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OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Recommendations 1 – 15, 19,

and 21 From the Evaluation

Report Titled Condition of Indian 

School Facilities

(C-EV-BIE-0023-2014) 

VERIFICATION REVIEW

In recognition of Secretarial Order No. 3380, we are providing estimated costs 

associated with certain work products. Applying a formula involving prior salary and 

benefit expenses, we estimate the cost of preparing this report to be $29,000.

Report No.: 2020-CR-026 November 2020
 

 

 

 

 

 

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Memorandum 

To: Tonya Johnson 

Deputy Chief Financial Officer and Director, Office of Financial Management 

From: Amy R. Billings 

Regional Manager, Central Region 

Subject: Verification Review – Recommendations 1 – 15, 19, and 21 From the Evaluation 

Report Titled Condition of Indian School Facilities (C-EV-BIE-0023-2014) 

Report No. 2020-CR-026 

The Office of Inspector General has completed a verification review of 17 of the 21 

recommendations presented in the subject report. Our objective was to determine whether the 

Office of the Assistant Secretary- Indian Affairs (IA) implemented the recommendations as 

reported to the Office of Financial Management (PFM), Office of Policy, Management and 

Budget. The PFM reported to us when each of the 17 recommendations were addressed and 

provided supporting documentation. Based on our review, we consider recommendations 1 – 13, 

15, and 21 resolved, implemented, and closed. We consider Recommendations 14 and 19 not 

implemented and recommend they be reopened for implementation tracking. 

Background 

In our September 30, 2016 evaluation report, Condition of Indian School Facilities, we 

found systemic issues with facilities management, major facility deficiencies, health and safety 

concerns, and information not documented in the Bureau of Indian Affairs’ (BIA’s) facility 

management system for the 13 schools we visited. We made 21 recommendations designed to 

help the BIA and the Bureau of Indian Education (BIE) develop promising practices to ensure 

that Indian school facilities are operated and maintained properly for the students. 

We did not receive a formal response from the IA prior to our final report’s publication, 

thus, we referred all 21 recommendations to the Director of the PFM to track their resolution and 

implementation. Shortly thereafter, we learned that the IA had already begun implementing some 

of our recommendations and in April 2017, the PFM reported that the IA generally concurred 

with all our recommendations, except Recommendation 8, and provided the names of 

responsible parties and target dates for implementation of each recommendation. 

Scope and Methodology 

We limited the scope of this review to the 17 recommendations reported closed by the 

PFM. Between May 2017 and October 2018, the PFM reported Recommendations 1 – 15, 19, 

Office of Audits, Inspections, and Evaluations | Lakewood, CO 
 

 

 

 

 

 

 

 

 

 

 

and 21 as closed. Recommendations 16, 17, 18, and 20 were not reported as closed and are not 

included in this review. 

To accomplish our objective, we reviewed the supporting documentation the IA provided 

to the PFM, and collected and reviewed additional supporting documentation from the IA. We 

did not perform internal control testing, site visits, or conduct fieldwork to determine whether the 

underlying deficiencies that we initially identified have been corrected. As a result, this review 

was not conducted in accordance with generally accepted government auditing standards, issued 

by the Comptroller General of the United States, or Quality Standards for Inspection and 

Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency. 

Results of Review 

We found that the IA implemented 15 of the 17 recommendations reported closed by the 

PFM. We determined that recommendations 14 and 19 have not been fully implemented and 

should be reopened until the IA: 

• Ensures facility condition assessments are conducted every 3 years (Recommendation 14)

• Confirms that all the deficiencies identified in our previous report have been corrected or

accounted for in the IA-Facility Management System (Recommendation 19)

Recommendation 1: Develop, implement, and communicate a detailed project

plan for completing the transition to Maximo. 

Action Taken: When transitioning to the new system, the IA developed a 

communication plan for IA-FMS that included numerous training sessions, quick user guides for 

Maximo applications, and, in November 2015, an IA-FMS briefing for stakeholders. Among the 

topics covered in this briefing were the IA’s system implementation strategy, the status and 

milestones of the system transition, and the IA end-user training. We consider Recommendation 

1 resolved, implemented, and closed. 

