HISTORICAL ACCOUNTING FOR

INDIVIDUAL INDIAN MONIESA Progress Report
Examples of docu

account transactio

ContentsMessage from the 

Secretary. . . . . . . . . . . . . 1

Executive Summary. . . . . . . 2Historical Accounting:

The Basics . . . . . . . . . . . . 4

Historical Accounting:

Protecting the Past . . . . . . 8

Historical Accounting:

Results . . . . . . . . . . . . . 12

Historical Accounting:

Comparative Analysis . . . 20

Historical Accounting:

Conclusions . . . . . . . . . . 22
Message from the SecretaryFor several years, the Department of the Interior has been involved in an accounting project ofunprecedented proportions. Among other things, Interior has been ordered by the district courtin Cobell v. Norton to document every dollar it has received and disbursed on behalf of

individual Indians since 1887—a task that encompasses billions of dollars, hundreds ofthousands of accounts, and tens of millions of account transactions. Under the district court’sorder, Interior must verify the accuracy of every transaction in its individual Indian accountledgers by reference to the supporting documents. No other federal financial system—not thetax collection system, the Social Security system, or the Medicare system—has ever been taskedwith an undertaking of this type and scope. The resources necessary to accomplish this task are staggering—estimated at more than $12 billion. Although the district court’s order has been stayed pending appeal, Interior hasnonetheless continued its accounting work, consistent with its own 2003 accounting plan andthe funding provided by Congress, and has made substantial progress. Interior’s experience in conducting its accounting has revealed that a very high percentage offinancial records are available—a quarter of a billion pages of Indian records have been collectedand electronically indexed. Interior’s accounting experts have uncovered no evidence of fraud orwidespread systemic error in the U.S. government’s handling of the individual Indian moniesaccounts, and the few errors that have been found are generally small in monetary value. Thispicture is significantly different from that offered by Interior’s critics.This brochure reports on the progress Interior has made in its historical accounting effort. I amvery proud of the historical accounting work Interior has accomplished thus far, through its

dedicated employees and an impressive group of outside contractors. The reported resultsprovide some needed perspective on the allegations that have been made against theDepartment about its handling of individual Indian monies, and will, I hope, informCongressional deliberations as well.

Sincerely,Gale A. Norton

Gale A. Secretar
2

Executive SummaryThe historical accounting work on individual Indian monies (IIM) completed to date by the Department of the Interior supports severconclusions:• Supporting contemporaneous records do exist and can be locate

high percentage of accounts and transactions.

• Differences between supporting records and recorded transactio

number, small in size, and not widespread or systemic.

• There is no evidence that historical records have been altered or 

have tampered with electronic records.

• There is ample evidence that monies collected for individual Ind

distributed to the correct recipients—contrary to the claims of I

Interior has completed a great deal of work to reach these conclusio• About a quarter of a billion pages of Indian records have been c

over 8 million relevant pages, some dating to the 1910s, digitallcoded for search and retrieval. 

• Interior’s accounting consultants, using these documents to reco

compare) the actual IIM account transactions with the expected 

on an examination of the original financial documents and own

• have fully reconciled more than 25,800 out of a total of 42

and Per Capita IIM accounts (accounts based on payments members) with balances as of December 31, 2000, represenof more than $150 million in account balances; and

• have reconciled nearly 17,000 transactions in Land-Based a

(accounts that derive their income from the sale or use of laresources), which in aggregate constitute 10 percent of all tsuch accounts. 

Judgment accounts are often establishedfor Indian minors. 
• Some small differences have been uncovered that affect IIM accounts. While important

to each affected account holder, in each portion of the accounting work to date, onlyabout one percent of all the transactions reconciled has been found to be different fromwhat was expected, some in favor of the account holder (overpayments), and some infavor of the U.S. government (underpayments).

• The aggregate value of the dollars posted that are different from the expected postings

constitutes less than one percent of all the dollars reconciled. 

Through the use of statistical samples, Interior is in a position to draw conclusions with ahigh degree of confidence about the overall accuracy of the transactions in the Land-BasedIIM accounts covering the 1985–2000 period. Based on the sample findings, Interior’sexperts are highly confident that the difference rates for all disbursement and deposittransactions are very small, and that the vast majority of these differences are less than $10.

