Indian Energy Development: Interior Could Do More to Improve Its Process for Approving Revenue-Sharing Agreements
Published: 2016-06-13T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The development of Indian-owned oil and gas resources is one of the largest revenue generators in Indian country, and individual Indian mineral owners may rely on royalty payments from such development to pay for living expenses. Various offices within Interior are responsible for management and oversight of oil and gas development on Indian lands. In some cases, Indian-owned resources cannot be developed independently. In those cases, BLM reviews a revenue-sharing agreement known as a CA, and BIA approves it. Prior GAO reports identified an extensive backlog of Indian CAs awaiting review and approval, leading to significant delays in the payments of royalties to Indian mineral owners.
GAO was asked to review Interior's review and approval process for Indian CAs. This report examines Interior's recent guidance intended to streamline the review and approval process for Indian CAs and the effect this guidance may have on the timeliness of the process. GAO analyzed agency procedures and guidance and interviewed Interior officials responsible for managing the CA review and approval process.
section_title: What GAO Found
paragraphs: The Department of the Interior (Interior) recently issued guidance intended to streamline the review process and reduce the approval times of oil and gas revenue-sharing agreements—called a communitization agreement (CA)—that include Indian resources. Under the revised guidance, for example, oil and gas operators are to provide simplified, less detailed information in their CA applications. In addition, the revised guidance eliminates some duplication in the Bureau of Indian Affairs' (BIA) and the Bureau of Land Management's (BLM) review processes.
It is too early to determine the effect the revised guidance will have on the CA process, but Interior will be limited in its ability to assess the results of its actions for three reasons:
Interior has established few time frames for the BIA and BLM offices that perform key tasks during the review and approval process. None of these time frames apply to BIA, which is ultimately responsible for approving an Indian CA. Standards for Internal Control in the Federal Government states that management should define objectives to include, among other things, time frames for achievement. Without time frames, BIA will be limited in its ability to hold offices accountable to ensure a more timely review process.
BIA has no systematic way to track an Indian CA through the review process. A 2014 interagency plan to improve the federal permitting review process stated that the ability to track review times is a best practice to improve the federal review process. Without a systematic tracking mechanism, BIA will be unable to fulfill its monitoring role to ensure that documents move through the review process expeditiously.
Interior's revised guidance does not include a plan to evaluate whether its efforts to streamline the process result in the more timely review of Indian CAs, and BIA officials told GAO that they have no plans for such an assessment. Standards for Internal Control in the Federal Government states that management should compare actual performance to expected results and analyze significant differences. Without conducting such an assessment, Interior will not know if the revised guidance has resulted in the more timely payments of royalties to Indian mineral owners.
section_title: What GAO Recommends
paragraphs: GAO recommends that Interior establish required time frames for the review and approval of Indian CAs, develop a systematic mechanism to track these CAs through the review process, and assess its actions to improve the timeliness of the process. Interior concurred with GAO's recommendations and described the actions it plans to take in response.

section_title: Letter
paragraphs: In fiscal year 2015, the development of Indian-owned oil and gas  resources generated more than $1 billion in revenue for tribes and  individual Indian mineral owners, according to the Department of the  Interior (Interior), making oil and gas resources one of the largest revenue  generators in Indian country. For some tribes, energy development is the  foundation of their economy and the primary source of funding for  education, infrastructure, and other public services. In addition, according  to a report by Interior, individual Indian oil and gas resource owners may  rely on revenue from oil and gas development to pay for living expenses,  such as food, shelter, health care, and education.
