Bureau of Land Management: Improper Charges Made to Mining Law Administration Program
Published: 2001-03-08T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Bureau of Land Management's (BLM) Mining Law Administration Program (MLAP) is responsible for managing the environmentally responsible exploration and development of locatable minerals on public lands. The program is funded through mining fees collected from the holders of unpatented mining claims and sites and by appropriations to the extent that fees are inadequate to fund the program. Congress and program managers need accurate cost information in order to make informed program and budgeting decisions.
section_title: What GAO Found
paragraphs: However, GAO found that BLM's financial records did not accurately reflect the true costs of its programs because the costs of labor and a number of contracts and services costs were charged to MLAP and not to the appropriate program. As a result, other subactivities benefited from the charging of these improper costs and fewer funds have been available for actual MLAP operations. BLM has taken steps to make correcting adjustments for improper charges to MLAP contracts and services; however, additional adjustments are needed to correct for labor costs that were improperly charged to MLAP. Until these adjustments for improperly charged labor are made, Congress and program managers can place only a limited reliance on the accuracy of MLAP cost information.

section_title: Letter
paragraphs: The Bureau of Land Management’s (BLM) Mining Law Administration  Program (MLAP) is responsible for managing the environmentally  responsible exploration and development of locatable minerals on public  lands. The program is funded through mining fees collected from the  holders of unpatented mining claims and sites and by appropriations to the  extent that fees are inadequate to fund the program. During fiscal year  2000, BLM collected over $22.7 million in MLAP fees and reported MLAP  obligations totaling almost $32.6 million. Labor obligations represented a  substantial portion of the program cost − about 73.6 percent of total  obligations in fiscal year 2000. Therefore, an accurate accounting of these  costs is crucial for proper program management and accountability and  serves as a basis for estimating future costs when preparing budgets.
This report responds to your request that we review labor charges to MLAP  during the first 10 months of fiscal year 2000. On the basis of our prior  work, you also asked that we review BLM’s methodology for identifying  contracts and services that may have been improperly charged to MLAP  during fiscal years 1998 and 1999 and evaluate the processes and  procedures developed to correct the improper charges. Finally, you  requested that we determine whether BLM employees were aware of the  source of MLAP funding.
subsections: section_title: Background
paragraphs: Beginning in 1993, mining fees have included an annual $100 mining  maintenance fee on unpatented mining claims and sites and a $25 location  fee on new claims and sites. The maintenance fees are collected in lieu of  the annual $100 worth of labor or improvements required by the Mining  Law of 1872.
In addition, the Department of the Interior appropriations act for fiscal year  1993 and each fiscal year since established an amount of BLM’s  appropriation for MLR to be used for MLAP operations. However, the  appropriations acts require that the mining fees that BLM collects be  credited against the MLR appropriation used for MLAP operations until all  MLR funds used for MLAP are “repaid.” To the extent that fees are  insufficient to fully credit the MLR appropriation, the MLR appropriation  absorbs the difference and therefore partially funds MLAP. At the end of  the fiscal year, BLM issues a reverse warrant to the Treasury for the amount  of fees collected.
MLAP operations deal with locatable minerals, which include base and  precious metals (also called “hardrock minerals”), on public lands. MLAP  operations do not include work on nonlocatable or common variety  minerals, such as sand or gravel, or oil and gas work. MLAP operations do  include:  reviewing and approving plans and notices of mining operations,  conducting a comprehensive program of inspections and enforcement  to ensure compliance with the terms of plans and notices of operation  and related state and local regulations,  identifying and eliminating cases of unauthorized occupancy of mining   conducting validity examinations of mining operations in order to  eliminate cases of mineral trespass,  completing mineral examinations and processing of the  “grandfathered” mineral patent applications,  collecting and processing mining fees, and  collecting and processing waivers of maintenance fees.
section_title: Objectives, Scope, and Methodology
paragraphs: We examined how labor was charged to MLAP by BLM during the first  10 months of fiscal year 2000. We also examined BLM’s methodology for  identifying contracts and services that were improperly charged to MLAP  during fiscal years 1998 and 1999 and evaluated the processes and  procedures developed to correct the improper charges. We also asked  employees whether they were familiar with the source of MLAP funding.