Recommendation 2: Provide access to a more consistent training program for 

school staff on entering data into both FMIS and Maximo until Maximo is fully 

implemented 

Action Taken: The IA fully transitioned to IA-FMS in July 2015. Through its Division 

of Facilities Management and Construction (DFMC) and the DIT, the IA provided classroom 

training on entering data into Maximo to over 680 school staff, as well as 29 webinars on a 

variety of topics, many of which were posted on the BIE’s website. In addition, another division 

within the IA, the Division of Safety and Risk Management, hosted Safety Inspector trainings 

from 2015 through 2017. Further, in fiscal year (FY) 2018, the DFMC and the DIT collaborated 

on developing other training capabilities, such as how-to documents and demonstrations, in 

response to new topics and changes. The previous system, FMIS, was closed and subsequently 

decommissioned once Maximo was fully implemented, therefore the training related to the FMIS 

is no longer relevant. We consider Recommendation 2 resolved, implemented, and closed. 

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Recommendation 3: Communicate to schools regarding points of contact for 

technical assistance. 

Action Taken: In September 2017, the IA issued a memorandum to all programs 

supporting BIE-funded schools defining the roles and responsibilities for various facilities 

management staff, including those available to provide technical assistance. Additionally, a 

national directory on the BIE’s website includes points of contact at the regional level and within 

the DFMC. We consider Recommendation 3 resolved, implemented, and closed. 

Recommendation 4: Ensure accounts and passwords for Maximo are established 

and used. 

Action Taken: The DFMC and the supporting contractor, DIT, established access 

requirements, accounts, and passwords for the IA-FMS. Instructions on IA web applications and 

user roles are outlined in the IA User Management Portal Guide developed in April 2017. The 

guide requires passwords and registration to access the portal. Further, users are required to 

access IA-FMS at least once every 90 days to remain active. To monitor account usage and the 

status of inactive users, the DFMC sends monthly Users Audit Reports to BIA and BIE 

managers. We consider Recommendation 4 resolved, implemented, and closed. 

Recommendation 5: Create a tracking and reminder system to document which 

schools are actively accessing their accounts and entering information. 

Action Taken: The Users Audit Report, created by the DFMC and the DIT, identifies 

users’ activities within IA-FMS. The report contains user information, including active or 

inactive status, number of days not logged in, and date of the last login. On a monthly basis, the 

DFMC sends the user report to BIA and BIE managers for their information or action. In 

addition to the report, the DFMC and the DIT created a gatekeeper review process that includes 

levels of review for each work order submitted by schools. The IA does not track which schools 

actively enter work orders in the system because of varied conditions and number of work orders 

for each school. However, the DFMC can review work order history to see when status changes 

occur. We consider Recommendation 5 resolved, implemented, and closed. 

Recommendation 6: Determine which schools have connectivity issues, help the 

schools identify what is necessary to enhance the networks from the grid reliability 

stance, and document any infrastructure needs in the facility management system. 

Action Taken: The IA’s Office of Information Management Technology (OIMT), in 

conjunction with the BIE, is responsible for monitoring network reliability and coordinating and 

tracking network upgrades. To determine which schools had connectivity issues, the IA issued 

the Education Native American Network II Broadband Progress report, which identified whether 

school connectivity speeds, for both tribally controlled and BIE-operated schools, met the 

established modified and full standards set forth by the State Education Technology Directors 

Association. The report determined that in FY 2017, 68 schools did not meet modified standards 

and 78 schools did not meet full standards. To enhance networks and grid reliability, the IA 

completed upgrades at 53 schools in FY 2017, and planned to upgrade the remaining schools by 

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FY 2019. Further, the OIMT noted that it documents infrastructure needs in Remedy, the DOI’s 

system of record for IT service needs, not in the IA-FMS. We determined that the IA met the 

intention of Recommendation 6. We consider Recommendation 6 resolved, implemented, and 

closed. 

Recommendation 7: Until networks issues are resolved, explore alternative 

means for capturing the schools’ data in the facility management system. 

Action Taken: The IA allowed access to the IA-FMS Maximo application from the 

public Internet. This enabled all users (BIA, BIE, tribal, or IA) to access the Maximo application, 

enter work orders, and create job plans. However, some applications that work in conjunction 

with Maximo, like the Safety and Condition Assessment Portal (S&CAP) where inspections are 

tracked and recorded, must reside within the restrictive IA Trust Network. The IA stated that it 

plans to move the S&CAP system to an internet-based application called ColdFusion, but in the 

meantime, users must coordinate with their region or agency location to gain access directly. We 

determined that the IA mitigated S&CAP access issues by developing and communicating a 

procedure for non-Trust network users to complete abatement plans outside of the S&CAP until 

the ColdFusion application is live. We consider Recommendation 7 resolved, implemented, and 

closed. 