The development of Indian oil and gas resources is governed by a  number of federal laws, such as the Indian Mineral Leasing Act. Several  bureaus and offices within Interior—including the Bureau of Indian Affairs  (BIA), Bureau of Land Management (BLM), and Office of Natural  Resources Revenue (ONRR)—have responsibility for implementation of  these laws and the oversight and management of Indian oil and gas  development. One of the functions that BIA and BLM perform under  these laws and regulations is to review and approve revenue-sharing  agreements—called a communitization agreement (CA)—that include  Indian resources. To promote conservation and efficient utilization of  minerals, Interior approves CAs when an Indian lease cannot be  independently developed and operated in conformity with established well  spacing rules. In these cases, leases are consolidated to form a single  spacing unit, and a CA is established to identify production allocation for  the purpose of distributing revenue from oil and gas development in the  form of royalties based on each mineral owner’s percentage of ownership  in that unit. Without an approved CA, royalties cannot be distributed to  individual Indian mineral owners.
In recent years, advances in hydraulic fracturing and horizontal drilling,  along with favorable economic conditions, resulted in significant increases  in oil and gas development from shale formations, according to Interior  and the Department of Energy’s Energy Information Administration.  Although prices for crude oil and natural gas have since declined, the  leasing of Indian oil and gas resources continues in some areas of the  country, as evidenced by ongoing lease sales held by BIA agency  offices. According to a report by Interior, BIA has struggled to keep up  with the demand for oil and gas leasing, permitting, and drilling. The  number of CA applications submitted has surpassed BIA’s and BLM’s  ability to review and approve them in some areas of the country, such as  North Dakota and Oklahoma, causing a severe backlog of work and  preventing the timely distribution of oil and gas royalties to Indian mineral  owners. For example, one oil and gas operator told us that during the  boom period they held almost $7 million in oil and gas royalties in an  escrow account for Indian mineral owners because BIA and BLM delays  in processing the CAs prevented ONRR from accepting payments from  operators for the distribution of royalties to Indian mineral owners.
BIA has noted that the circumstances that led to the backlog of energy- related leases and permits are beginning to occur in other states where  Indian resources are being developed, such as Utah, New Mexico, and  Montana. Interior officials have also noted that the current downturn in oil  and gas leasing provides an opportunity to review the regulatory delays  facing operators when attempting to lease and drill on Indian lands and  streamline the process to encourage future development.
Our past reports have highlighted the importance of Interior’s role in the  management and oversight of federal and Indian energy resources and  identified some challenges with the current system. In a May 2014 report,  we found that BLM was not able to review CAs within required time  frames, creating delays in the payment of royalties to the federal  government, tribes, and individual Indian mineral owners. In that report,  we recommended that Interior identify and take necessary steps to  ensure that CAs are reviewed within required time frames, and Interior  generally agreed with our recommendation. In addition, in a June 2015  report, we found that BIA could not ensure that its review process for  energy-related documents was transparent or that such documents were  moving forward in a timely manner. In that report, we recommended that  Interior improve its review process by developing a documented process  to track its review and response times. Interior did not fully concur with  our recommendation, but stated in a letter to us in August 2015 that BIA  would try to implement a tracking and monitoring effort within its system  of records for oil and gas leasing documents.
In this context, you asked us to examine Interior’s review and approval  process for CAs that include Indian leases. This report examines the  actions Interior has taken to improve the timeliness of its review and  approval of Indian CAs and the results of these actions.
For this review, we examined Interior’s internal policies and guidance  pertaining to the review and approval of Indian CAs, including BLM’s  Instructional Memorandum, issued on July 17, 2015, and BIA’s National  Policy Memorandum, issued on August 27, 2015, describing plans for a  more streamlined process. Because these memorandums were issued  less than a year ago, it is too soon to compare Indian CAs reviewed  under the revised process with those reviewed under the former process.  We also examined laws and regulations that pertain to Interior’s role in  the review and approval of Indian CAs. We interviewed BIA, BLM, ONRR,  and other Interior officials at the headquarters and field levels who were  familiar with the former CA review and approval process, as well as the  proposed changes to this process. We selected officials from BIA and  BLM field offices from various areas of the country that experienced a  surge in oil development, which could result in an increase in demand for  the review and approval of CAs. Because this was a nonprobability  sample, their responses are not generalizable to all BIA and BLM offices  but provide examples of instances where offices did not review and  approve an Indian CA in a timely manner and the actions, if any, these  offices took to resolve the problems.
