OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OFTHE INTERIOR 

The National Park Service Did Not 

Oversee Its General Agreements 

EVALUATION 

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 $222,000. 

Report No.: 2019-CR-035 September 2020 

This is a revised version of the report prepared for public release.
 

 

 

 

 

 

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Memorandum 

To: Margaret Everson 

Counselor to the Secretary, Exercising the Delegated Authority of the Director 

National Park Service 

From: Mark Lee Greenblatt 

Inspector General 

Subject: Final Evaluation Report – The National Park Service Did Not Oversee Its General 

Agreements 

Report No. 2019-CR-035 

This memorandum transmits our final evaluation report on the National Park Service’s 

(NPS’) oversight of its general agreements (GAs). We determined that the NPS did not oversee 

its GAs to ensure compliance with policies and governing laws. Specifically, we found the NPS 

was misusing GAs at all three parks we reviewed, which puts the NPS at risk of unauthorized 

commitments. 

We make five recommendations to help the NPS improve oversight of its GAs. Based on 

the NPS’ response to our draft report, we consider one recommendation unresolved, one 

recommendation resolved and implemented, and three recommendations resolved but not 

implemented. We will refer the recommendations to the Assistant Secretary for Policy, 

Management and Budget for resolution and to track implementation. 

If you have any questions regarding this memorandum or the subject report, please 

contact me at 202-208-5745. 

The legislation creating the Office of Inspector General requires that we report to 

Congress semiannually on all audit, inspection, and evaluation reports issued; actions taken to 

implement our recommendations; and recommendations that have not been implemented. 

Office of Inspector General | Washington, DC 
 

 

Table of Contents 

Results in Brief ................................................................................................................................1 

Introduction......................................................................................................................................2 

Objective ......................................................................................................................................2 

Background ..................................................................................................................................2 

Findings............................................................................................................................................3 

The NPS Did Not Maintain a GA Inventory or Use a Standard Review Process........................3 

Parks Incorrectly Used GAs to Commit Resources .....................................................................4 

Conclusion and Recommendations..................................................................................................7 

Conclusion....................................................................................................................................7 

Recommendations Summary........................................................................................................7 

Appendix 1: Scope and Methodology............................................................................................10 

Scope ..........................................................................................................................................10 

Methodology ..............................................................................................................................10 

Appendix 2: Bureau Response.......................................................................................................12 

Appendix 3: NPS Signatory Memorandum ...................................................................................16 

Appendix 4: Status of Recommendations......................................................................................18 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Results in Brief 

We evaluated the National Park Service’s (NPS’) general agreements (GAs) to determine if the 

NPS oversees its GAs to ensure compliance with policies and governing laws. 

The NPS describes a GA as a nonbinding written agreement used to document a wide range of 

policies, procedures, objectives, understandings, or relationships among Federal and non-Federal 

entities. Policies and laws prohibit these agreements from committing the NPS to providing 

financial assistance in any form or transferring NPS goods or services to Federal and non-Federal 

entities. 

We found that the NPS did not oversee its GAs to ensure compliance with policies and 

governing laws. We initially requested national information on the NPS’ GAs. The NPS, 

however, was unable to provide that information. We found that the NPS was unaware of the 

number of active GAs because it did not maintain a central inventory for its GAs. We then 

requested the same information from the NPS Intermountain Region, which was also unable to 

provide it. We found the NPS administered and tracked its GAs at only the program level within 

each national park. Therefore, we selected three parks to review in the Intermountain Region: 

Yellowstone, Grand Teton, and Rocky Mountain. 

We found the NPS was misusing GAs at all three parks we reviewed, which is likely a result of 

the informal review process associated with these instruments. During our evaluation, we 

determined that the NPS used the GAs to provide financial assistance or transfer goods or 

services to non-Federal entities, in apparent contravention of policies and laws. Further, we noted 

that personnel who were not authorized to commit NPS resources signed the GAs that 

inappropriately transferred something of value, which puts the NPS at risk of unauthorized 

commitments. The NPS has neither provided clear, consistent guidance, nor provided training on 

how to develop and use GAs at the national level. 

We make five recommendations to help the NPS improve oversight of its GAs. The NPS 

responded to all five recommendations in its response to our draft report. Based on the NPS’ 

response, we consider one recommendation unresolved, one recommendation resolved and 

implemented, and three recommendations resolved but not implemented. We will refer the 

recommendations to the Assistant Secretary for Policy, Management and Budget for resolution 

and to track implementation. 