About a Indian over 8 mdating coded fo
4

Historical Accounting: The Basic
Individual Indian Monies Trust AccountsThe General Allotment Act of 1887 directed that tribal lands be divided into parcelsand given or allotted to individual members of Indian tribes. The initial individualIndian held the sole ownership interest in the allotment. As Indians died, often withoutwills, their heirs each received an undivided interest (or share) in the allotment. Although much of the allotted lands has transferred from Indian ownership since1887, individual Indians today own approximately 3.2 million undivided interestsin approximately 10 million acres of trust lands. Because an individual Indian mayinherit interests from several different ancestors, the total number of individualswho own interests is considerably smaller than the number of interests—only about225,000. The U.S. government is the trustee for the lands and natural resources ofindividual Indians and for the monetary assets they generate. The Secretaries of theInterior and the Treasury manage those monetary assets through the individualIndian monies (IIM) accounts.Requirements for AccountingIn passing the American Indian Trust Fund Management Reform Act of 1994 (the1994 Reform Act), Congress imposed the following duty on the Secretary of theInterior:

The Secretary shall account for the daily and annual balance of all funds held in trust by theUnited States for the benefit of an Indian tribe or an individual Indian that are deposited orinvested pursuant to the Act of June 24, 1938 (25 U.S.C. 162a).

In accordance with this duty, monies received today on behalf of individual Indiansare reconciled on a daily basis, transactions are regularly reported to accountholders (at least quarterly), and an annual audit of the IIM trust accounts isconducted by an independent auditing firm and reported to the account holders.Interior’s current electronic accounting system (the Trust Fund Accounting System)is the same electronic system used by one-third of all U.S. banks. Purpose and Scope of the Historical AccountingThe purpose of the historical accounting for individual Indian monies is todetermine and verify the correctness of the opening balance in today’s accounts.Ever since Interior began collecting funds for and disbursing these funds to Indians,it has maintained systems—first manual and now electronic— to record thosetransactions.

What Are UndividUndivided interests are ownership of allotted lasixteenths, etc. Today aphave about 3.2 million iacres of allotted lands.

Initial ownership 

One 

ow

As ownership passes 

increase w

MMMM

Each heir has 

in the e

MMMMMMMM
Consequently, Interior has divided the historical accounting into tw

the electronic accounting era of 1985–2000 and the prior paper accInterior’s Historical Accounting Plan, issued January 6, 2003, incluaccounts open on or after October 25, 1994 (the date of the 1994 Rpassage), through December 31, 2000 (the date by which all IIM acwere receiving regular quarterly account statements). The Plan calls provide each individual Indian a Historical Statement of Account—includes the opening balance, every transaction that ever occurred iand the ending balance, as recorded manually or electronically. Inteto provide each Indian a statement of assurance regarding the accurHistorical Statement of Account. Types of Individual Indian Money AccountsInterior has separated its historical accounting activities into four diIIM accounts: Judgment, Per Capita, Land-Based, and Special DepoEach account type had dollar balances in them as of December 31, JUDGMENT AND PER CAPITA ACCOUNTSIndividual tribal members received monetary distributions from thetwo general sources:• funds paid to the tribe as a settlement or judgment award, and/o

• re

venue the tribe earned on its activities (e.g., timber cutting, m

extraction) and divided among tribal members as a per capita pato a dividend payment. 

Most judgment and per capita payments were made directly to the but minors and other individuals not eligible for direct payment weIIM accounts. Interior has observed opening balance payments to inaccounts ranging from $43 to $15,370.LAND-BASED ACCOUNTSSome individual Indians received payments based on surface or subother permitted uses of their allotted land and resources. These uses farming, grazing, rights-of-way, mining, timber, and oil and gas pro

6IIM Accounts as ofDecember 31, 2000Interior is examining four kinds ofaccounts that make up the trustfunds held for individual Indians.Three-quarters of all IIM accountsare Land-Based accounts, andnearly one-half of the money in theIIM account balances are in LandBased accounts. 