We conducted this performance audit from June 2015 to June 2016 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: Development of Indian energy resources is a complex process that may  involve a range of stakeholders, including federal agencies, state  agencies, tribal governments, individual Indian mineral owners, and  private oil and gas operators. When an operator seeks to develop land  that includes Indian resources, the operator must identify ownership of  surface and subsurface resources and acquire a lease for the right to drill  for oil and gas resources, among other things. BIA maintains these  surface and mineral ownership records, including lease information.  There are several ways in which Indian oil and gas resources can be  leased. For example, oil and gas resources can be nominated for lease  by operators, the tribe, or an individual Indian mineral owner. BIA then  reviews nominated oil and gas resources to determine ownership, and in  some cases, BLM may assist with identifying ownership of the proposed  parcels. If the resources are not already leased, BIA may advertise and  conduct competitive lease sales where operators can bid on nominated  leases. BIA reviews the bids, identifies the highest bidder, notifies the  operator whether its bid was accepted, and issues the lease.
An Indian lease document comprises a primary term and a secondary  term, both of which are negotiated as part of the lease agreement. The  primary term is the time frame in which the company has to begin drilling  or the lease will expire. The length of this term varies, but it usually  ranges from 2 to 10 years for Indian leases, according to Interior officials.  The secondary term is established after production begins and remains in  effect as long as the well is producing in paying quantities. The lease also  consists of three payment types between the operator and the tribe or  Indian mineral owner: (1) a onetime bonus payment paid per acre  following lease approval, (2) an annual rental payment for the leased  land, and (3) ongoing royalty payments for development of the resource.
If an Indian lease cannot be independently developed in conformity with  well spacing requirements set by the state and BLM, the operator  developing an area including Indian mineral interest must request  approval of a CA from BIA. Production from a well located within the CA  is attributed to the entire area—meaning that all owners share a  percentage of the royalties based on their percentage of surface  ownership, regardless of where the well is located. According to BIA’s  Fluid Mineral Estate Procedural Handbook, communitization serves a  conservation function by eliminating excessive drilling and minimizing  surface disturbance, while protecting adjoining properties from drainage  of their minerals. Figure 1 illustrates a hypothetical example in which  three leases are included in an approved CA. The example shows how  royalties are allocated among each lessor.
A CA must be approved before operators can distribute royalty payments  for Indian leases to the appropriate mineral owners. BIA, through several  divisions and its various regional and agency offices, has primary  authority for managing Indian energy development and has ultimate  approval authority for Indian CAs. BIA may approve a CA if it determines  that approval “is advisable and in the best interest of the Indian mineral  owner”. However, other offices within Interior also have a role in the  development and accounting of Indian energy resources in regard to CAs.  For example, BLM reviews a CA application and recommends to BIA  whether to approve an Indian CA based on the engineering and technical  aspects. Operators send royalty payments from the production of Indian  mineral leases to ONRR. Once the CA is approved by BIA and production  has been established, payments are made to ONRR, unless otherwise  provided for by the lease. ONRR transfers royalty payments to the  appropriate Indian accounts, and the Office of the Special Trustee for  American Indians (OST) makes the royalty payments to Indian mineral  owners based on instructions from BIA. An approved CA is effective on  either the date of first production or the date the CA is approved,  whichever is earlier. Traditionally, Interior encouraged the operator to  submit an Indian CA before the well was drilled, but it was common for  operators to wait until the results of the well were known before  submitting the CA application, according to Interior officials.
