OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OFTHE INTERIOR 

VERIFICATION REVIEW 

Recommendations 1 – 3 and 4 – 6 

From the Evaluation Report 

Titled, The Bureau of Indian 

Education Is Not Ensuring That 

Background Checks at Indian 

Education Facilities Are Complete 

(Report No. 2017-WR-024) 

Report No.: 2020-CR-033 September 2020 
Office of Audits, Inspections, and Evaluations | Washington, DC

Memorandum 

To: Tonya Johnson 

Deputy Chief Financial Officer and Director, Office of Financial Management 

From: Amy R. Billings 

Central Region Manager for Audits, Inspections, and Evaluations 

Subject: Verification Review – Recommendations 1 – 3 and 6 – 8 From the Evaluation 

Report Titled The Bureau of Indian Education Is Not Ensuring That Background 

Checks at Indian Education Facilities Are Complete (2017-WR-024) 

Report No. 2020-CR-033 

The Office of Inspector General has completed a verification review of 6 of the 11 

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

Bureau of Indian Education (BIE) implemented the recommendations as reported to the Office of 

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

us that the recommendations had been implemented and closed. We concur that 

Recommendations 1 – 3 and 6 – 8 have been implemented. 

Background 

Our February 2018 evaluation report, The Bureau of Indian Education Is Not Ensuring 

That Background Checks at Indian Education Facilities Are Complete, found that the BIE was 

not completing and updating required background checks for its employees, contractors, and 

volunteers who have regular contact with children. We made 11 recommendations to help the 

BIE improve its background check process for both BIE-operated and tribally controlled schools. 

On December 26, 2017, the BIE responded to our draft report, concurred with the 

report’s recommendations, and detailed its plans to implement them. On the basis of the 

response, we considered Recommendations 1 – 10 resolved but not implemented and 

Recommendation 11 to be unresolved. In a February 15, 2018 memorandum, we referred the 11 

recommendations to the Assistant Secretary for Policy, Management and Budget to track their 

resolution and implementation. As of June 2, 2020, the PFM reported Recommendations 1 – 3 

and 6 – 8 as implemented and closed; therefore, only these six recommendations are included in 

the scope of this review. The five remaining recommendations had not been reported as closed at 

the start of this review. 
2

Scope and Methodology 

We limited the scope of this review to determining whether the BIE implemented the six 

recommendations reported closed. To accomplish our objective, we reviewed the supporting 

documentation the BIE provided to the PFM and collected and reviewed additional supporting 

documentation from the BIE. We did not perform internal control testing, visit sites, or conduct 

fieldwork to determine whether the underlying deficiencies 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 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 BIE has implemented Recommendations 1 – 3 and 6 – 8. 

Recommendation 1: Develop and implement policy requiring that local law enforcement 

checks, including tribal law enforcement, be completed prior to final adjudication of the OPM 

[U.S. Office of Personnel Management] background check. 

Action Taken: The BIE Human Resources Officer issued a memorandum to his staff, 

dated March 19, 2019, to update the personnel security pre-employment screening process to 

ensure coverage for State and local law enforcement checks. In addition, the policy includes 

follow-up action if disqualifying issues are identified. The BIE Human Resources Office 

followed that memorandum with more detailed policy, signed June 10, 2019, requiring the 

completion and favorable review of local law enforcement inquiries (tribal) and State criminal 

history repository checks prior to entry-on-duty and suitability determinations. This process 

change was effective June 2019 and applied to all childcare-designated positions within the BIE. 

Therefore, we consider Recommendation 1 implemented and closed. 

Recommendation 2: Follow up with the Navajo Police Department to identify and 

implement the steps needed to complete the local law enforcement checks.

Action Taken: Local law enforcement checks involving the Navajo Police Department 

had not been completed as the checks required a nominal fee. According to the security specialist 

who formerly led BIE background checks, the Navajo Police Department was willing to waive 

the local law enforcement fee, following a formal request from the BIE Director. According to 

the BIE’s response to our recommendation, the Office of the Director, BIE, and the Solicitor's 

Office coordinated on an agreement between the BIE and the Navajo Nation to waive the fee and 

complete the local law enforcement checks. However, the BIE was unable, ultimately, to 

implement the waiver agreement with the Navajo Nation. Instead, the BIE updated its Security 

Screening Requirements for BIE Childcare Positions policy to include a requirement that the 

applicant is responsible for any required fees incurred during tribal law enforcement 

coordination. The BIE noted that it informed the Navajo Police Department of the changes that 

were put in place in lieu of the waiver agreement. 
3

On the basis of our review of closure documentation, we concluded that, although the 

BIE did not come to an agreement with the Navajo Nation, the BIE mitigated the payment issue 

with the updated policy, which included applicant responsibility for local fees and required 

completion of local law enforcement inquiries prior to final determination. Therefore, we 

determined the BIE met the intent of Recommendation 2, and we consider it implemented and 

closed.