IIM BALANCES BY ACCOUNT TYPE

Land-Based

$198.0 M

48%

Special Deposit

$67.9 M

16%

Per Capita

$69.5 M

17%

Judgment

$80.8 M 

19%

NUMBER OF IIM ACCOUNTS WITH BALANCES

BY ACCOUNT TYPE

Land-Based

193,766

75%

Judgment

33,205

13%

Per Capita

9,013

4%

Special Deposit

21, 415 

8%
Land-Based account balances and transactions ranged in value from less than $1 to

more than $1 million. As land-based assets were inherited over time, the number ofsmall payments continued to grow, along with the increasing number of undividedowner interests. This pattern continues today. DEPOSIT TRANSACTIONS FOR THE ELECTRONIC ERA: 1985–2000The overwhelming majority of deposit transactions during the electronic records era aresmall in value and cumulatively represent a small percentage of total deposits. For example,during this period, 93.8 percent of the individual deposits were for less than $100 andrepresented 7.3 percent of total dollars received, while 0.1 percent of the individual depositswere for more than $10,000 and represented 60.1 percent of total dollars received.SPECIAL DEPOSIT ACCOUNTSInterior designed Special Deposit Accounts (SDAs) to be temporary holdingaccounts for the deposit of funds that could not immediately be credited to theirrightful owners. SDAs have been used for a variety of reasons, including instanceswhere ownership could not be readily determined, where time constraints preventeddistribution, or where an unresolved issue affected the handling of the funds.Research and analysis of all SDAs must be completed to determine their originalsource of funds and to properly distribute the funds. 

pfp

0

5,000,000

10,000,00015,000,00020,000,00025,000,000

NUMBER OF TRANSACTIONS

$0-1 $1-10 $10-

100

$100-

1,000

$56,729,166

13,921,831

$368,252,328

10,816,503

$1,000-

10,000

$10,000-

100,000

$100,000-

1,000,000

>=$1,000,000

$1,266,545,686

47,038

$1,801,466,595

6,856 $488,898,391

243

2,500,0007,500,000

12,500,00017,500,00022,500,00027,500,000

$1,161,905,728

439,977

$772,619,299

2,805,398

$4,918,58825,395,975

DOLLAR STRATUM
Historical Accounting: Protectin

8
Preserving and Consolidating Indian RecordsSome have alleged that conducting a historical accounting is impossible because theneeded records no longer exist. As a consequence of the work of the Indian ClaimsCommission of the 1950s, the National Archives and Records Administration(NARA) imposed a “do not destroy” order on all Indian records held at FederalRecords Centers—an order that is still in effect today. As a result, the U.S.government has in its possession hundreds of millions of Indian-related documents. For years, inactive individual Indian and tribal trust records were stored under avariety of conditions at various Federal Records Centers and Bureau of IndianAffairs field offices throughout the country. Following passage of the 1994 ReformAct, the need to protect and have ready access to these records prompted an effortto collect and store them in several warehouses in Albuquerque, New Mexico. After learning over time that many of these warehouses were not optimal storagespaces, Interior initiated discussions with NARA to build a state-of-the-artdocument storage facility to consolidate in one location all inactive federal Indianrecords. As a result, in 2003, Interior and NARA entered into an agreement to

Originaledgers fpreserveReposit
establish the American Indian Records Repository (AIRR) in an un

storage center in NARA’s Federal Records Center in Lenexa, Kansascompleted in 2004, and all records were transferred from Albuquerq2005. AIRR has been constructed in accordance with higher standards for preservation of archival records than any other U.S. records storage addition to lower temperature and humidity controls, AIRR has conparticulate matter and ultraviolet light. These controls make AIRR location for the storage of historical records. AIRR also has sufficient future capacity to hold all of Interior’s Amerecords. Documents will continue to be shipped to AIRR as Bureau Affairs and Office of the Special Trustee for American Indians headregional field offices retire records. Access to Indian RecordsAIRR provides secure access to records for research by individual Inand historians, with permission from Interior, and for Interior staff historical accounting. The boxes of records in AIRR are electronicalthe file level, with the resulting data entered into the Box Index SeaThis system facilitates the search for individual paper documents am120,000 boxes that contain about 250 million pages of records currAIRR. Additional Bureau of Indian Affairs records are being collectoffices, and are being indexed and stored in AIRR.Further, Interior estimates that about 70 percent of the accounts th

scope of Interior’s historical accounting were opened in or after 198also relates to the time when accounting transaction records were melectronic system. Interior’s initial historical accounting work has prthese accounts, and has demonstrated that supporting records can bbeing) located. In addition, for some of the accounts that have tranpre-date 1985, older paper accounting ledgers and supporting papebeen located. As part of their reconciliation work, Interior’s accounthave reported that they have not observed any evidence that paper rbeen altered or that hackers have tampered with electronic records.