In recent years, some offices within Interior have taken actions to address  the backlog of CAs in their regions. For example, we previously reported  that in North Dakota the BLM Dickinson field office, BIA Fort Berthold  agency office, and ONRR created a preliminary CA process in March  2011 to address the backlog of CAs in their region. According to Interior  officials, the preliminary CA process was used by some BIA and BLM  offices as an interim step to ensure the timely collection and distribution of  royalties while operators prepared the required documents for a complete  CA application. However, in early 2015 Interior’s Office of the Solicitor  instructed BIA and BLM to cease using this process. The Office of the  Solicitor determined that preliminary CAs were not legally binding  because documents used in the process were not formally reviewed,  approved, and signed by the Secretary of the Interior or the Secretary’s  designee.
In addition, Interior officials said that they signed a contract with Lockheed  Martin in October 2011 that included providing technical assistance and  additional staff to help expedite the processing and approval of CA  packages at the BIA Fort Berthold agency office. We previously reported  that some BIA offices did not have adequate staff resources or staff with  the skills needed to effectively evaluate energy-related documents,  including the large number of CAs. According to Interior officials, the  additional staff and technical resources that the Lockheed Martin contract  provided allowed the office to review and approve more CAs than it  otherwise could have. However, Interior officials told us that because the  contract is scheduled to end in September 2016, some of these functions  will subsequently be administered directly by Interior’s recently  established Indian Energy Service Center. As of March 2016, according  to Interior officials, the Service Center has some funding available for  fiscal year 2016 and is in the process of hiring a director, identifying  overall staffing needs, and defining its roles and responsibilities. We are  examining the roles and responsibilities of the Indian Energy Service  Center in a separate ongoing review.
section_title: Interior Has Taken Actions to Streamline the Review and Approval Process, but Three Weaknesses Will Effect Its Ability to Assess the Results of Its Actions
paragraphs: In the summer of 2015, BIA and BLM issued guidance in an effort to  streamline the CA review and approval process and address the backlog  of Indian CAs awaiting review and approval. The guidance seeks to  shorten the time required to review and approve a CA by, among other  things, reducing paperwork, eliminating duplicative reviews, and  expediting the review of key information early in the process. However,  Interior does not have plans to set time frames for CA reviews,  systematically collect data on review times, or assess the effect of its  revised guidance. As a result, Interior will be unable to determine whether  the resulting actions have had a positive effect on the CA review and  approval process.
subsections: section_title: BIA and BLM Issued Guidance Intended to Streamline the CA Review and Approval Process
paragraphs: In 2015, BIA and BLM worked collaboratively to develop guidance  intended to streamline the CA review and approval process and help  address the current backlog of Indian CAs awaiting approval. Specifically,  in July 2015, BLM issued guidance that called for the CA approval  process to be streamlined to ensure the more timely payment of royalties  to Indian mineral owners. Approximately one month later, BIA issued  corresponding guidance to ensure the timely review, adjudication, and  approval of Indian CAs.
The guidance for both BIA and BLM, which we refer to in this report as  the revised guidance, was developed through a collaboration between  BLM, BIA, ONRR, and OST senior officials who attend biannual meetings  of the Indian Energy and Minerals Steering Committee (IEMSC).  According to Interior officials, the revised guidance incorporates best  practices of individual offices and standardizes the CA review and  approval process to better ensure consistency of approval methods in  offices across the country. The guidance also helps to clarify and  delineate the responsibilities of BIA, BLM, and the operators.
Based on our review of Interior’s former and revised guidance and  supporting documents, the revised process includes approximately the  same number of steps as the former process. However, as shown in  figure 2, the revised process includes various steps designed to reduce  paperwork, eliminate duplicative reviews, and expedite the review of key  information early in the process, which, according to the guidance, should  dramatically reduce CA adjudication and processing times.
