Free Response to Motion - District Court of Federal Claims - federal

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Exhibit 19

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Status Report to the Court Number Nineteen
For the Period July 1, 2004 through September 30, 2004

November 1, 2004

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004

TABLE OF CONTENTS
Io

INTRODUCTION .............................................................................................................

1

II.

SECRETARY GALE NORTON'S OBSERVATIONS .................. i .............................. 2 4 10 13 15 24 27 30 30 34 34 37 40 42

A. INFORMATION TECHNOLOGY ................................................................................. B. CADASTRAL SURVEY ................................................................................................

C. MINERALS MANAGEMENT SERVICE ................................................................... D. OFFICE OF HISTORICAL TRUST ACCOUNTING ............................................... III.
Ao

OFFICE OF THE SPECIAL TRUSTEE FOR AMERICAN INDIANS ................... TRUST REVIEW AND AUDIT ..................................................................................... OST-OFFICE OF THE CHIEF INFORMATION OFFICER ...................................
°

B.

RECORDS MANAGEMENT ....................................................................................

C. TRUST ACCOUNTABILITY ....................................................................................... 1. 2. 3. 4. 5. TRUST BUSINESS PROCESS: MODELING .......................................................... TRUST DATA QUALITY AND INTEGRITY ........................................................ INDIAN FIDUCIARY TRUST TRAINING PROGRAM ...................................... RISK MANAGEMENT .............................................................................................. REGULATIONS, POLICIES AND PROCEDURES ...................................

: .......... 43 45 45 48 48 53 53 56 58 60

D. FIELD OPERATIONS ........................................................................... ........................ 1. APPRAISAL .................................................................................................................

E. TRUST SERVICES ......................................................................................................... 1. IV. CURRENT ACCOUNTING ACTIVITIES ............................................................. BUREAU OF INDIAN AFFAIRS .................................................................................

A. TRUST REGULATIONS, POLICIES AND PROCEDURES ................................... B. FRACTIONATION ........................................................................................................ ~ .............................................................

C. PROBATE .........................................................

ACRONYMS AND ABBREVIATIONS ...................................................................................

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004 A. INFORMATION TECHNOLOGY Introduction This section describes the status of Interior IT systems, particularly the systems that house or provide access to IITD or provide various computing capabilities, including functions critical to the proper administration of the individual Indian trust responsibilities within Interior. In addition, this section describes various efforts being made to improve IITD security within Interior, pursuant to OMB Circular A-130 Appendix III, and the status of Internet connectivity. Accomplishments and Completions Computer Security: Interior continues to make progress in ensuring IT security and, in particular, addressing the potential risks associated with unauthorized access to IITD from the Internet. A primary focus for this quarter has been completing actions required for certification and accreditation of Interior IT systems pursuant to A-130. The most noteworthy accomplishments and completions during the reporting period are described below. Training and Awareness · Bureaus and offices conducted a simulation exercise for incident response. The exercise tested procedures and practices in place to determine their effectiveness in responding to security incidents. It also provided IT staff and management hands-on experience in dealing with unexpected situations. All bureaus and offices completed the test and documented potential improvements to processes. Information Technology

Prevention and Monitoring · · Interior continued testing Internet-accessible systems against the SANS Top 20 vulnerability list. For the second consecutive reporting period, no hosts were found to have vulnerabilities listed in the SANS Top 20. BIA completed its assessment of the Blaster worm incident reported in the previous report to the Court. The virus was introduced to BIA by magnetic media and subsequently spread to other machines that had not been patched for Blaster worm vulnerability. The incident occurred while BIA was in the process of implementing two actions that would have mitigated or prevented the incident: (1) deploying automated patching capability; and (2) replacing legacy operating systems. The first of these actions was completed but cannot be used with older operating systems; the second is scheduled to be completed by the end of CY2004.

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004 Policies and Guidance · The Memorandum, "Information Technology Security Requirements for Acquisition," dated August 18, 2004, from Interior's CIO and Director of the Office of Acquisition and Property Management, was sent to the heads of bureaus and offices, bureau and office CIOs, deputy CIOs and procurement chiefs. This memorandum establishes guidelines for assuring IT security requirements are included in IT-related contracts. Information Technology

A-130 Certification and Accreditation: Over 90% of Interior's general support systems and major applications have been certified and accredited by the respective bureau or office DAA and have full authority to operate. C&A reviews conducted by a qualified third-party have been completed for 21% of the bureau and office accreditations. OCIO expects to report on these reviews in future reporting periods. IT Systems Architecture: Interior was honored for its Enterprise Architecture Program, which guides the modernization of Interior's business operations to provide more cost-efficient, user-centered service to the nation. The E-Gov Institute, a private organization, awarded Interior the Excellence in Enterprise Architecture Award in the category of Federal Civilian Leadership in Government Transformation. The Enterprise Architecture Program provides a roadmap for leveraging information technology to meet strategic and programmatic goals and objectives efficiently and effectively. Interior updated its program maturity self-assessment using the OMB Enterprise Architecture framework tool. Interior scored 4.0 on a 5.0 scale, which indicates the architecture is being operationalized across Interior and is providing performance impact to business operations. This is an improvement from a 3.3 rating from the last quarterly submission, and up from 2.0 in 2003. Phase 3A of DEAR data validation and population was completed this reporting period. This phase focused on cross-mapping Interior's system inventory to the goals and objectives in the DOI Strategic Plan FY 2003 ­ 2008 and the Interior Enterprise Architecture Performance Reference Model. This cross-mapping provides Interior information to identify system gaps in its portfolio for accomplishing the DOI Strategic Plan. TrustNet During this reporting period, TrustNet, an internal secured network, was expanded as follows: · · Four of the six OHTA sites have been connected to TrustNet on a managed service program (firewalls, intrusion detection and monitoring). The Office of the Solicitor moved 95% of its data communications infrastructure from Denver to Herndon, VA, and is expected to be connected to the Department's TrustNet during the next reporting period.