10

The boxes of records in AIRR areelectronically indexed to the file level,with the resulting data entered into theBox Index Search System. This systemfacilitates the search for individualdocuments among more than 120,000boxes that contain about 250 millionpages of records currently stored in AIRR.Additional Bureau of Indian Affairsrecords are being collected from fieldoffices, and are being indexed and storedin AIRR.
AIRR presearch and hisconductfacility of recor
Historical Accounting: Results

12
Judgment and Per Capita IIM Accounts

To provide a statement of assurance to accompany Historical Statements of Account,Interior has decided to reconcile all transactions in each Judgment and Per Capitaaccount. For the most part, these accounts consist of a single opening deposit postingand periodic interest postings. Because numerous accounts are usually associated witheach Judgment or Per Capita distribution, by reconciling a payment in one account,Interior can also reconcile all the related accounts. Reconciliation of these types ofaccounts is straightforward: • Judgment accounts are reconciled by comparing a posted deposit to (1) the

judgment or Act of Congress award, (2) the Tribal Council resolution to distributethe funds in accordance with a use and distribution plan, and (3) the authorizedtribal membership roll.

• Per Capita accounts are reconciled by comparing a posted deposit to (1) a Tribal

Council resolution, and (2) the authorized tribal membership roll.

• For Judgment and Per Capita IIM accounts, disbursements are reconciled by

comparing the posted disbursement to (1) the amount shown on a paymentauthorization or request for payment document, and (2) proof of clearance orreceipt of the disbursement, such as a check register, negotiated check, or electronicfund transfer confirmation. 

PRINCIPAL POSTINGDifferences identified during the reconciliation process sometimes favor the Indianbeneficiary (overpayments) and sometimes favor the U.S. government(underpayments). The work to date reveals:• More than 51,300 Judgment and Per Capita accounts were reconciled in which no

differences were identified in their principal postings.

• Two Judgment accounts received overpayments totaling $2,205.

• One individual identified on a tribal roll did not receive a Per Capita payment of

$100.

• Interior also found two instances where tribes did not distribute the correct

amounts to their members:

• Interest earned—$52—on a refund of legal fees to a tribe was never distributed

to 21 tribal members; only the refund itself was distributed. 

• Interest earned—approximately $25,000—by a tribe on Judgment funds was

never distributed to 786 accounts; only the principal amounts were distributed.

WHAT ARE DOLLAR ANDIFFERENCES?The accounting reconcian actual deposit, disbuto an account with the ean examination of the cdocuments that were thdifference represents an posted transaction amoexpected—or, in the carecalculated—amount.As part of Interior’s histprocedures, when a difffound, Interior reports thbetween the actual posshould have been postebe positive (the actual pexpected, to the benefit negative (the actual posto the detriment of the a
INTEREST POSTING

Because most Judgment and Per Capita IIM accounts have one depmany interest postings, Interior recalculated the interest posted to epart of the reconciliation process. This recalculation has revealed int(defined as greater than 0.5 percent of the posted interest values), dto calculation errors, for: • 12,533 Judgment IIM accounts—Potential underpayments of le

$225,000 and more than $600,000 in potential overpayments hidentified (out of more than $78 million in posted interest) for overpayment to Indian beneficiaries of $375,000. The underpay0.3 percent of the aggregate interest posted. 

• 1,236 Per Capita IIM accounts—Potential underpayments of le

and potential overpayments of less than $9,000 were made to II(out of more than $14 million in posted interest) for a net undeIndian beneficiaries of $10,000. The underpayments represent 0the aggregate interest posted. 