Specifically, Interior took the following actions in an effort to streamline  the CA process:
Reducing paperwork: The new guidance reduces and simplifies the  information required to be submitted to BIA and BLM as part of a the  CA package by, among other things, allowing operators to combine all  nonfederal and non-Indian ownership interests, such as private and  state interests, into a single entry representing total acreage. As a  result, information such as the individual lease date, lease term, and  lessor is no longer required by BIA and BLM. According to the revised  guidance, BLM now verifies the total acreage and land description of  the proposed CA. One operator told us that this change will  significantly reduce the amount of paperwork submitted to BIA and  BLM for review. For example, according to the operator, BIA and BLM  used to review CAs with attachments numbering approximately 400  pages of lease information, often in hardcopy; in contrast, the  attachments may now be as few as 10 pages of lease information. In  addition, the revised guidance states that BIA and BLM should  already have the necessary information for Indian and federal leases.  According to officials, BIA and BLM used to verify the signatures of all  interest owners that were party to the CA but did not have the staff to  accomplish this task in a timely manner. The revised guidance allows  operators to self-certify that they have collected the necessary  signatures, including signatures from private and state interests,  which, according to officials, further decreases the amount of  information federal officials are responsible for reviewing and places  the burden on operators to collect such information. The reduction in  paperwork submitted is expected to reduce the workload for both BIA  and BLM offices.
Eliminating duplicative reviews: According to several BLM officials,  BLM’s technical review of an Indian CA traditionally involved the  adjudication of federal, Indian, state and private interests, which  required the individual verification of acreage, ownership, and  operating rights, resulting in lengthy reviews of the CA package. After  BLM’s technical review, according to officials, BIA would adjudicate  ownership of the same Indian leases, duplicating BLM’s efforts and  the review time. However, under the revised process, BIA is to  adjudicate only Indian interests and BLM is to adjudicate only federal  interests within the proposed CA. The revised guidance places  responsibility for adjudication with the agency that has the expertise to  verify the necessary information. For example, the new guidance  makes BIA responsible for information it currently maintains and is  independently knowledgeable of, such as lease records for Indian  interests. While it is too soon to determine the extent to which  reducing duplication of effort will reduce the time needed to review  and approve Indian CAs, the new guidance appears to more clearly  define the separate roles of BIA, BLM, and the operators in the CA  process.
Expediting the review: Several BIA and BLM officials noted that  under the former process, operators often submitted proposed CAs in  an incomplete form or to the wrong office, which ultimately led to  review and approval delays. Under the revised process, operators  must submit the proposed CA directly to the BIA Regional Director or  Superintendent of the Agency with jurisdiction over the lands included  in the CA. BIA has noted that an operator’s failure to file an Indian CA  with the appropriate BIA office puts the company at risk of not  complying with regulation and not having an approved CA in place  before expiration of the Indian lease(s). In addition, according to the  revised guidance, BIA is now tasked with performing a “quick review”  early in the process to determine if there are problems with the  information provided by the operator that could ultimately delay CA  approval. The revised guidance notes that BIA will take the lead in  documenting potential errors in the proposed package, such as  potential acreage errors that could affect royalty payments, and if  necessary, will quickly notify BLM and the operator. The guidance  also notes that this is an important step considering the length of time  it takes for CAs to be adjudicated and recommended for approval.  Again, it is too soon to determine the extent to which the earlier  submission of a complete CA by the operator to the appropriate BIA  office may help ensure the timely review of an Indian CA and  ultimately the more timely payment of royalties to Indian mineral  owners.
The revised guidance also includes BIA’s and BLM’s new goals for  streamlining the CA review process. BIA’s guidance states that its goal is  to address, devise, and implement a solution when there are problems  with a CA before the well is completed and any royalty payments are  made. Similarly, BLM’s guidance states that its goal is to have an  approved CA in place before the date of first production in order to allow  the operator to pay royalties to the mineral owner from the start of  production. According to Interior officials, under the former process, CAs  were sometimes approved years after production began, leading to  accounting challenges to recoup and distribute royalties to Indian mineral  owners at a later date. It is Interior’s goal, as noted in the revised  guidance, to identify and address any problems that may exist with an  Indian CA early in the review process to help ensure the more timely  approval of the CA, ideally before oil and gas development begins.