To accomplish our first objective, we obtained records for MLAP’s fiscal  year 2000 collections and labor obligations from BLM’s accounting and  payroll systems and conducted a statistically representative survey o 125 BLM employees who charged time to MLAP during the period of  October 1, 1999, to July 15, 2000. Our review focused on nine of BLM’s  administrative states and offices: Alaska, California, Colorado, Eastern  States, Nevada, New Mexico, Oregon, Utah, and Washington Office. To  accomplish our second objective, we reviewed the documentation used in  BLM’s review of the contracts and services over $1,500 charged to MLAP  for fiscal years 1998 and 1999, a total of 491 contracts. These 491 contracts  represented over $8.0 million, or 89.3 percent, of the contracts and services  charged to MLAP during this time period. For our third objective we  included a question in our survey asking employees whether they were  aware of the source of funding for MLAP.
We did not independently verify the reliability of the accounting data  provided nor did we trace the data to the systems from which they came.  We conducted our work from August 2000 through December 2000 in  accordance with generally accepted government auditing standards. A  detailed discussion of our objectives, scope, and methodology is contained  in appendix I of this report. BLM provided written comments on a draft of  our report. The comments have been incorporated as appropriate and are  reprinted as appendix II. We considered but did not reprint the attachment  referred to in BLM’s comment letter.
section_title: Some Labor Costs Were Improperly Charged to MLAP
paragraphs: The results of our survey indicated that BLM employees’ hours charged to  MLAP were not a reliable record of hours actually worked on that program.  According to employees, hours were often charged to MLAP in excess of  hours worked or for work unrelated to mining. In addition, individuals  received bonuses or awards from MLAP funds although they charged no  labor to the program. An accurate accounting of MLAP costs is crucial for  proper program management and accountability and serves as a basis for  estimating future costs when preparing and reviewing budgets. Proper  tracking and recording of MLAP costs is especially important since this  program is partially funded through mining fees that Congress has made  available only for mining law administration program operations. “Charging work tasks, employee salaries, procurement or contract items, or equipment  purchases to any subactivity other than the benefiting subactivity violates the terms of the  Appropriations Act. Similarly, when procurements are charged to a given subactivity simply  because “money is available there” but have no direct relationship to subactivity’s program  accomplishment, is a violation of the integrity of managers’ financial management  responsibility and both the specific policy decisions and the direction of proper authorities  in setting those requirements. Future year program needs and requirements are based in  part on the record of past years’ costs and accomplishments. Therefore, records of actual  costs and accomplishments must be accurate as possible.”
subsections: section_title: Time Charges Differ From Hours Worked
paragraphs: While approximately one-half of the BLM employees stated that they  worked and charged the same amount of time to MLAP, we found that 38.9 percent charged more time to MLAP than they actually worked. Of this  38.9 percent, 17.6 percent of the employees stated that they did not work  on MLAP at all during the 10 months of our study period, although a portion  of their labor had been charged to the program. In contrast, approximately  11.4 percent of BLM employees reported charging less time to MLAP than  they actually worked. These results are summarized in table 1.
Our survey results showed that there were wide variations between the  hours worked and the hours charged to the program among the employees  who did not work and charge the same amount of time to MLAP. For  example, we found three respondents who reported working 50, 70, and 75 percent of their time on MLAP during our study period, but charged  100 percent of their time to the program. One respondent reported doing no  work on MLAP and charging 60 percent of the work hours to the program.  In contrast, another respondent reported working 60 percent of the time on  MLAP and charging only 11 percent to the program.
From our survey results, we were able to compute the total number of  hours worked and charged to the program and calculate an estimated net  overcharge to the program of about 10.8 percent. Based on this percentage  being applied to the 10-month MLAP payroll of approximately $11.4 million  for the nine administrative states and offices under review, we estimate the  potential net dollar overcharge to MLAP to be about $1.2 million. The total  MLAP payroll for all states and offices was approximately $24.0 million for  fiscal year 2000.
We asked the employees who stated that they charged more time to MLAP  than they worked to explain why the additional time was charged to MLAP.  During survey pretesting we had identified four possible explanations,  including: (1) time was charged based on the funding allocations (in other  words, charges were made to subactivities from which funds were  available for obligation rather than from the subactivity related to the task),  (2) time was charged based on the directions of a supervisor, (3) time was  charged based on the directions of a budget officer, and (4) no other codes  were available to charge (for example, the task being done may not have  been anticipated in the budget allocation and therefore the proper  subactivity code was not available to the office). The results of their  responses are presented in table 2. Employees could provide more than  one explanation for the overcharging; therefore the percentages in the  table total to more than 100 percent.
