roadmap and blueprint.
     other agencies assessed.

  u Two IEA blueprints, Human Resources and               Financial Management
    Management Planning NEPA were approved                Human Capital
    by the IRB in June 2007.
                                                          The Department of the Interior’s financial
  u Interior’s EA Program generated international         management community continues to face major
    interest. The IEA program has provided                workforce challenges. The decade of the 1990s
    information sharing sessions on its methods           brought significant legislation and increased
    and achievements to representatives from              responsibilities for the entire Federal financial
    Singapore and South Korea. Interior’s Chief           management community. The need to expand
    Architect has also been the keynote speaker           knowledge and expertise by the financial community
    at EA conferences sponsored by government             continued with the requirements of the PMA, and,
    agencies.                                             more recently, OMB’s revised Circular No. A-123,
                                                          Appendix A. In addition to the Governmentwide
  u MBT and DEAR Training - Training sessions             initiatives, Interior is also engaged in a
    in the Denver, Colorado, and Washington, DC,          Departmentwide effort to implement a fully
    metro areas were held to train architects and         integrated FBMS.
    other stakeholders on using MBT and DEAR.
                                                          It is imperative that Interior have an adequate
  u Improved EA Governance and Management                 number of highly qualified financial management
    oversight by instituting semi-annual reporting        personnel. These individuals must have the
    of Bureau EA Maturity Assessments.                    competencies required to successfully transition to
                                                          and implement FBMS, as well as the ability to lead
FY 2008 Planned Activities                                a world-class finance organization in the future. The
The main focus for the IEA in 2008 is on developing       need for a highly-qualified financial management
an IT infrastructure modernization blueprint. The         workforce comes at the same time that many “baby
goal is to optimize Interior’s IT infrastructure assets   boomer” supervisors, managers, and executives
and improve overall management, operations, and           reach retirement age.




108
                                                 Compliance with Legal and Regulatory Requirements


A financial management workforce plan was                 u Executed a Fall 2006/Spring 2007 recruitment
completed and published at the end of 2004.                strategy;
Interior’s Chief Financial Officer Council approved
the plan’s major recommendations and established         u Participated in Office of Personnel
a Workforce Steering Committee in early 2005. The          Management forum on best practices in
workforce plan’s four major recommendations are:           recruitment; and

 u A strategic focus on new employee                     u Led panel on acquisition intern programs
   recruitment;                                            at the Federal Acquisition Conference and
                                                           Exposition.
 u Retention of employees who have or can
   develop needed competencies;                         The 2005 intern classes completed the following
                                                        courses:
 u Career paths to develop employees at all
   levels of experience with “workforce of the           u Auditing Fundamentals
   future” skills; and,
                                                         u Critical Thinking Problem Solving
 u Training and professional development                 u Internal Control
   opportunities for both technical/analytical skills    u Essentials of Analysis
   and business/organization skills to enhance
   competencies and develop employees who                u Congressional Operations Seminar
   are flexible and versatile.                            u Leading and Managing Change

Interior established the R. Schuyler Lesher              u Leadership Skills & Techniques
Financial Management Career Intern Program in            u Briefing & Presentation Skills
2002 to recruit and train entry-level professionals
in accounting and financial analysis for the
Department and the bureaus. Each year Interior’s        The 2006 intern classes completed the following
financial management community partners with DOI         courses:
University to recruit a new class of high potential
entry-level accountants and financial analysts to         u Dollars and Sense
participate in this career development program.
                                                         u Government Budget & Accounting
FY 2007 Accomplishments for the Intern Program           u Multi-generational Workforce
 u Recruited 6 new interns for the Class of 2007;        u Mentoring

 u Completed the first year of training and               u Budget Analyst’s Guide for Formulation
   development for the 2006 FMCIP Intern class           u Auditing Fundamentals
   (five interns);
                                                         u Basic USSGL
 u Graduated the FMCIP Class of 2005 (four               u Appropriations Law
   members);
                                                         u Briefing & Presentation Skills
 u Conducted outreach activities at                      u Government Environment
   geographically dispersed colleges and
   universities with diverse student populations.       FY 2008 Planned Actions for the Intern Program
   Recruited at career fairs in the South (Texas),       u Increase the number of participating Interior
   the West (Colorado), the Southeast (Florida),             bureaus in the FMCIP Class of 2008
   Mid-Atlantic (DC and Virginia), the Northeast
                                                         u Recruit a new class of interns; and
   (New Jersey);
                                                         u Continue providing training opportunities for
                                                           the class of 2007 and 2006.