1 
 

 

 

 

 

 

 

 

 

Introduction 

Objective 

Our objective was to determine if the NPS oversees general agreements to ensure compliance 

with policies and governing laws. 

Appendix 1 contains the scope and methodology for this evaluation. 

Background 

The NPS establishes relationships with multiple nonprofits, partners, stakeholders, and Federal 

agencies through a variety of legal instruments. Each legal instrument comes with its own set of 

policies and governing laws. In 2003, the NPS started using the term general agreement (GA) to 

replace memoranda of understanding (MOUs) or agreement (MOAs) in Director’s Order #20 

(DO 20) in an attempt to reduce the confusion in selecting legal instruments at the suggestion of 

the U.S. Department of the Interior’s (DOI’s) Office of the Solicitor. According to DO 20, a GA 

is a generic instrument used to document a wide range of policies, procedures, objectives, 

understandings, or relationships among Federal and non-Federal entities. DO 20 prohibits the 

NPS from using a GA to provide financial assistance in any form or transfer NPS goods or 

services to Federal and non-Federal entities. The NPS can use other legal instruments to procure 

or transfer goods or services, such as a procurement contract1 or grant or cooperative 

agreement.

2 

1 A procurement contract, which must adhere to the Federal Acquisition Regulation, reflects the legal relationship the NPS has 

with another entity when the principal purpose is to acquire property, goods, or services that directly benefit the NPS. 2 A grant or cooperative agreement is a financial assistance agreement that can be used to transfer something of value from the 

NPS to a recipient to carry out a public purpose (see Section 31 U.S.C. Chapter 63). 

2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Findings 

During our evaluation, we found that the NPS did not oversee its GAs to ensure compliance with 

policies and governing laws. Specifically, we found the NPS did not maintain an inventory of the 

total active GAs, the NPS did not use a standard review process for its GAs, parks incorrectly 

used GAs to commit NPS resources, and the NPS did not provide training or consistent guidance 

on how to develop and use GAs. As a result, the NPS is at risk for unauthorized commitments. 

The NPS Did Not Maintain a GA Inventory or Use a 

Standard Review Process 

During our evaluation, we found that the NPS did not know how many active GAs it had in place 

across the Nation. In our initial data request, we asked for a universe of all active NPS GAs, 

including active MOUs and MOAs. The NPS notified us that it did not have a central inventory 

for the GAs at the Washington Area Support Office or the individual park level. Through 

discussions with NPS Intermountain Region (IMR) Major Acquisition Buying Office and 

Financial Assistance personnel, we learned that the IMR also did not track the GAs. Rather, the 

NPS administered the GAs at the program level within each park. As a result, we directly asked 

three IMR parks—Yellowstone, Grand Teton, and Rocky Mountain—for a list of their GAs. 

While none of the three IMR parks we sampled had a list of active GAs readily available, each 

park produced one in a timely manner over the course of our evaluation. 

In addition, we found that NPS officials did not consistently review the GAs beyond the 

authorizing park prior to implementation. Park officials noted that while they occasionally asked 

the Office of the Solicitor or IMR personnel for help when developing agreements, they primarily 

used previously developed GAs as a template when drafting new or updated GAs. Because the 

GAs are intended for nonbinding agreements, the NPS does not require any official to review 

them at a higher level than the park itself. In contrast, the NPS requires tracking and review at the 

regional or national level for other legal instruments, such as financial assistance agreements or 

contracts, due to the inherent commitment of NPS resources. 

Because the NPS does not track its active GAs, nor require higher level review, the parks may 

incorrectly use GAs in place of financial assistance agreements or contracts. In our review, we 

identified GAs that committed NPS resources, similar to a financial assistance agreement or 

contract, that did not go through a review process at the regional or national level. Additional 

oversight would help ensure that the NPS is appropriately and consistently using the GAs for their 

intended purpose in accordance with applicable policies and governing laws. 

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Recommendations 

We recommend that the NPS: 

1. Develop a process to track all nonfinancial assistance agreements, such as the 

GAs, so they can be easily monitored, reviewed, and updated, as necessary 

2. Implement a higher level review process for all future GAs to ensure parks use 

the correct legal instrument 

Parks Incorrectly Used GAs to Commit Resources 

We found that the NPS used five GAs at three different parks to provide financial assistance or 

transfer goods or services to a non-Federal entity, in contravention of DO 20 (see Figure 1). For 

example, a multiyear GA at Rocky Mountain National Park committed the NPS to reimburse a 

non-Federal entity $10,932 in 2018 for maintenance and custodial services at a visitor center. 