In addition, we asked the employees who stated that they charged more  time to MLAP than they worked to specify the tasks that they had charged  to MLAP. They reported charging time for such non-MLAP related tasks as  processing and approving applications to drill oil and gas wells, working on  environmental remediation projects, doing recreation management, and  performing vehicle maintenance. BLM officials stated that work involving  these tasks should not have been charged to MLAP. Employees also stated  that they had charged MLAP for labor involved in preparing mineral reports  for land exchanges and conducting work on common variety minerals,  such as sand and gravel. BLM officials stated that charging these tasks to  MLAP would be improper except for specific and unique cases—for  example, preparing a mineral report on a land exchange involving a mining  claim or making a validity determination on a mining claim involving sand  and gravel deposits. Our survey did not address whether the tasks charged  to MLAP were for any of these specific and unique cases.
Some BLM employees expressed uncertainty as to which tasks were  appropriate to charge to MLAP. For example, some employees stated that  work on mineral reports for land exchanges or abandoned mine lands  should not be charged to MLAP, while other employees told us that they  believed that any mineral-related tasks, including work on sand and gravel  operations, could be properly charged to MLAP.
All of the employees were asked whether they alone determined which  subactivity, including MLAP, would be charged for their labor. In our study  population, 68.5 percent of the employees responded that they had  received directions as to which subactivity to charge. Of these 68.5 percent,  approximately 66.3 percent stated that they received either written or  verbal direction from their supervisor and 55.7 percent stated that they  received either written or verbal direction from the budget officer/official.  In total, 93.7 percent of these employees received written or verbal  direction from either a supervisor or budget officer.
Labor obligations represent a significant portion of total MLAP  obligations—about 73.6 percent in fiscal year 2000—therefore, improperly  charging labor to MLAP could result in the Congress and program  managers using program cost information that is significantly misstated.
section_title: MLAP Funds Improperly Used to Pay Certain Bonuses and Awards
paragraphs: From BLM’s accounting records we identified 27 individuals who received  approximately $34,000 in bonuses or awards financed by MLAP funds, but  who had not charged any hours to the program. Because there were no  hours charged, these individuals were excluded from our survey; however,  we did contact BLM officials to determine the reasons for nine of the  awards and bonuses.
As stated previously, BLM’s policy is that labor associated with any task  should be charged to the subactivity benefiting from that labor. In addition,  we interviewed BLM’s Director of Budget to determine BLM’s policy for  charging bonuses and awards. He stated that any bonuses and awards  received as a result of the labor performed should also be charged to the  subactivity that benefited from that labor.
We found that five awards had been given to employees working on a  special project requiring the collection of mining claim documents for the  Department of the Interior’s Office of the Solicitor General. They received  awards from MLAP funds, even though the hours and associated labor for  the special project were not charged to MLAP. BLM officials stated that  charging these awards to MLAP was appropriate and that the associated  labor should also have been charged to the program. Not charging the  associated labor costs to MLAP resulted in program costs being  understated.
The remaining four awards were given to individuals for (1) researching  historical land data for a land withdrawal program, (2) assisting in the  moving of a BLM office to a new facility, (3) selling a private residence as  part of a lateral transfer and not using BLM’s relocation service, and  (4) performance resulting in an end-of-year bonus to a Lands and Realty  specialist. When asked why these four individual bonuses and awards had  been charged to MLAP, BLM officials either could provide no explanation  or stated that MLAP had been charged by mistake.
These over- and under-charges to MLAP further distort the cost of the  program and undermine the usefulness of MLAP operating data for  decision-making or performance reporting purposes.
section_title: BLM Effectively Identified Contracts and Services Improperly Charged to MLAP but Needs Additional Procedures to Prevent Recurrence
paragraphs: As a result of findings discussed with BLM management and provided in an  April 2000 congressional briefing, the Acting Director of BLM directed  BLM’s administrative states and offices to review contracts and services  costing over $1,500 that were charged to MLAP during fiscal years 1998 and  1999. The contracts reviewed represented over $8.0 million, or  89.3 percent, of the contracts and services obligated to MLAP during this  time period. The methodology BLM used to identify contracts and services  improperly charged to MLAP during fiscal years 1998 and 1999 was  reasonable and resulted in BLM determining that about $716,000 in contracts and services should not have been charged to MLAP. These  improper payments included:  over $34,000 for janitorial services,  $30,000 for the appraisal of federal coal leaseholds,  $25,000 for an attorney in an Equal Employment Opportunity settlement  for an employee who had not worked on MLAP tasks,  $2,800 for a cultural survey of an area prior to an off-highway vehicle  and motorcycle race, and  $2,000 for a habitat survey of a threatened and endangered species of  butterfly in an area with no active mining.
