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OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Recommendations 2 and 4 

for the Management Advisory 

Titled The Bureau of Land 

Management’s Wild Horse and 

Burro Program Is Not

Maximizing Efficiencies or

Complying With Federal 

Regulations (2016-WR-027)

VERIFICATION REVIEW

Report No.: 2020-WR-015 March 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: Michael P. Colombo 

Western Regional Manager for Audits, Inspections, and Evaluations 

Subject: Verification Review – Recommendations 2 and 4 for the Management Advisory 

Titled The Bureau of Land Management’s Wild Horse and Burro Program Is Not 

Maximizing Efficiencies or Complying With Federal Regulations (2016-WR-027) 

Report No. 2020-WR-015 

The Office of Inspector General has completed a verification review of 

Recommendations 2 and 4 presented in the subject report. Our objective was to determine 

whether the Bureau of Land Management (BLM) implemented the recommendations as reported 

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

In two emails dated October 4, 2017, and September 27, 2018, the PFM reported to us that it had 

closed these two recommendations. Based on our review, we concur that Recommendations 2 

and 4 have been resolved and implemented. 

Background 

Our October 2016 management advisory, The Bureau of Land Management’s Wild Horse 

and Burro Program Is Not Maximizing Efficiencies or Complying With Federal Regulations, 

made four recommendations to help the BLM maximize the cost-effectiveness of its off-range 

wild horse and burro holding facilities and ensure that it is complying with applicable Federal 

laws and regulations. 

On December 2, 2016, the BLM Director responded to the management advisory, 

partially concurring with Recommendation 1 and concurring with Recommendations 2 – 4 and 

detailing the BLM’s plans to implement them. Based on the response, we considered 

Recommendation 1 resolved and implemented. In a December 21, 2016 memorandum, we 

referred the remaining three recommendations to the Assistant Secretary for Policy, Management 

and Budget to track their implementation. 

Scope and Methodology 

We limited the scope of this review to determining whether the BLM took sufficient 

action to implement Recommendations 2 and 4. The BLM is working to implement 

Recommendation 3. To accomplish our objective, we reviewed the PFM’s documentation 

Office of Audits, Inspections, and Evaluations | Sacramento, CA 
 

 

 

 

 

 

supporting its closure of the two recommendations, as well as additional documentation that the 

BLM provided to us upon request. 

We did not test internal controls, perform any site visits, or conduct fieldwork to 

determine whether the BLM had corrected the underlying deficiencies that were initially 

identified. 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 the 

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 BLM implemented Recommendations 2 and 4. 

Recommendation 2: Develop and implement a plan to maximize the transition of wild 

horses and burros from short-term corral facilities to long-term pasture facilities. 

Action Taken: In its response to the management advisory, the BLM noted that housing 

a horse or burro in a corral can be twice as expensive as maintaining one on a contracted pasture. 

The BLM said it had taken steps to shift animals from short-term corrals to long-term pastures 

and noted that these steps were already yielding significant cost savings. 

The BLM assembled a team of wild horse and burro specialists, grants management 

officers, contracting specialists, and procurement analysts to develop guidance on maximizing 

the cost-effectiveness of its off-range holding facilities and the management of the wild horse 

and burro population. In April 2017, the BLM issued Instruction Memorandum (IM) 2017-068 

titled Transition of Wild Horses and Burros from Off-Range Corrals to Off-Range Pastures, 

outlining new policy to maximize the safe and efficient transfer of wild horses and burros with 

low chance of adoption from off-range corrals to off-range pastures for cost reduction. IM 2017-

068 requires the national shipping coordinator to collaborate with the off-range pasture 

contracting officer’s representative in decision-making and to consider animal criteria (e.g., wild 

horses 6 years old or older, wild horses that possess undesirable characteristics for adoption, and 

pregnant mares 5 years old or older) and the following four factors: (1) space availability, 

(2) transportation, (3) weather, and (4) contractor readiness.

A BLM official provided us with documentation showing the shipments of animals from 

off-range corrals to off-range pastures from October 2016 to January 2020. 

Recommendation 4: Comply with existing Federal laws and regulations to ensure all 

correctional institution programs are functioning under appropriate financial instruments. 

Action Taken: In 2016, the BLM conducted an internal control and management review 

of all current agreements related to the use of correctional institutions as off-range corrals. As a 

result of that review, the BLM determined that it would adjust its correctional facility 

procurement instruments as they expire. In addition, the BLM stated that its field-based grants 

management officers will collaborate with its Washington, DC procurement office to ensure that 

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all financial instruments used to acquire corrals and pastures comply with Federal laws and 

regulations and are in the best interest of the Government and taxpayers. 

A September 27, 2018 email from the PFM that closed this recommendation explains that 

the BLM issued IM 2018-059 titled Financial Assistance Standards and Review, which promotes 

more efficient management of financial assistance programs. In addition, the BLM closed 

cooperative agreements with Arizona, Nevada, New Mexico, and Wyoming and in June 2018 

converted the cooperative agreements for these States into a wild horse public off-range facilities 

contract. We reviewed the supporting documentation showing that the BLM converted these 

cooperative agreements into a contract. 

Conclusion 

We conclude that Recommendations 2 and 4 are resolved and implemented. 

We informed BLM officials of the results of this review on March 2, 2020. 

If you have any questions about this verification review, please contact me at 916-978-

6199. 

cc: Andrea Brandon, Deputy Assistant Secretary for Policy, Management and Budget 

William Pendley, Deputy Director for Policy and Programs, exercising the authority of 

the Director, Bureau of Land Management 

LaVanna Stevenson, Audit Liaison Officer, Bureau of Land Management. 

Scot Fluer, Wild Horse and Burro Specialist, Bureau of Land Management 

Rosemarie L. Spano, Civil Engineer, Asset Management Branch, Bureau of Land 

Management 

Vincent A. Myers, Program and Management Analyst, Bureau of Land Management 

3 
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