Likewise, GAs at Yellowstone National Park and Grand Teton National Park provided NPS 

property to non-Federal entities free of charge. Other GAs at the parks committed funds for 

services or supply reimbursements. 

Figure 1: GAs Identified at Yellowstone, Grand Teton, and 

Rocky Mountain National Parks 

GAs 

Committing 

National Park GAs Resources NPS Commitments 

Rocky 

Mountain 40 3 • Payments for services • Park passes for resale 

Grand Teton 10 1 • Free rent 

Yellowstone 10 1 • Free rent 

• Supply reimbursements 

Total 60 5 

In addition, for all five of these GAs, NPS employees who signed the agreements were not 

warranted contracting officers or appointed agreements officers. For instance, a park program 

head and a superintendent signed the GAs that committed funds for services and supplies at 

Rocky Mountain National Park and Yellowstone National Park, respectively. According to 

regulations,3 DOI policy,4 and the NPS’ Financial Assistance Handbook, only NPS contracting 

officers or agreements officers may enter into legally binding agreements that transfer anything 

of value on behalf of the NPS. 

3 FAR § 4.101 states that only contracting officers shall sign contracts on behalf of the United States. 4 The DOI’s Financial Assistance Certification and Certificate of Appointment Programs Policy states that only financial 

assistance experts with training and certification can sign financial assistance awards. 

4 
 

 

 

 

 

 

 

 

 

 

 

 

 

We also found the NPS did not provide clear or consistent guidance on how to develop and use a 

GA. DO 20, which has not been revised since its inception in July 2003, states that the NPS 

would develop an agreements handbook to provide further guidance on the GAs. We learned that 

the NPS developed chapters on agreements; however, the draft guidance conflicted with DO 20, 

and the NPS never formally published it. For example, a 2006 version of Chapter 7 titled 

“Agreements” defines an MOU as a GA while defining an MOA as an instrument to accept 

donations. In contrast, DO 20 clearly states that the GAs would replace both the MOUs and the 

MOAs and does not draw a distinction between the two. In 2014, the NPS initiated an 

Agreements Improvement Plan to clarify agreement types and uses. The NPS published a 

Financial Assistance Handbook in 2015 as part of the Agreements Improvement Plan, but never 

developed official guidance clarifying the use of the GAs. 

Additionally, the NPS used conflicting templates and agreement decision trees when developing 

its GAs (including MOUs and MOAs). For example, the decision tree on the NPS’ Office of 

Policy Agreements Portal shows that the NPS should use an MOU or an MOA to solidify 

agreements that do not transfer anything of value, while the decision tree located in the Financial 

Assistance Handbook refers to an MOA as a legal instrument that can be used to account for 

funding provided to the NPS. The decision trees we reviewed were not dated, which may add to 

the confusion of which decision trees to use. 

The absence of training for NPS staff on their roles and responsibilities surrounding the GAs 

further complicates this issue. During our evaluation, we did not identify any training related to 

the GAs at any level within the NPS. Further, NPS personnel identified as the point of contact 

for the GAs we reviewed told us they had not received training on the GAs. The employees also 

noted that training would be beneficial for both themselves and for any other personnel who 

develop and execute the GAs. 

Outdated and inconsistent guidance allowed parks to enter into agreements that did not comply 

with existing policies and governing laws. According to officials we interviewed, the NPS did 

not prioritize updating DO 20 and providing supplemental GA guidance because the GAs 

establish nonbinding partnerships and should not transfer anything of value. Incorrectly using a 

GA for financial assistance or to transfer goods and services increases the NPS’ risk of making 

unauthorized commitments. With consistent guidance and training on agreement types and 

purposes, each park would be better equipped to enter into agreements with outside entities using 

the correct legal instrument. 

5 
 

 

 

 

 

 

 

Recommendations 

We recommend that the NPS: 

3. Identify, review, and update the current GAs that commit the NPS to provide 

financial assistance or transfer goods or services to ensure the correct legal 

instrument is used 

4. Review and update existing GA policy and guidance (including templates, 

handbooks, and decision trees) to ensure consistency and clarification across 

the NPS 

5. Develop and deliver agreements training to all staff working with the GAs 

6 
 

 

 

 

 

 

 

 

 

 

 

Conclusion and Recommendations 

Conclusion 

During our evaluation, the NPS was unable to provide information on its GAs at the national 

level, so we selected three parks in the NPS Intermountain Region to review. We found that the 

NPS did not oversee its GAs to ensure compliance with policies and governing laws. 