In addition, on the basis of our review, we questioned whether an  additional $40,000 for two contracts and services were improperly charged  to MLAP. These contracts and services were for a cooperative agreement  for Geographic Information System (GIS) support and a biological survey.  BLM officials concurred and stated that correcting adjustments would be  made to the proper appropriation for the additional $40,000.
BLM prepared Instruction Memorandum 2000-148 (IM-148) to provide  guidance on correcting the contracts and services charges that were  improperly charged to MLAP in fiscal years 1998 and 1999. IM-148 required  all offices that had improperly charged contracts and services to MLAP to  develop implementation plans to replace the funds and submit those plans  to BLM’s Director of Budget. Fourteen administrative states and offices  developed and submitted implementation plans to make about $716,000 in  correcting adjustments.
These correcting adjustments must be made to the appropriations that  were properly available when the obligations were incurred and BLM’s  records adjusted accordingly to charge that appropriation. BLM officials  have told us that they are identifying the appropriations for fiscal years  1998 and 1999 that should have been charged for the costs of these  contracts and services and that there are sufficient funds to make the  correcting adjustments of about $716,000. According to BLM’s Reports on  Budget Execution filed with the Office of Management and Budget for the  fourth quarters of fiscal years 1998 and 1999, MLR unobligated balances  were $54 million and $32 million, respectively.
On the basis of our review, we determined that BLM offices have complied  with all of the requirements in IM-148. While the memorandum stated that  all funds, not just MLAP funds, should be expended appropriately and costs  properly recorded in BLM’s financial management systems, it did not  establish any additional procedures on how to implement this policy to  prevent future improper charging of MLAP funds. Therefore, until  additional procedures specifically for MLAP are established and  implemented, BLM has little assurance that improper charging of MLAP  funds will not recur in the future.
section_title: Many Employees Are Unaware of Source of MLAP Funding
paragraphs: Finally, as requested, in our survey we asked BLM employees whether they  were aware of the source of funding for MLAP. Approximately 47.7 percent  of BLM employees stated that they were not aware of the source of funding  for MLAP programs. In addition, of the 52.3 percent of employees who  stated that they were aware of the source for this funding, about  42.5 percent did not know that the funding was based in part on mining  fees and designated for MLAP operations. In total, an estimated  69.9 percent of BLM employees were either not aware of the source of  MLAP funding or did not know that the program is partially funded by fees  collected from miners that are legally available only for MLAP operations.
section_title: Conclusions
paragraphs: The Congress and program managers need accurate cost information in  order to make informed program and budgeting decisions. BLM’s Fund  Coding Handbook recognizes that accurate records of costs and  accomplishments are critical for planning and decision-making. However,  the results of our work at BLM show that BLM’s financial records have not  accurately reflected the true costs of its programs because the costs of  some labor and a number of contracts and services costs were not charged  to the appropriate program. Other subactivities have benefited from the  charging of these improper costs to MLAP. Correspondingly, fewer funds  have been available for actual MLAP operations. BLM has taken steps to  make correcting adjustments for certain of these improper charges,  including the development of an Instruction Memorandum. However, the  memorandum dealt only with improper charges occurring in fiscal years  1998 and 1999 and did not establish specific guidance or procedures to  prevent improper charging of MLAP funds from recurring in the future.  Therefore, until additional procedures for MLAP are developed and  implemented, the Congress and program managers can place only limited  reliance on the accuracy of MLAP cost information.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Director of the Bureau of Land Management take  the following four actions:  make correcting adjustments for improper charges to appropriation   remind employees that time charges and other obligations are to be  made to the benefiting subactivity as stated in BLM’s Fund Coding  Handbook and develop a mechanism to test compliance;   provide detailed guidance clarifying which tasks are chargeable to  MLAP operations, such as those listed in the background section of this  report; and  conduct training on this guidance for all employees authorized to charge  MLAP.
section_title: Agency Comments
paragraphs: In commenting on a draft of this report, BLM concurred with the findings  and recommendations contained in our report. BLM’s response indicated a  number of actions it planned to take to address the respective  recommendations. Additionally, BLM indicated it would endeavor to  improve monitoring guidance and training to ensure the accuracy of costs  associated with MLAP. BLM’s comments have been incorporated as  appropriate and are reprinted as appendix II. We considered but did not  reprint the attachment referred to in BLM’s comment letter.