Recommendation 8: Redesign the way FCI is calculated and used in funding 

allocations to allow consideration for the condition of individual structures. 

Action Taken: The IA disagreed with our recommendation and provided two reports to 

demonstrate its assertion that the Facility Condition Index (FCI) allows consideration for the 

condition of individual structures. Based on a structure summary report provided by the DFMC, 

we determined that the IA uses FCI scores to grade both the condition of the school as a whole, 

and individual structures at each school. Specifically, the FCI Summary Report with Location 

Detail, provided by the DFMC, assigned numerical FCI scores and a rating of Poor, Fair, or 

Good, to all individual structures. Further, the IA’s School Deferred Maintenance Work Order 

Report contained detailed descriptions about facility deficiencies, category, rank, and estimated 

costs. The IA stated that it considers these data and additional factors other than the FCI when 

making funding decisions such as the size, age, and isolation of the school. We determined that 

the IA demonstrated its use of the FCI that allows for consideration of the condition of individual 

structures, and reports provided by the DFMC indicate the FCI is not the sole factor used in its 

capital improvement and funding decisions. Therefore, we determined that the IA has met the 

intent of Recommendation 8 and consider the recommendation resolved, implemented, and 

closed. 

Recommendation 9: Identify and clarify the specific roles and responsibilities 

that BIA and BIE have in school facilities management and then publicize those roles and 

responsibilities to bureau staff and schools. 

Action Taken: In September 2017, the IA issued a memorandum titled Facilities 

Management Communication and Organizational Roles and Responsibilities 

Clarification to all BIE, BIA, and Central Office programs supporting BIE-funded 

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Schools; associate deputy directors; BIE facility managers; regional directors; and 

regional facility managers. The memorandum delineated the various roles and 

responsibilities within BIA and BIE related to BIE-funded schools. Additionally, the 

memorandum identified weekly status conference calls and process action teams as 

methods to publicize the roles and responsibilities. Lastly, the IA met with the Ramah 

Navajo School Board and Pine Hill Boarding School in September 2017, to further 

ensure that these responsibilities were understood. We determined that the IA identified 

and clarified the BIA’s and the BIE’s specific roles and responsibilities in school 

facilities management and publicized those roles and responsibilities to bureau staff and 

schools. We consider Recommendation 9 resolved, implemented, and closed. 

Recommendation 10: Update contact lists for both BIA and BIE facilities 

personnel and post them online and distribute them to the schools. 

Action Taken: The IA chose to develop a national directory instead of updating a contact 

list that may become irrelevant with employee turnover. The directory—including points of 

contact at the BIE, the BIA, and the DFMC—is posted on the BIE’s website and accessible to 

schools. We determined that the IA updated contact lists for both BIA and BIE facilities 

personnel and posted them online. Therefore, we consider Recommendation 10 resolved, 

implemented, and closed. 

Recommendation 11: Devise and implement a strategy to improve 

communication between the bureaus and the schools and to share information including 

alternate and in-house funding sources, updated contact information, and best practices. 

Action Taken: To help improve communications between the IA and the schools, the 

DFMC developed a Communication Improvement Plan With Bureau of Indian Education. The 

plan identifies priority communication issues, communication strategies and themes, and 

numerous communication channels to be used to disseminate focused messages to a variety of 

stakeholders. The improvement plan also contains a detailed action plan clarifying the activities, 

responsible parties, milestones, and outcomes for identified priority communication issues. 

Further, the DFMC maintains and updates a public internet site with pertinent facilities related 

information; conducts weekly regional facility managers conference calls; and participates in 

BIE-sponsored training events, conferences, and meetings. We consider Recommendation 11 

resolved, implemented, and closed. 

Recommendation 12: Improve monitoring to ensure funds are used for the 

intended and approved purposes and that projects are completed to applicable quality 

standards. 