Specifically, we found that the NPS did not have an inventory of active GAs or a standard review 

process to ensure that it uses its GAs for their intended purpose in accordance with applicable 

policies and governing laws. We also found that the NPS incorrectly used its GAs to transfer 

property, funds, goods, or services to its non-Federal partners. 

The NPS committed more than $20,000 of funding per year and provided free rent of NPS 

facilities through five agreements at the three parks we reviewed. Given that the NPS manages 

more than 400 national park sites, if additional sites use similar agreements, the NPS is at risk of 

significant unauthorized commitments across the Nation. 

Increased GA oversight, including a tracking and review process, would help the NPS ensure 

that parks follow financial agreement processes and do not use GAs for financial assistance or to 

transfer goods and services. With consistent guidance and training on agreement types and 

purposes, each park would be better equipped to enter into agreements with outside entities using 

the correct legal instrument. 

Recommendations Summary 

The NPS responded to our draft report on June 9, 2020, providing target dates and responsible 

officials for implementation (see Appendix 2 for the full NPS response). Prior to its response, the 

NPS issued a Memorandum, Regional Director Review and Signatory Authority on all General 

Agreements, dated February 26, 2020, requiring all GAs to be signed by the regional director or 

their regional office designee (see Appendix 3). Based on the memorandum and the NPS’ 

response, we consider one recommendation unresolved, one recommendation resolved and 

implemented, and three recommendations resolved but not implemented (see Appendix 4 for the 

status of recommendations). 

We recommend that the NPS: 

1. Develop a process to track all nonfinancial assistance agreements, such as the GAs, so 

they can be easily monitored, reviewed, and updated, as necessary 

NPS Response: The NPS stated that it does not intend to create a database or other 

system to track its GAs. The NPS stated that all regional offices have ready access to 

these agreements because of the newly implemented requirement that all regional 

directors or their designees must sign all GAs within their regions starting March 1, 2020. 

7 
 

 

 

The NPS said that this new process will ensure that it can track its GAs. The NPS also 

noted, however, this process may change as it implements other recommendations. 

OIG Comment: Based on the NPS’ response, we consider this recommendation 

unresolved. Even assuming that the signature requirement will promote better awareness, 

ensuring GAs are tracked at the regional level going forward does not address existing 

inventories of nonfinancial agreements, including GAs. Further, keeping an inventory of 

all existing and future nonfinancial assistance agreements will allow the NPS to easily 

search and maintain accountability of its GAs and will also ensure compliance with DO 

20. As the NPS implements the recommendations in this report, our staff is available to 

further discuss the benefits of tracking these agreements. We will refer this 

recommendation to the Assistant Secretary for Policy, Management and Budget (PMB) 

for resolution. 

2. Implement a higher level review process for all future GAs to ensure parks use the 

correct legal instrument 

NPS Response: As set forth in the February 26, 2020 memorandum, regional directors or 

their designees must sign all GAs starting March 1, 2020. 

OIG Comment: Based on the NPS’ response and our understanding that the person 

signing the GA has conducted a review of the document, we consider this 

recommendation resolved and implemented. 

3. Identify, review, and update the current GAs that commit the NPS to provide financial 

assistance or transfer goods or services to ensure the correct legal instrument is used 

NPS Response: The NPS agreed to identify, review, and resolve all DO 20 agreements 

with financial assistance commitments. 

OIG Comment: Based on the NPS’ response, we consider this recommendation resolved 

but not implemented. We will refer this recommendation to the PMB to track 

implementation. 

4. Review and update existing GA policy and guidance (including templates, handbooks, 

and decision trees) to ensure consistency and clarification across the NPS 

NPS Response: The NPS concurred with our recommendation and agreed to undertake a 

review of DO 20 and update appropriate policies and guidance. 

OIG Comment: Based on the NPS’ response, we consider this recommendation resolved 

but not implemented. We will refer this recommendation to the PMB to track 

implementation. 

8 
 

5. Develop and deliver agreements training to all staff working with the GAs 

NPS Response: The NPS concurred with our recommendation and agreed to develop 

training after it consults with the Office of the Solicitor and updates its GA guidance. 

OIG Comment: Based on the NPS’ response, we consider this recommendation resolved 

but not implemented. We will refer this recommendation to the PMB to track 

implementation. 