Land-Based IIM AccountsTo assess the accuracy of the Land-Based Historical Statements of Acchas decided to reconcile (1) all transactions of $100,000 or more and 

sample of transactions less than $100,000. No statistical sampling is in

compiling each individual Indian’s Historical Statement of Account. Samused to test the accuracy of the recorded transactions in the account to 

confidence one should have in the account histories and to provide a assurance. Although Interior considered conducting transaction-by-treconciliation for all transactions in the Land-Based accounts, due to number of transactions (over 23 million deposit and 5 million disburtransactions), of which the substantial majority have a value of less thInterior determined this course was too time consuming and costly. Reconciling Land-Based accounts is more complicated than reconcior Per Capita accounts because many more supporting documents asupport Land-Based transactions, and locating those documents invthrough many boxes of trust records at AIRR and in the field. Alsointerest in allotted lands at the time of the receipt of money must bverify that a posted deposit is the correct amount paid to the right iinterest owner.

14

PROGRESS MADE IN RECONCILINGJUDGMENT AND PER CAPITA ACCOUNTSAs of June 30, 2005, Interior has fullyreconciled 25,842 (61 percent) of the 42,218Judgment and Per Capita IIM accounts withbalances on December 31, 2000.An additional 57,354 Judgment and PerCapita accounts were open on or afterOctober 25, 1994, and were distributedprior to December 31, 2000. As of June 30,2005, Interior has also reconciled 26,323 ofthese zero-balance accounts.

0

20406080

100

THOUSANDS OF DOLLARS

Judgment Per Capita

NUMBER OF ACCOUNTS

33,205

3,995

9,013

21,847

0

20406080

100

MILLIONS OF DOLLARS

Judgment Per Capita

ACCOUNT BALANCES

80,840

28,056

69,847

56,288

ReconciledTo be reconciled
WHAT ARE THE BENEFITS OF SAMPLING?Sampling is a well-accepted means for making inferences about an entire population.Sampling employs a review of selected members of a population based upon theinformed belief that the selected members are representative of the entire population.This “representativeness” allows sound statistical inferences or valid conclusions to bedrawn from the sample and applied to the entire population. For example, when adiabetic tests for blood sugar, the result for the single blood drop—the sample—isassumed to represent the sugar level in all the blood—the population.The proper design, use, and application of statistical sampling:• Saves time—Voter polling keeps candidates quickly informed of changing views

of the electorate by sampling public opinion. Asking every voter his or her opinionwould take far too long.

• Saves money—The Neilsen Ratings of television programs are produced by

sampling what viewers are watching. Producing the Ratings by examining whatevery viewer in America is watching would be far too costly.

• Preserves accuracy—Sampling can provide a high degree of precision and a high

degree of confidence in the accuracy of the results. Examining even 100 percentof a population can produce results that have work errors, especially for largerpopulations. Auditors use sampling to give their assurances regarding the resultsof major financial reports or the regulation of institutions, such as banks.

Land-Bfrom thresourcegrazing
16

The January 6, 2003, Accounting Plancalls for Interior to provide eachindividual Indian with a HistoricalStatement of Account that includes theopening balance, every transaction asrecorded in manual and electronicsystems, and a statement of the accuracyof the statement. To date, more than12,000 Historical Statements of Accounthave been mailed to Judgment accountholders.
Historical Analysis of the “Named Plaintiffs and Their Predecessors in Interest”In 1996, five plaintiffs filed a class action lawsuit (Cobell v. Babbitt, now Cobell v.Norton), demanding, among other forms of relief, an accounting of IIM funds. TheU.S. District Court for the District of Columbia certified “present and former”IIM account holders as a class, and required the Secretary of the Interior to“provide plaintiffs an accurate accounting of all money in the IIM trust held intrust for the benefit of plaintiffs, without regard to when the funds weredeposited.”As part of the Cobell litigation, Interior collected more than 165,000 documents

for the historical analysis of the IIM accounts for the “Named Plaintiffs and TheirPredecessors in Interest.” These documents went back as far as 1914, with seven ofthe 37 IIM accounts examined opened prior to 1920. Even in instances wherethere were gaps in an account’s transaction records, it was possible to reconstructthe missing transactions from the original documents that created the transaction.This historical analysis tested the accuracy of the more than 12,500 recordedaccount transactions by reconciling the source documents to the transactions andthe ownership through time. Upon completing this $20 million effort, Interior(and a partner in Ernst & Young LLP) reached the following conclusions:• The historical IIM ledgers were sufficient to allow Interior to analyze monies

collected and disbursed for the 37 accounts, an amount totaling $1.12 million.