section_title: Interior Will Not Be Able to Fully Assess the Results of Its Recent Actions to Streamline the CA Process without Required Time Frames and a Systematic Tracking Mechanism
paragraphs: BIA and BLM developed the revised guidance with the intent to expedite  the review and approval of CAs and ensure the more timely payment of  royalties to Indian mineral owners, but Interior has established few time  frames for the BIA and BLM offices that perform tasks during the review  and approval process and BIA has no mechanism in place to track Indian  CAs. In addition, the revised guidance does not include plans to assess  whether its efforts to streamline the CA review and approval process  result in the more timely review of Indian CAs.
Standards for Internal Control in the Federal Government states that  management should define objectives to include what is to be achieved,  who is to achieve it, how it will be achieved, and the time frames for  achievement. However, no statute, regulation, or internal procedures  specify a time frame by which BIA, as the approving office for an Indian  CA, is required to review or approve an Indian CA. In contrast, according  to statute, BLM is to review CAs and issue determinations of allocation  within 120 days of a request. Interior’s standard operating procedures  that govern energy development of federal and Indian resources note that  BLM is to review and recommend whether to approve an Indian CA within  30 days of BIA’s request; again, these procedures do not include a time  frame for BIA’s role in the review and approval of an Indian CA. Many  Interior officials we spoke with stated that some BLM offices treat the 30- day time frame as a suggestion rather than a requirement and said that  offices within their regions rarely meet the time frame because of  overwhelming workloads and staffing shortages, which is consistent with  the findings in our May 2014 report. Senior BIA officials told us that  establishing time frames for BIA could help ensure a more transparent  and efficient Indian CA review and approval process. Without required  time frames, Interior is limited in its ability to ensure that BIA and BLM  reviews of Indian CAs help the agency meet its objective to provide for a  more timely CA review and approval process.
In addition, according to the revised guidance, it is BIA’s responsibility to  monitor the review and approval times for Indian CAs; however, BIA  currently has no systematic mechanism in place to track an Indian CA  through the review and approval process and the revised guidance did  not establish such a mechanism. BIA officials in some field offices told us  that they maintain an informal tracking document, typically a spreadsheet,  to track the CAs their office is reviewing; however, this document is  usually not accessible by officials outside their field office, including  coordinating agency officials and headquarters staff. An interagency plan  created in May 2014 in response to Executive Order 13604 notes that the  ability to track and monitor the review of permits and applications is a best  practice to improve the federal review process. In our June 2015 report,  we found that BIA did not have a process to track its review and response  times for energy-related documents, including CAs. In our report, we  recommended that, to improve the efficiency and transparency of its  review process, BIA should develop a documented process to track its  review and response times. Interior did not fully concur with our  recommendation, but in an August 2015 letter to us noted that BIA  intends to enhance its national database—the Trust Asset and  Accounting Management System (TAAMS)—by improving the tracking  and monitoring of oil and gas leasing documents by the end of fiscal year  2017. According to officials, BIA does not currently enter CAs into TAAMS  until after the CAs are approved because the system is not used to track  oil and gas documents through the review process. BIA officials told us  that a subject matter expert group was formed in July 2015 to evaluate  the need for system updates to TAAMS, but that the group has no  specific plans to include recommendations associated with the tracking of  Indian CAs. The revised guidance does not explain how BIA will monitor  the review and approval times of Indian CAs without information on the  length of time BIA and BLM offices are taking to review and approve  these CAs. Without a systematic tracking mechanism to collect  information that is accessible by coordinating officials and headquarters  staff, Interior will be unable to fulfill its objective to ensure that Indian CAs  are being reviewed and approved in a timely manner.