Action Taken: In its closure request, the IA outlined the DFMC’s responsibility 

for providing program management, construction, and program oversight. The DFMC 

tracks projects by ensuring all funded projects are assigned a unique code tracked within 

IA-FMS that ties the project to an approved deferred maintenance entry and to specific 

budget activities. According to the IA, all funding requests require approval from the 

DFMC division chief. In addition, the DFMC holds regular meetings with program 

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managers to discuss project issues and conducts annual internal control reviews. We 

determined that the IA met the intent of Recommendation 12 and consider the 

recommendation resolved, implemented, and closed. 

Recommendation 13: Communicate that unspent funds should be returned for 

potential reallocation. 

Action Taken: The IA issued a National Policy Memorandum (NPM), effective in February 

2018 and until official policy can be established, which delineated procedures to follow in 

returning unspent funds for reallocation purposes. Additionally, the IA has used weekly staff 

conference calls and emails to communicate information about the reallocation of unspent funds. 

For example, minutes from a January 2017 conference call with regional facility managers, the 

BIE, and the Office of Justice Services, documented approval of the NPM and underscored a 

provision about returning any savings or carryover to the DFMC for reallocation. Procedures for 

returning unspent funds for allocation have not yet been formally incorporated into the BIA’s 

policy manual; however, a recent amendment to the NPM extended the memorandum’s 

provisions to February 2021. We determined that the IA communicated that unspent funds 

should be returned for potential reallocation. Therefore, we consider Recommendation 13 

resolved, implemented, and closed. 

Recommendation 14: Revisit the condition assessment contract to ensure that 

inspections are thorough, captured in the facilities management system, and completed 

every 3 years. 

Action Taken: The IA modified its Facility Condition Assessment (FCA) 

contract performance work statement in 2016, to include an enhanced scope of services 

beyond a snapshot of current conditions. In addition, between 2015 and 2017, the DFMC 

held regularly scheduled quarterly contract performance meetings with the FCA 

contractor and other IA stakeholders to ensure inspections were thorough and that any 

problems were identified. It also hosted financial management and other coordination 

meetings to discuss how information would be captured in the newly released IA-FMS, 

among other topics. Further, in its recommendation closure to the PFM, the IA provided 

the DFMC’s Three Year Condition Assessment-Inventory Validation Site Visit Schedule. 

In reviewing the schedule, however, we noted several instances in which it appeared that 

school inspections would not be completed every 3 years. 

We asked the DFMC for additional information and it provided an assessment site 

listing status report covering the current FCA contract’s 3-year period of performance, 

from 2018 to 2020. Our review of this document confirmed that school inspections were 

not being completed every 3 years. The DFMC told us that the gaps in assessments of 

some sites was due to acquisition issues that delayed the award of a new contract. 

Further, the DFMC noted that it was currently soliciting for yet another new contract due 

to the failure of the current contractor to perform adequately. We confirmed that the 

DFMC’s final FCA statement of work for the new contract—dated June 2020— 

specifically outlines the IA’s standard that comprehensive assessment inspections be 

conducted every 3 years. However, until the IA’s current contract is in place and it can 

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confirm that inspections have taken place every 3 years, we recommend the PFM reopen 

Recommendation 14 and continue tracking its implementation. 

Recommendation 15: Create a standardized checklist for minimum critical 

factors for health and safety inspections. 

Action Taken: In December 2016, the IA’s Division of Safety and Risk Management 

(DSRM) published comprehensive inspection guidelines for safety, health, and 

accessibility, and fire systems inspection, testing, and maintenance. Included in the 

guidelines are detailed checklists for identifying unsafe, unhealthy, and non-compliant 

items and conditions needing correction. To disseminate this information, the IA 

conducted webinars, issued memoranda to senior responsible officials and program 

managers in the BIA and the BIE, and developed PowerPoint presentations about the new 

guidelines. We determined that the IA created a standardized checklist for minimum 

critical factors for health and safety inspections. We consider Recommendation 15 

resolved, implemented, and closed. 

Recommendation 19: Take corrective action for the deficiencies noted in this 

report or ensure that these items are entered into FMIS for future funding consideration. 