As agreed with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from the  date of this report. At that time, we will send copies to the Ranking  Members, Senate Committee on Energy and Natural Resources and its  Subcommittee on Forests and Public Land Management; the Ranking  Minority Members, House Committee on Resources and its Subcommittee  on Energy and Mineral Resources; Honorable Gale Norton, the Secretary of  the Interior; and Nina Hatfield, the Acting Director of the Bureau of Land  Management. Copies will also be made available to others upon request.
If you or your staff have any questions concerning this report, please  contact me at (202) 512-9508 or Mark Connelly, Assistant Director, a (202) 512-8795. Key contributors to this assignment are listed in appendix III.
section_title: Objectives, Scope, and Methodology
paragraphs: Our review examined labor charged to the Mining Law Administration  Program (MLAP) by the Department of the Interior’s Bureau of Land  Management (BLM) during the first 10 months of fiscal year 2000. We also  examined BLM’s methodology for identifying contracts and services that  were improperly charged to MLAP during fiscal years 1998 and 1999 and  evaluated the processes and procedures developed to correct those  improper charges. Finally, we determined whether BLM employees were  aware of the source of MLAP funding.
To accomplish our first objective, we obtained the records for MLAP’s  fiscal year 2000 collections and labor obligations from BLM’s accounting  and payroll systems. During fiscal year 2000, BLM collected over $22.7 million in MLAP fees, with BLM’s Nevada State Office collecting  approximately $11.1 million, or approximately 48.9 percent of the total  collections. In the same year, MLAP reported obligations totaling  approximately $32.6 million.
As agreed, our review focused on BLM employees charging time to or  receiving pay from the Mining Law Administration Program in Alaska,  California, Colorado, Eastern States, Nevada, New Mexico, Oregon, Utah,  and Washington Office for the period October 1, 1999, through July 15,  2000. The nine administrative states and offices reported MLAP obligations  of over $23.4 million, representing approximately 72 percent of total MLAP  obligations. BLM classified these obligations as either labor or operational  in purpose. Labor obligations, including leave surcharge, for the nine  administrative states and offices totaled over $17.4 million, over 74 percent  of the total obligations for the nine administrative states and offices in  fiscal year 2000.
subsections: section_title: Survey Sample
paragraphs: In order to evaluate labor charges to MLAP by BLM during fiscal year 2000,  we conducted a statistically representative survey of BLM employees who  had charged MLAP during this 10-month period. The survey included  questions regarding employees’ time keeping and reporting practices  during the survey period, the tasks they worked on, and the subactivities  charged for their work. We specifically asked employees in our survey  whether they were aware of the source of MLAP funding. Estimates  included in this report are representative of the study population for this  10-month period.
section_title: Survey Sample Design
paragraphs: The study population consisted of 744 BLM employees for whom work was  charged to MLAP appropriation account during the period of October 1,  1999, through July 15, 2000, in the nine administrative states and offices  listed above. Excluded from the study population were those employees  who did not charge work to MLAP, even if they had other charges to the  funds appropriated for MLAP operations.
The sample design for this study is a single-stage stratified sample of the  employees in the study population. The nine administrative states and  offices are the strata for our study population. The sample of 125 employees was selected from the strata in proportion to the study  population in each stratum. We obtained 116 useable responses from this  sample. The population, sample allocation, and sample disposition are  summarized in the following table.
section_title: Questionnaire Design
paragraphs: The survey questionnaire was pretested twice and then distributed to  survey participants in advance of the telephone interviews. Interviewers  used a computer-assisted data entry program to conduct the telephone  interviews and to input the sample data into a database.
section_title: Survey Administration
paragraphs: This was a telephone survey, with hard copy of the questionnaire made  available to the respondent a couple days prior to the telephone interview.  Data were collected between October 25 and November 20, 2000.  Follow-up interviews were performed between November 21 and  December 21, 2000.
section_title: Survey Response
paragraphs: We received useable responses from 116 sampled employees for an overall  response rate of 92.8 percent. The nonrespondents consisted of nine  individuals who were no longer BLM employees and could not be located,  had retired, or were on extended sick leave. Response rates by strata are  summarized in table 3.
section_title: Calculation of Survey Estimates
paragraphs: After weighting survey responses to account for selection probabilities and  nonresponses, estimates were produced for various characteristics of the  study population.
section_title: Sampling Error
paragraphs: Because we followed a probability procedure based on random selections,  our sample is only one of a large number of samples that we might have  drawn. Since each sample could have provided different estimates, we  express our confidence in the precision of our particular sample’s results as  a 95-percent confidence interval (for example plus or minus 9 percentage  points). This is the interval that would contain the actual population value  for 95 percent of samples we could have drawn. As a result, we are  95-percent confident that each of the confidence intervals in this report will  include the true values in the study population.
