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OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

VERIFICATION REVIEW

Recommendations

for the Evaluation Report 

Titled Bureau of Indian Affairs’ 

Southern Ute Agency’s 

Management of the Southern Ute

Indian Tribe’s Energy 

Resources

(CR-EV-BIA-0011-2014) 

Report No.: 2020-CR-025 September 2020
 

 

 

 

 

 

 

 

 

 

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Memorandum 

To: 

From: 

Subject: 

Tonya Johnson 

Deputy Chief Financial Officer and Director, Office of Financial Management 

Amy R. Billings 

Central Region Manager for Audits, Inspections, and Evaluations 

Verification Review – Recommendations for the Evaluation Report Titled 

Bureau of Indian Affairs’ Southern Ute Agency’s Management of the 

Southern Ute Indian Tribe’s Energy Resources (CR-EV-BIA-0011-2014) 

Report No. 2020-CR-025 

The Office of Inspector General has completed a verification review of seven 

recommendations presented in the subject report. The objective of this review was to determine 

whether the Bureau of Indian Affairs’ (BIA’s) Southern Ute Agency implemented the 

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

Management and Budget. The PFM reported to us that it closed the recommendations. We 

concur that the recommendations have been resolved and implemented. 

Background 

Our February 9, 2016 evaluation report, Bureau of Indian Affairs’ Southern Ute Agency’s 

Management of the Southern Ute Indian Tribe’s Energy Resources, made seven 

recommendations designed to improve the effectiveness of the Agency’s oversight of the 

Southern Ute Indian Tribe’s energy resources. The Acting Director of the BIA concurred with 

our recommendations in a memorandum dated January 6, 2016 and detailed how the Agency 

would address each recommendation. In a February 12, 2016 memorandum, we referred the 

seven recommendations to the Director of the PFM to track their implementation. 

Scope and Methodology 

The scope of this review was limited to determining whether the Agency implemented 

the seven recommendations. To accomplish our objective, we reviewed the supporting 

documentation the Agency provided to the PFM. We also collected and reviewed additional 

supporting documentation from the Agency. We did not test internal controls, perform 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. 

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

 

 

 

 

 

 

 

 

 

 

 

 

Results of Review 

We found that the Agency has implemented all seven recommendations. 

Recommendation 1: We recommend that the BIA enter into a memorandum of 

understanding (MOU) or another type of formal agreement with the Tribe that would 

better define the Tribe’s role in performing work to support the BIA’s review and 

approval of the Tribe’s mineral leasing activities. 

Actions Taken: The Agency entered into an MOU with the Tribe in January 

2017 to better define the Tribe’s and the BIA’s roles in performing the review and 

approval of energy-related functions. 

Recommendation 2: We recommend that the BIA provide oil and gas leasing 

training for staff and consider accepting tribal offers for energy-specific training. 

Actions Taken: The BIA provided multiple energy-related training sessions, 

including training with modules specific to oil and gas leasing. Additionally, the Agency 

has attended energy-related training sessions with the Tribe’s staff and has contacted the 

Tribe and other relevant organizations to ask about any offerings of other energy-specific 

training. 

Recommendation 3: We recommend that the BIA collaborate with other tribal 

agencies for energy-specific expertise, training, and staffing for energy-related functions. 

Actions Taken: The Agency collaborated with the Tribe and Federal agencies to 

secure energy-specific expertise and staffing for energy-related functions. Specifically, 

the Agency secured support staff for energy-related tasks from the Tribe, the BIA’s 

Southwest Region, and the Indian Energy Support Center. Additionally, the Agency 

contacted the Uintah and Ouray Agency and the Indian Affairs’ Minerals and Energy 

office to ask about any offerings of energy-specific training. 

Recommendation 4: We recommend that the BIA actively recruit qualified 

energy staff by seeking authority to consider all incentives and hiring flexibilities such as 

recruitment bonuses, retention bonuses, relocation incentives, and special pay provisions. 

Actions Taken: The Agency recruited extensively for the realty specialist 

position in fiscal years 2016 and 2017. The position description was amended to include 

responsibilities for realty processes related to oil and gas lease activity, Indian mineral 

development agreements, tribal energy resources agreements, and rights-of-way for oil 

and gas pipelines. In several of the job announcements for the realty specialist position, 

the Agency included incentives and hiring flexibilities such as recruitment bonuses, 

relocation incentives, and special pay provisions. 

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Recommendation 5: We recommend that the BIA develop and implement 

official, comprehensive, internal Agency policies and procedures that govern, guide, and 

regulate energy activities. 

Action Taken: The Agency has provided its staff the BIA Fluid Mineral Estate 

Handbook, which identifies authorities and policies for the management of fluid minerals and 

establishes comprehensive procedures for the management of fluid minerals estate. Additionally, 

the Agency has directed its staff to use several operating procedures in the management of 

energy resources on the Tribe’s lands. These include procedures for: 

• Processing applications for permit to drill

• Processing authorizations for: drilling oil and gas wells, right of way easements, and

surface leases for energy development projects

• Conducting onsite visits for energy-related projects

• Processing communitization agreements

• Encoding and recording all energy-related activities into the Trust Asset and

Accounting Management System

Recommendation 6: We recommend that the BIA ensure that the corrective 

action plan is actively managed by the responsible official to meet the established 

milestones. 

(Note: The corrective action plan cited in this recommendation was issued in 

September 2014 by the Office of Trust Review and Audit and identified remedies to 

significant records management deficiencies.) 

Actions Taken: The Agency’s superintendent took corrective action to address 

records management deficiencies. These actions were taken during our fieldwork for our 

evaluation report (fiscal years 2014 and 2015) and addressed findings from a January 

2014 OIG report titled Records Management at Selected Bureau of Indian Affairs’ 

Agency Office (CR-IS-BIA-0001-2014). Specifically, the superintendent managed the 

development of a recordkeeping plan and standard operating procedures to ensure 

accuracy and completeness of trust and nontrust records. Additionally, the superintendent 

managed the development of safeguards to protect trust and nontrust records. 

Recommendation 7: We recommend that the BIA actively monitor and report to 

the Division of Internal Evaluation and Assessment on progress of the corrective action 

plan. 

Actions Taken: As identified in our review of Recommendation 6, we found that 

the Agency’s superintendent monitored the progress of the corrective action plan. Indian 

Affairs emailed us on August 13, 2020, to tell us that the Agency had reported its 

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progress on the corrective action plan to the Division of Internal Evaluation and 

Assessment throughout fiscal years 2016 and 2017. 

Conclusion 

We conclude that all seven recommendations are resolved and implemented. We 

informed the BIA’s Southern Ute Agency officials of the results of this review on August 25, 

2020. If you have any questions about this verification review, please contact me at 303-236-

9243. 

cc: 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, PFM Audit Liaison 

Tara Sweeney, Assistant Secretary-Indian Affairs 

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

Karen Frejo, BIA Audit Liaison Officer 

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