9 
 

 

Appendix 1: Scope and Methodology 

Scope 

We evaluated the National Park Service’s (NPS’) general agreements (GAs), as defined by 

Director’s Order #20, that were active as of May 16, 2019. During our evaluation, we could not 

determine the universe of active GAs because the NPS did not have a centralized inventory for 

its GAs—including its memoranda of understanding (MOUs) and memoranda of agreement 

(MOAs)—at the national, regional, or park levels. As a result, we directly obtained lists of GAs 

from three parks in the NPS Intermountain Region: Yellowstone, Grand Teton, and Rocky 

Mountain. 

Methodology 

We conducted our evaluation in accordance with the Quality Standards for Inspection and 

Evaluation as put forth by the Council of the Inspectors General on Integrity and Efficiency. We 

believe that the work performed provides a reasonable basis for our conclusions and 

recommendations. 

To accomplish the objective, we: 

• Reviewed the universe of the active GAs, MOUs, and MOAs from Rocky Mountain 

National Park (40), Grand Teton National Park (10), and Yellowstone National Park (10) 

• Identified and interviewed NPS staff at the park, regional, and national levels 

• Identified, analyzed, and documented policies and governing laws pertaining to the GAs, 

MOUs, and MOAs, including NPS websites 

• Identified and interviewed appropriate NPS staff associated with the selected sample of 

the GAs, MOUs, and MOAs 

• Identified, analyzed, and documented activities and services associated with a 

judgmentally selected sample of the GAs, MOUs, and MOAs 

• Reviewed documents related to oversight and monitoring processes, including Director’s 

Orders, policies, and procedures 

We visited the following NPS sites: 

• Rocky Mountain National Park, Estes Park, CO 

• Intermountain Regional Office, Lakewood, CO 

• Washington Support Office, Lakewood, CO 

10 
 

 

 

We also contacted or interviewed personnel from: 

• Yellowstone National Park 

• Grand Teton National Park 

• NPS Intermountain Region Contracting, Financial Assistance, Property and Requisition 

Program 

• U. S. Department of the Interior, Office of the Solicitor, Salt Lake City, UT 

• NPS Partnership and Civic Engagement Office, Washington, D.C. 

• NPS Office of Policy, Washington, D.C. 

• NPS Washington Contracting Office 

Our evaluation included obtaining an understanding of the administration and internal controls 

surrounding the GAs, testing and evaluating the design and operating effectiveness of internal 

controls, and performing such other procedures as we considered necessary under the 

circumstances. NPS park personnel provided the lists of the GAs, which we used but could not 

test for completeness and accuracy. 

11 
 

 

Appendix 2: Bureau Response 

The National Park Service’s response follows on page 13. 

12 
 

United States Department of the Interior 

NATIONAL PARK SERVICE 

1849 C Street, NW 

Washington, DC 20240 

Memorandum 

To: Office of Inspector General 

Digitally signed by From: Deputy Director, Operations RAYMOND RAYMOND VELA 

Date: 2020.06.08 Exercising the Authority of Director VELA 13:51:29 -04'00' 

Subject: National Park Service Response to Office of Inspector General Report entitled. The 

National Park Service Did Not Adequately Oversee Its General Agreements, Report 

No. 2019-CR-035 

The National Park Service (NPS) has reviewed the Office of Inspector General report entitled, The 

National Park Service Did Not Adequately Oversee Its General Agreements (Report No. 2019-CR035 dated April 2020). Thank you for the opportunity to respond to the referenced report. 

The NPS has reviewed the reference draft report. We take these matters seriously and are working 

to ensure that General Agreements comply with statutes and regulations and with applicable 

policies. 

Attached are the responses to the specific recommendations, including steps the NPS has taken or 

will be taking to address the concerns raised. 

If you should have any questions or need additional information, contact Vera 

Washington, NPS Audit Liaison Officer at 202-354-1960. 

Attachments 

13
National Park Service Response to Office of Inspector General Report entitled The National 

Park Service Did Not Adequately Oversee Its General Agreements, Report No. 2019-CR-035 

14

OIG Recommendation NPS Response Target Date Responsible Official 

Develop a process to 

track all nonfinancial 

assistance agreements, 

such as the GAs, so 

they can be easily 

monitored, reviewed, 

and updated, as 

necessary 

NPS will not create a 

database or other system to 

track these non-binding 

agreements. NPS currently 

requires all DO-20 GAs to be 

signed by the Regional 

Director or their designee. 

Under that process, all 

Regional Offices have ready 

access to these agreements. 

This process ensures GAs 

are tracked. NPS advises OIG 

Completed Shawn Benge, Acting 

Deputy Director for 

Operations 

that as they implement 

other recommendations, 

this process may change. 