• The documents gathered by Interior allowed 86 percent of the transactions to

be reconciled and supported more than 93 percent of the dollar values of thetransactions analyzed.

• The documents gathered did not reveal any collection transactions that were

not included in the selected IIM accounts, with a single exception in theamount of $60.94, which was paid to another account holder due to atransposed account number entered in the recording process.

• There was no indication that IIM accounts are not substantially accurate, that

monies were not disbursed, or that the transactions are not substantiallysupported by contemporaneous documentation.

As part 

collected the histPlaintifInterest
Differences greater than $1 were noted in some of the amounts pos

differences—totaling nearly $3,500 in overpayments and nearly $25underpayments—constitute a combined difference rate of 0.4 perceunderpayment dollar difference of less than 0.02 percent of the dollInterim Results of the Litigation Support Accounting ProjectCongress has authorized expenditures for accounting work in suppoongoing litigation. The Litigation Support Accounting (LSA) projecaccuracy of Land-Based IIM accounts, and reconciles all high-dollar greater) transactions, and a statistical sample of smaller-value (less thtransactions drawn from Land-Based IIM accounts nationwide. The LSA project is now sufficiently complete to report interim resulocated documents to support over 99 percent of the transactions to in this project, further refuting the notion that the records needed faccounting do not exist, are misfiled, or cannot be located. As a co• Statistical conclusions can be made. These are based on a sampl

6,000 transactions out of the approximately 28 million transact1985–2000 period. It is estimated that more than 40 percent of that have ever flowed through IIM accounts occurred during th

18

Interior has located documents to supportover 99 percent of the transactions to bereconciled in the Litigation SupportAccounting project.
• Interior’s reconciliation of 1,784 high-dollar transactions to supporting

documentation represents more than 10 percent of the aggregate dollars in the1985–2000 period.

Disbursement Transactions. A key finding of the LSA project is the accuracy ofdisbursement transactions—payments made to IIM account holders. • There is no evidence that monies were not disbursed to account holders.• Only ten differences were found among the 956 high-dollar disbursement

transactions reconciled. Three were underpayments totaling more than $1,800,and seven were overpayments totaling more than $19,700 (out of more than$224.8 million reconciled). These underpayment differences represent 0.0008percent of all the dollars reconciled.

• No differences were found in the sampled disbursement transactions (those that

were less than $100,000). The statistical conclusion can be made that, with 95 percent confidence, the underpayment difference rate for disbursements inthe entire population in the 1985-2000 period is no more than 0.6 percent. 

Deposit Transactions. The 828 high-dollar deposit transactions reconciled resulted

in 65 differences: 34 were underpayments totaling just over $60,000, and 31 wereoverpayments totaling just over $33,000. For the 2,117 smaller-value deposittransactions reconciled, 36 differences were identified: 11 were underpaymentstotaling $341 and 25 were overpayments totaling $853. For all deposit transactionsreconciled, this is a difference rate of 3.4 percent. The statistical conclusion can bemade that, at 95 percent confidence, the underpayment difference rate for deposittransactions for the full population in the 1985-2000 period is no more than 3.0percent. SPECIAL DEPOSIT ACCOUNTSThe SDA project is an investigation of balances in active and inactive SDAs todetermine the nature of the balance and the proper ownership of the accountbalance. This project is not a reconciliation process in that its primary goal is todetermine rightful owners—IIM account holders, tribes, and other parties, such asnatural resource companies—of the funds and to distribute their funds to them.Thus far, $36.1 million has been distributed. 