In this report, all percentage estimates from MLAP survey have sampling  errors of plus or minus 9 percentage points or less, unless otherwise noted.
section_title: Nonsampling Error
paragraphs: In addition to the reported sampling errors, the practical difficulties of  conducting any survey may introduce other types of “nonsampling” errors.  For example, differences in how a particular question is interpreted, the  sources of information that are available to respondents, or the types of  employees who do not respond can all introduce unwanted variability into  the survey results.
Although we did not verify respondents’ answers, we did include steps in  the questionnaire design, data collection, data entry, and analysis processes  to minimize nonsampling errors. Specifically, we modified our questions  based on pretests to make them more understandable and easier to answer.  We made repeated attempts to contact sample employees to encourage a  high level of response that would reduce any potential nonresponse bias.  As data were keyed, they were automatically checked for internal  consistency and for out-of-range values. An additional review of survey  estimates revealed internally inconsistent data between two questions for  eight survey respondents. We made follow-up phone calls to these  respondents and reconciled the noted inconsistencies.
Another potential source of nonsampling error in this survey would be the  reporting of information for the wrong time period. Estimates from this  survey are only applicable to the time period from October 1, 1999, to July 15, 2000. In order to reduce the possibility that respondents might  report on labor performed after the end of the study period, language was  included with many of the survey questions to remind the respondent that  they should only respond about labor performed during the study period.
section_title: Limitations of the Survey
paragraphs: Estimates from this survey are only applicable to the time period from  October 1, 1999, to July 15, 2000, and cannot accurately represent labor  performed over the entire fiscal year. For example, if employees tended to  charge more or less time than worked to certain programs during the last  2 months of the fiscal year, that labor would not be reflected in survey  estimates.
Our study population was limited to those BLM employees who charged  work to MLAP during the study period. Consequently, the estimates from  the MLAP survey would not reflect any labor by employees who worked on  MLAP during the study period but did not charge the program.
section_title: Nonsurvey Work
paragraphs: In addition to our statistically representative telephone survey, we  conducted telephone interviews with judgmentally selected BLM  employees who had received awards or bonuses from MLAP, but had not  charged any time to the program.
To accomplish our second objective, we reviewed the documentation used  in BLM’s review of the contracts and services over $1,500 charged to MLAP  for fiscal years 1998 and 1999, a total of 491 contracts. These 491 contracts  represented over $8.0 million, or 89.3 percent, of the contracts and services  obligated to MLAP during this time period. We conducted walkthroughs of  the procedures BLM performed in that review and evaluated BLM’s criteria  for determining appropriate use of MLAP funds. We also interviewed field  office personnel regarding internal controls associated with the requisition  and approval of contracts and services. In order to review BLM’s  procedures for making correcting adjustments for improper charges to  MLAP, we obtained and reviewed BLM’s Instruction Memorandum No.  2000-148 (IM-148), which required all offices that had improperly charged  contracts and services to MLAP to develop implementation plans for the  replacement of the miscoded MLAP funds and submit those plans to BLM’s  Director of Budget. We then interviewed BLM officials responsible for  coordinating the implementation of IM-148, reviewed the procedures taken  to comply with IM-148’s requirements, and verified that the procedures had  been followed by reviewing the pertinent documentation, including  implementation plans, reports of budgetary transactions, and budget  control printouts. We compared the contracts and services listed in the  transactions reports prepared by BLM’s Man’agement Information System  with the lists of contracts and services submitted by BLM’s administrative  states and offices to test the completeness of BLM’s sample. Finally, we  reviewed the 491 contract amounts using the documentation provided to  BLM. We examined the amounts cited, the services provided, and the  justifications given in order to verify that the charges to MLAP were  appropriate.
We did not independently verify the reliability of the accounting data  provided nor did we trace the data to the systems from which they came.  We conducted our work from August 2000 through December 2000 in  accordance with generally accepted government auditing standards.
section_title: Comments From the Department of the Interior
section_title: Staff Acknowledgments
paragraphs: Mark P. Connelly, Edda Emmanuelli-Perez, Lisa M. Knight, W. Stephen  Lowrey, Miguel A. Lujan, Mark F. Ramage, Shannah B. Wallace, and  McCoy Williams made key contributions to this report.
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