Recommendation 3: Develop and implement a plan to complete reinvestigations that 

addresses both the backlog and reinvestigations coming due. 

Action Taken: The BIE entered into an agreement with the U.S. Department of the 

Interior’s Interior Business Center (IBC) Human Resources Directorate to complete overdue and 

future reinvestigations. The agreement’s period of performance was extended to September 30, 

2021, and specific support to be provided by the IBC includes but is not limited to: 

• Coordinating and processing background investigations for applicants, employees, and

contractors

• Adjudicating all background investigation results for suitability determination and issuing

national security clearances per BIE and OPM regulations and policies

• Coordinating directly with the BIE’s Human Resources Office to address unfavorable

adjudications and determinations or revoking national security clearances

• Consulting with the BIE on applying OPM or agency personnel security regulations,

policies, and procedures

In addition, a BIE official informed us that the bureau added a security officer supervisor

and doubled the number of security specialists (from four to eight) who work with the IBC on 

reinvestigations and will be capable of sustaining all new reinvestigations after the agreement

expires in September 2021. On the basis of supporting documentation provided by the BIE, we 

consider Recommendation 3 implemented and closed.

Recommendation 6: Develop and implement up-to-date procedures for the background 

check process.

Action Taken: The BIE worked with the IBC to update its policies on background 

investigations. Specifically, the BIE Human Resources Office updated its personnel security preemployment screening process to complete State and local background checks prior to entry-onduty and suitability determinations. In addition, during fiscal years (FYs) 2018 and 2019, the 

BIE Personnel Security Office met with security specialists and other BIE and IBC stakeholders 

to incorporate changes and additions to processes and procedures. Therefore, we consider 

Recommendation 6 implemented and closed. 

Recommendation 7: Ensure that schools are provided with consistent access to current 

procedures, as well as other tools and forms applicable to the background check process. 
4

Action Taken: The BIE engaged in outreach and training for schools on background 

investigation procedures and tools in December 2018. The IBC also provided school security 

points of contact (POCs) with additional guidance on required childcare background checks and 

answers to frequently asked questions in April 2019. In addition, the BIE created a new Security 

Officer Admin Repository SharePoint site, which includes school security POC updates and 

materials provided during 2019 and 2020 trainings. On the basis of our review of the supporting 

documentation provided, we consider Recommendation 7 implemented and closed. 

Recommendation 8: Develop and implement standardized background check training 

for the schools to be received on a periodic basis. 

Action Taken: In FY 2019, the BIE conducted annual training for assigned security 

staff. Specifically, from February 25 to 28, 2019, the BIE provided two daily training sessions on 

the School Point of Contacts and Affiliate Workforce Tracking System. According to training 

materials we obtained from the BIE, these trainings provided instruction for school security 

POCs on personnel security processes, use of the tracking system, and onboarding. The IBC’s

Personnel Security Services and the BIE’s Personnel Security office partnered to provide this 

information to schools. 

In addition, a BIE official stated that the BIE Personnel Security office provided inperson training for all school security POCs at the Southwest Indian Polytechnic Institute in

March 2020. According to its Security Officer Admin Repository SharePoint site, the BIE also 

provided web-based trainings for its staff in 2019 and 2020, including a Personnel Security 

Training Seminar from July 14 to 16, 2020. The BIE also used the SharePoint site to provide 

school security POCs with announcements, updates, and historical training materials. On the 

basis of our review of this information, we consider Recommendation 8 implemented and closed. 

Conclusion 

We concluded that Recommendations 1 – 3 and 6 – 8 are implemented. We informed BIE 

officials of the results of this review on August 18, 2020. 

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

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

cc: Tara Sweeney, Assistant Secretary–Indian Affairs

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

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

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

Management 

Alexis Vann, Audit Liaison, Office of Financial Management

Spike Bighorn, Audit Liaison, Bureau of Indian Education 
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