                                                                                                          109
  Compliance with Legal and Regulatory Requirements


Sponsoring Comprehensive Training                        FY 2007 Accomplishments
and Career Development Programs                           u Completed a Departmentwide financial
in Financial Management                                       management skills gap analysis based on the
The other critical component of Financial                     Financial Management Competency Model.
Management Human Capital is to provide
appropriate training and professional development          u Department of the Interior University
opportunities to existing financial management                sponsored the following finance-related
personnel so that they are prepared to carry out their       courses:
growing responsibilities. The Financial Management
Workforce Plan noted specific competencies                      n   Basic Standard General Ledger
Interior’s workforce must develop to support both                  Accounting;
the implementation of the FBMS and a successful
transformation to a world-class finance organization.           n   Federal Appropriations Law;
The plan emphasized the need for a simultaneous
focus on competency training and development for               n   Intermediate Standard General Ledger;
both the current transition period and for the future.
                                                               n   Internal Controls; and
The Financial Management Workforce Plan
recommends a comprehensive financial                            n   Understanding Budget Formulation
management career path program, with career                        and Execution.
paths defined at multiple levels. Interior has
already implemented an entry-level phase of the          FY 2008 Planned Actions
Financial Management Career Paths Program with            u Conduct a Financial Management needs
the FMCIP. Initial work has begun on the design               assessment
and development of a competency model. The
competency model will be used to develop and               u Begin to design the Financial Management
implement the mid-level, senior-level, and executive-        Career Paths curriculum
level components of this comprehensive program.

Due to budget constraints the Business                   Financial Data Stewardship
Management Conference was not held in FY 2007.
This conference allows the financial community            Financial data stewardship is the process of
to discuss issues that cross bureau lines and            managing information needed to support program
meet face-to-face with those individuals that they       and financial managers, and ensures that data
normally only hear as a voice on a conference call.      captured and reported is accurate, accessible,
The Conference is planned to be held in FY 2008          timely, and usable for decision-making and activity
which will afford financial management staff with an      monitoring. The objective of data stewardship policy
opportunity to network, attend sessions on subjects      is to synchronize data collection processes, reduce
of common interest, and discuss common issues            data redundancy, and increase data accessibility,
among themselves.                                        availability, and flexibility in a systematic manner.
                                                         Effective data stewardship requires that (1)
Many of the individuals active in the implementation     definitions clearly describe requirements and
of the Financial Management Workforce Plan are           characteristics of data to be maintained in financial
from the “baby boomer” era and several retired           management systems; (2) data are created,
during FY 2007. New individuals have been named          recorded, and reported in compliance with
to assist in the effort to implement the Plan.           definitions; and, (3) feedback is provided when data
                                                         are inadequate to meet user needs for information.
                                                         Additionally, data assurance must provide attestation
                                                         to, or comments on, the integrity of the information in
                                                         the system.




110
                                                Compliance with Legal and Regulatory Requirements


The Office of Financial Management provides             FY 2007 Accomplishments
overall coordination of data stewardship functions      u Established project team to review bureau
for financial data in Interior. The data stewardship         revenue source codes, standardize codes,
function involves two levels of activities: (1)             and create a handbook for transition to FBMS.
participating in setting Government-wide financial
data standards; and (2) setting financial data           u Reviewed existing Budget Object Class
standards in coordination with the bureaus’ finance        designations and User Product Codes to
operations.                                               prepare for revision of Handbook in 2008.