Implement a higher 

level review process for 

all future GAs to ensure 

parks use the correct 

legal instrument 

NPS requires all DO-20 GAs 

to be signed by the Regional 

Director or their designee. 

Completed Shawn Benge, Acting 

Deputy Director for 

Operations 

Identify, review, and 

update the current GAs 

that commit the NPS to 

NPS will conduct a data call 

for DO-20 agreements that 

meet certain criteria 

May 1, 2021 Chief of Staff 

provide financial 

assistance or transfer 

indicating that financial 

assistance was committed 

goods or services to 

ensure the correct legal 

instrument is used 

or that transfers goods or 

services beyond what SOL 

deems allowable in a DO-20 

agreement. Those identified 

agreements will be 

reviewed and resolved. 

Review and update 

existing GA policy and 

guidance (including 

templates, handbooks, 

and decision trees) to 

ensure consistency and 

clarification across the 

The NPS concurs and 

intends to undertake a 

review of DO-20 to 

determine whether it 

should be rescinded, 

updated, or replaced. 

NPS will then create the 

August 1, 2022 Chief of Staff 

NPS appropriate policies and 

guidance. 

Develop and deliver 

agreements training to 

The NPS concurs and 

will consult with the 

Officer of the Solicitor 

Clarification 

memo regardi

GAs was sent 

ng 

to 

Chief of Staff 
 

 

 

 

all staff working with 

the GAs 

on appropriate use of 

GAs. NPS will then send 

a notice to all Regional 

Directors, 

Superintendents, and 

Administrative Officers 

clarifying what GAs 

cannot be used to 

commit to in terms of 

funding and transfer of 

goods and services. 

Once NPS has 

completed the review 

and update of our GA 

guidance, we will 

prepare a training on 

that guidance to reside 

on DOITalent and the 

NPS Common Learning 

Portal. 

RDs, 

Superintendents, 

and 

Administrative 

Officers on 

February 26, 

2020. Full training 

on new GA 

guidance will be 

operational within 

9 months of the 

finalization of our 

updated guidance. 

Tentatively May 1, 

2023. 

15
 

Appendix 3: NPS Signatory Memorandum 

The National Park Service’s February 26, 2020 Memorandum, Regional Director Review and 

Signatory Authority on all General Agreements, follows on page 17. 

16 
United States Department of the Interior 

NATIONALPARKSERVICE 

1849 C Street, N.W. 

Washington, DC 20240 

FEB 2 6 2020 Memorandum 

To: Regiona l Directors 

From: Deputy Director, Management and Administration 

Subject: Regional Director Review and Signat01-y Authority on all General Agreements 

The purpose of this memo is to update the signatory authority on all General Agreements, as 

defined under DO-20, and commonly referred to as Memorandum of Understanding (MOU) and 

Memorandum of Agreement (MOA). As of March 1, 2020, all General Agreements must be 

signed by the Regional Director, or their Regional Office designee. 

The Office of Inspector General is unde1taking a review of General Agreements and has 

provided NPS leadership with prel iminary findings that indicate a lack of clarity regarding their 

proper use. As a reminder, General Agreements must not commit the NPS to provide financial 

assistance in any form, 11or transfer NPS goods or services to Federal or non-Federal entities. By 

raising the signatory authority to the Regional Director's level, we wi ll be able to ensure that 

NPS complies with these restrictions and addresses O1G's preliminary findings. We also believe 

that this change will help us address the OIG concerns without overly bmdening the field. We 

are committed to taking a series of actions to ensure clarity and proper use of General 

Agreements and will continue to commw1icate on this topic. Please communicate this change to 

all parks and programs in your region. 

lf you have any questions, please contact Caitlin Rogalski at or 

@nps.gov. 

Thank you for your attention to this matter. 

17 
 

 

 

 

 

 

 

Appendix 4: Status of Recommendations 

Based on the National Park Service’s response to our draft report (see Appendix 2), we consider 

one recommendation unresolved, one recommendation resolved and implemented, and three 

recommendations resolved but not implemented. We will refer the recommendations to the 

Office of Policy, Management and Budget (PMB) for resolution and implementation tracking. 

Recommendation Status Action Required 

We will refer this 

1 Unresolved recommendation to the PMB for 

resolution. 

2 Resolved and implemented No action needed. 

We will refer these 

3 – 5 Resolved but not implemented recommendations to the PMB to 

track their implementation. 

18 
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