In addition, although the revised guidance states that the proposed  actions should “dramatically reduce” adjudication and processing times to  ensure the more timely review and approval of CAs, it does not include a  plan to assess the process to determine if Interior has met this policy  objective. A senior BIA official confirmed that the agency has no plans to  track the results and assess the time-saving elements included in the  revised CA process. Instead, according to this official, BIA’s current focus  is to work through the existing backlog of Indian CAs and complete the  review and approval of these applications. However, Standards for  Internal Controls in the Federal Government states that management  should compare actual performance to expected results and analyze  significant differences. Without a plan to assess the effect of its revised  guidance on the Indian CA review and approval process, Interior will not  be able to compare actual performance against the objective of a more  timely process, which may also prevent it from identifying further  improvements, if needed, to the process in the future.
section_title: Conclusions
paragraphs: BIA and BLM issued revised guidance in an effort to streamline the  review and approval process for Indian CAs. However, a number of  factors will limit BIA’s ability to ensure that the resulting actions have had  a positive effect on the process and lead to the more timely review and  approval of Indian CAs. Specifically, as Interior has not established  required time frames by which an Indian CA should be reviewed and  approved, BIA will be limited in its ability to hold offices accountable to  ensure that Indian CAs are reviewed and approved in a timely manner. In  addition, because BIA does not have a systematic mechanism to track an  Indian CA through the process, it will be unable to fulfill its monitoring role  to ensure that CAs are reviewed and approved in a timely manner.  Finally, because Interior does not have a plan to assess the results of its  revised guidance on the Indian CA process, the agency will be unable to  determine whether it has achieved its policy objectives, such as  decreasing the time needed to review and approve Indian CAs, designed  to result in the more timely disbursement of royalties to Indian mineral  owners. Without the ability to assess the effect of its revised guidance on  the Indian CA review and approval process, Interior may not have enough  information to make further improvements, if needed, to the process.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Secretary of the Interior direct the Director of the  Bureau of Indian Affairs and, as appropriate, the Director of the Bureau of  Land Management to take the following three actions:
Establish required time frames for the review and approval of Indian  CAs to ensure a more timely CA process.
Develop a systematic mechanism for tracking Indian CAs through the  review and approval process to determine, among other things,  whether the revised CA process meets newly established time  frames.
Assess whether the revised CA process is achieving its objective to  improve the timeliness of the review and approval of Indian CAs, and  if not, make changes as appropriate.
section_title: Agency Comments
paragraphs: We provided Interior with a draft of this report for review and comment. In  its written comments, reproduced in appendix I, Interior concurred with  our recommendations. In response to our recommendation about  establishing required time frames for the review and approval of Indian  CAs, Interior stated that BIA will issue a National Policy Memorandum  that establishes such time frames. In response to our recommendation  about developing a systematic mechanism for tracking Indian CAs,  Interior stated that BIA will develop such a mechanism in TAAMS, and  until that modification is made, BIA and BLM will use a centralized  tracking spreadsheet. Finally, in response to our recommendation about  assessing the revised CA process, Interior stated that both BIA and BLM  will use the tracking spreadsheet, and, upon completion, the enhanced  TAAMS, to monitor and assess the results of the efforts to streamline the  process, and establish a process for review of the collected data to  identify and implement any necessary process modifications.
As agreed upon with your office, unless you publicly announce the  contents of this report earlier, we plan no further distribution until 30 days  from the report date. At that time, we will send copies to the appropriate  congressional committees, the Secretary of the Interior, and other  interested parties. In addition, the report will be available at no charge on  the GAO website at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or ruscof@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. Key contributors to this report are listed in  appendix II.
section_title: Appendix I: Comments from the Department of the Interior
section_title: Appendix II: GAO Contact and Staff Acknowledgements
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Christine Kehr (Assistant  Director), Patrick Bernard, Richard Burkard, Patricia Chen, Cindy Gilbert,  Alison O’Neill, Dan C. Royer, Jay Spaan, and Amy Ward-Meier made key  contributions to this report.