PFM participates in Government-wide financial            u Revised the Inter/Intra Agency Handbook to
data standard setting activities and coordinates          reflect the changes in Treasury business rules.
with the Standard Accounting Classification
Advisory Team on setting standards for financial         u Provided support to BLM and NBC in reviews
data for use throughout Interior. PFM monitors the        of their internal processes to identify areas
Departmentwide data definition process, monitors           of opportunity for strengthened financial
data creation and compliance processes, ensures           management.
data usage relies on information derived from
data consistent with the intended definition, and        u Published multiple issue papers to facilitate
ensures adjustments are made to data definitions           the issuance of new or improved financial
when it is inadequate to meet user needs. In              management and accounting policies for intra-
addition, PFM participates in the development and         governmental activity.
implementation of the FBMS and Activity Based
Costing/Management. This function also coordinates      u Published issue paper to facilitate Parent/Child
Departmental financial data definitions with the three      reporting due to the changes in OMB Circular
key Government-wide financial data standard setting        No. A-136.
groups—the Financial Management Service’s
USSGL Board, the Federal Accounting Standards           u Prepared Department responses to Federal
Advisory Board, and OMB.                                  Accounting Standards Advisory Board issues
                                                          related to Oil and Gas reporting, National
To coordinate the establishment and implementation        Aeronautics and Space Administration
of financial data standards in Interior, the bureaus       Research and Development Reporting,
and PFM have chartered the SACAT, under the               Inter-Entity Costs, and Heritage Asset and
leadership of the Finance Officers’ Partnership,           Stewardship Land Reporting,
to establish and maintain a common approach
among the bureaus for addressing USSGL issues           u Established Condition Assessment Guidelines
that relate to accounting policy and procedures,          for U.S. Department of the Interior Library
reporting requirements, internal controls, and SGL        Collections.
maintenance.
                                                        u Participated in FASAB’s Inter-Entity Cost Task
In addition to the SACAT, Interior has developed a        Force to develop a draft technical release in
Financial Statement Guidance Team. The FSGT is            support of Statements of Federal Financial
comprised of the various bureaus of the Department        Accounting Standards #4, Managerial Cost
and deals with issues and concerns related to the         Accounting Concepts and Standards, and
preparation of the performance and accountability         SFFAS #30, Inter-Entity Cost Implementation.
report and implementation of OMB Circular No.
A-136, Financial Reporting Requirements.                u Continued to analyze and enhance the
                                                          reporting process to support performance
                                                          reporting under the GPRA and the timely
                                                          preparation of the Annual Performance and
                                                          Accountability Report.




                                                                                                      111
 Compliance with Legal and Regulatory Requirements


 u Coordinated the reconciliation of intra-Interior   FY 2008 Planned Activities
   financial balances and the reconciliation            u Continue to analyze and enhance the
   of Interior transaction balances with other             reporting process to support performance
   Federal agencies to ensure compliance with              reporting under GPRA and the timely
   new Intragovernmental Business Rules.                   preparation of the Annual Performance and
                                                           Accountability Report.
 u Worked closely with the FBMS Executive
   Steering Committee to monitor implementation        u Continue to coordinate and prepare
   progress; address and resolve accounting              Department responses to draft FASAB, OMB,
   and reporting issues; and ensure appropriate          and Treasury financial reporting guidance.
   internal controls are planned, implemented,
   and functioning as intended.                        u Continue to coordinate the reconciliation
                                                         of intra-Interior financial balances and the
 u Worked with Department of Homeland                    reconciliation of Interior transaction balances
   Security in conjunction with the United States        with other Federal agencies.
   Coast Guard, and U.S. Army Corps
   of Engineers to resolve reporting issues            u Continue to work closely with the FBMS
   related to the Sport Fish Restoration Boating         Execuive Steering Committee to monitor
   Trust Fund to ensure compliance with OMB              implementation progress; address and resolve
   Circular No. A-136.                                   accounting and reporting issues; and ensure
                                                         appropriate internal controls are planned,
 u Continued to communicate with several                 implemented, and functioning as intended.
   agencies on elimination issues (Department of
   Energy, Agency for International Development,       u Continue to work with bureaus to fully
   Department of Defense, Department of Labor,           implement ABC/M throughout the Department.
   Department of Commerce, The Smithsonian
   Institution, and National Aeronautics and
   Space Administration).




112

						
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