Contemverify fi
Historical Accounting: 

Comparative Analysis

20
Comparison with Other Historical Accountings and Audits

Historical audit and reconciliation studies addressing the soundness of the IndianTrust systems have been conducted by the General Services Administration’s IndianTrust Accounting Division, Arthur Andersen LLP (which conducted tribal trust fundreconciliations covering 1972-1992), the Government Accountability Office, andInterior’s Office of the Inspector General, among others. The National OpinionResearch Center (NORC) at the University of Chicago has reviewed more than 300of these studies and is conducting a meta-analysis of the studies, reports, andreconciliations of the Trust systems. By integrating and synthesizing these variousstudies, NORC’s meta-analysis will provide valuable evidence on the integrity of theIIM Trust Fund and the systems used in its administration over time.Thus far, NORC has found no evidence of fraud or major systemic error in the U.S.government’s handling of the IIM accounts. Although NORC’s meta-analysis isongoing, Interior’s findings, in terms of the number and the size of dollardifferences, are consistent with the findings of the previous studies NORC hasexamined to date. That is, while differences have been noted in transaction records:• the difference rates are small; • the dollar differences are a small percentage of the dollars managed in the Trust;

and 

• the differences appear to be randomly distributed, indicating no systemic issues.

WHAT IS META-ANALYSMeta-analysis is a recogallows conclusions to be similar studies. The statsimilar studies to gain ppossible to assert a morconclusion. Meta-analyscompare epidemiologicatrials to integrate the resparticular area. For examdrawn from the many dicancer rates.

The Na(NORCrevieweaudit athe soun
22

Historical Accounting: Conclusio
Lessons Learned

Including Fiscal Year 2005, Interior has spent more than $100 million conductinghistorical accounting. From this effort, Interior has learned the following:• To a very significant degree, the documents and financial records needed to

conduct the historical accounting are available. Locating the necessary records isa lengthy and expensive process due to the sheer volume of records, but thedocuments are accessible and most can be found.

• Reconciliations completed for Named Plaintiffs, Judgment and Per Capita

accounts, Land-Based transactions of $100,000 or more, and a random,nationwide sample of Land-Based transactions less than $100,000 show verylow rates of differences. Further, most of the differences tend to be small invalue.

• There does not appear to be any bias in the accounting results with respect to

differences that favor or disfavor IIM account holders.

• There is no evidence of fraud or major systemic error in the U.S. government’s

handling of the IIM accounts. Differences found appear to be randomcomputational, posting, or ownership errors.

To date, Interior’s accounting work has principally covered the 70 percent ofaccounts opened in or after 1985 and existing through the 1985–2000 electronicaccounting system era. Records prior to 1985 have been examined in the Judgmentand Per Capita reconciliations and in the “Named Plaintiffs and Their Predecessorsin Interest” reconciliations, which went back as far as 1914. Based on this pre-1985work and NORC’s meta-analysis, there is reason to believe the basic resultsachieved thus far will extend to the earlier paper accounting era.

September 2005 

To a vefinanciaaccount
24

Major Members of the Historical Trust Accounting Consulting TeamProfessional Accounting Firms—Five accounting firms are under contrOffice of Historical Trust Accounting (OHTA): Chavarria, Dunne & Lamey Touche LLP; Grant Thornton LLP; FTI Consulting, Inc.; and Reznick GroKPMG LLP, Arthur Andersen LLP, and Ernst & Young LLP participated in Commercial Trust Operations—The Bank of America, which has the latrust operation in the United States, provides commercial trust expertisStatistical Consultant—NORC, the National Opinion Research Center at of Chicago, provides statistical analysis.Historians—Morgan, Angel & Associates LLC, and Historical Research provide expertise on leasing, the allotment process, and reservation hiTrust Legal Advisor—The Washington-based trust specialist law firm, HBentzen, PLLC, provides expert trust law advice.Accounting Reconciliation Tool—Booz/Allen/Hamilton developed the syaccountants use to compare IIM transactions to trust records that supptransactions and record the findings.Information Technology Security Advisor—Government & Business Solprovides consulting on the security of trust data and information technDocument Imaging and Coding—Ecompex, Inc., has imaged and codemillion pages of documents, which are stored in OHTA’s Accounting ReMinerals Records Consultant—Gustavson Associates assists in identifyrelating to oil and gas leases on lands allotted to individual members oRecords Storage and Indexing—For the Office of Trust Records, Labat-developed the Box Index Search System, and then implemented it, inclthe boxes of records. Labat-Anderson advises OHTA on records storag

Many firms are involved in conductingthe historical accounting.
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