Action Taken: We identified 24 deficiencies in our previous evaluation report. In its 

recommendation closure to the PFM, the IA stated that the DFMC worked with BIA and BIE 

officials to confirm the status of the deficiencies identified in the report, and provided a Deferred 

Maintenance (DM) work order report dated September 2017, along with an explanation as to 

how identified deficiencies are added to IA-FMS. The IA did not provide evidence that the 

identified deficiencies were corrected. We asked for additional information and received a 

project funding summary report dated June 29, 2020, which included the status of current DM 

work orders within IA-FMS. Based on our review of both reports, we found that only 7 of the 24 

reported deficiencies from our previous evaluation were entered into IA-FMS. We also 

confirmed, during a separate inspection we conducted in November 2019, that one additional 

deficiency—undocumented fire extinguisher inspections at Pine Hill School—had been 

corrected. In total 16 deficiencies identified in our previous report appear to be unaddressed (see 

attachment). Until the IA can confirm that all the deficiencies noted in our evaluation report have 

been corrected or submitted into IA-FMS for future funding consideration, we recommend the 

PFM reopen Recommendation 19 and continue tracking its implementation. 

Recommendation 21: Review the existing inventory for the schools and make 

any necessary corrections so the inventory and additional needs of the schools are 

accurately reflected for funding considerations. 

Action Taken: The IA issued a memorandum to all regional directors, central office 

directors, the BIE, and education resources centers in January 2018, which formally addressed 

and transmitted property inventory and certification procedures for FY 2018, including key due 

dates. The memorandum provided explicit instructions for completing the personal and property 

annual inventory. Once completed, each regional director signed a certification statement, 

acknowledging their compliance with all the requirements of the procedures and accuracy of 

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their reported inventories. Although physically verifying these inventories was beyond the scope 

of this review, we believe annual certifications by the regional directors meet the intent of the 

recommendation. We consider Recommendation 21 resolved, implemented, and closed. 

Conclusion 

We conclude that Recommendations 1 – 13, 15, and 21 are resolved and implemented, 

but Recommendations 14 and 19 have not been fully implemented. We recommend the PFM 

reopen Recommendations 14 and 19 and continue tracking their implementation until the IA 

can (1) ensure that facility condition assessments are conducted every 3 years, and (2) confirm 

that all the deficiencies identified in our previous report have been corrected or accounted for in 

IA-FMS. We informed BIA officials of the results of this review on August 21, 2020. 

We would like to thank the DFMC for providing us the information requested during our 

review. If you have questions about this verification review, please contact me at 303-236-9243. 

Attachment 

cc: Tara Sweeney, Assistant Secretary – Indian Affairs 

Richard Myers, Audit Liaison Officer, Chief of Staff – Indian Affairs 

Andrea Brandon, Deputy Assistant Secretary – Budget, Finance, Grants and Acquisition 

Chadrick Minnifield, Chief, Internal Control and Audit Follow-Up, Office of Financial 

Management 

Alexis Vann, Office of Financial Management 

Karen Frejo, Bureau of Indian Affairs Audit Liaison Officer 

Spike Bighorn, Bureau of Indian Education, Audit Liaison Officer 

8 
Unaddressed Deficiencies Identified in our Prior Report 

School Name Report Deficiency 

Borrego Pass (Dibe Yazhi) Water valves in computer lab 

were not capped off or removed 

Laguna Elementary* Structural cracking 

Lukachukai Boarding School * Roofing issue 5 y ears after being 

replaced 

Moencopi Day School Boiler room bolted shut, which 

did not allow for inspection 

Tonalea Day School * Sprinklers not working 

Pierre Indian Learning Center •

•

•

•

•

•

Damaged bathroom walls 

and floor 

No ventilation system in 

main building 

Gutters drain to 

foundation 

Administration building 

foundation cracked and 

asbestos tiles in 

basement utility room 

Roofing materials left 

exposed 

Portable damage 

Rosebud Dormitory (Sicangu 

Owayawa Oti) 

Equipment not inspected for 

more than 8 years 

Ahfachkee Day School Portable floor damage 

Cherokee Central Schools Improper drainage allowed rain 

to flow into 5 -year-old facilities 

and contributed to cracking in 

floors and walls, flooded utility 

bays under bleachers, and 

standing water 

Flandreau Indian School Sprinkler installed adjacent to 

light fixture 

Tuba City Boarding School Exposed wiring in elementary 

school 

Attachment 

* IA identified these three schools for total school replacements in 2016.

9 
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