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004 Information Technology

Current Status A-130 Certification and Accreditation: OCIO has implemented a comprehensive program to define, accomplish, and review certification and accreditation packages. Interior established policies that use criteria identified in publications issued by the National Institute for Standards and Technology. Additionally, Interior to date has delivered formal C&A training to 258 bureau staff responsible for the conduct of certification and accreditation procedures. In FY2004, Interior bureaus and offices applied $12 million in funding, specifically budgeted to accomplish C&A. OCIO established a Blanket Purchase Agreement with vendors qualified to support the bureaus in independent verification of controls. This investment and focus helped bureaus and offices achieve accreditation for over 90% of major applications and GSS, compared to the 10% accredited as of September 30, 2003. As noted in GAO-04-376, Agencies Need to Implement Consistent Processes in Authorizing Systems for Operation (June 2004), accreditation packages of federal agencies required by the Federal Information Security Management Act and A-130 vary in quality and standards of content. OCIO is addressing this challenge faced by federal agencies by establishing a quantitative checklist for C&A package quality and applying it to accredited systems. Although not required by FISMA or A-130, Interior expects to perform a 100% quality review of the C&A packages by the end of the second quarter of FY2005. C&A reviews conducted by a qualified third party have been completed for 21% of the bureau and office accreditations. OCIO expects to report on these reviews in future reporting periods. Areas in C&A packages identified for improvement will be tracked via the POA&M process, which includes a schedule for resolution. Trust Network Connection: Interior's Enterprise Services Network consolidates departmental Internet connections, adds centrally-managed network perimeter security, provides secure connectivity between bureaus and offices (Intranet) and implements twenty-four hour network security monitoring. The trust network segment, which hosts trust related computer systems, will be connected to the ESN via a series of additional network security devices including firewalls, routers and intrusion detection devices. These devices will be configured to allow outbound connections to the ESN and block all incoming access except electronic mail. Internal trust computer applications are protected by at least three security layers: Internet perimeter security, Intranet security and host-based security. Shared network segments (known as demilitarized zones) will be created to allow trust and nontrust bureaus and offices to share a limited subset of trust data, such as electronic mail. Under no circumstances will direct Internet access be permitted to internal trust network segments.

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004 Information Technology

The trust network segment has been certified and accredited using Interior's NIST-based security C&A process. Routine scanning and vulnerability testing are used to ensure the trust network is secured from unauthorized access from the Internet. Interior continues to develop reconnection plans for Interior bureaus and offices (BIA, OHA, OST and SOL) that have not been permitted by the Court to have Internet access since December 5, 2001. Continued disconnection of these systems hampers Interior's ability to provide the most effective IT operations and security. Reports: · GAO issued "Federal Chief Information Officers: Responsibilities, Reporting Relationships, Tenure, and Challenges" (GAO-04-823) and "Information and Technology Management: Responsibilities, Reporting Relationships, Tenure and Challenges of Agency Chief Information Officers" (GAO-04-957T). As these reports cover descriptions of CIO roles government-wide, they may or may not be of interest to the Court. Although Interior issued its annual FISMA report on October 8, 2004, following the end of this reporting period, the Court may find it of interest. In summary, the report states Interior systems are adequately secured, its investments are sound and Interior is in compliance with the President's mandates and congressional direction. FISMA provides a framework and relevant agency roles in ensuring the effectiveness of security controls with regard to information resources that support federal operations and assets. In support of FISMA, Interior has: o Increased annual IT security spending from approximately $4 million in previous years to $49.2 million in FY2004, including $12 million specifically identified for C&A. The FY2004 budget is consistent with OMB guidance suggesting that 5% of IT spending be targeted for security. o Accredited over 90% of IT systems as of September 30, 2004. Reviewed 21% of those accreditations against quality standards. o Established configuration standards for common platforms to facilitate security settings and patch management. o Promulgated policies, directives, and standards for IT security topics including C&A, peer-to-peer technologies, security in contracts, and others. o Trained 76,888 employees and contractor staff (93% of end users) in relevant computer user policies and practices. o Maintained a monthly scanning program that assesses Interior systems against the SANS Top 20 vulnerability list, entering the eighth consecutive month with no vulnerabilities found. · In addition, OIG issued its FY2004 Annual Evaluation, DOI Information Security Program on October 12, 2004. This report states that Interior "has effectively designed its information security program to meet the requirements of FISMA and continued to improve security over its information systems." As part of the evaluation, OIG examined 19 fully accredited -7-

·

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004 Information Technology

systems. The report "identified weaknesses in the conduct of a majority of the system certifications" which, in the IG's opinion, "demonstrates a clear need for qualitative examination by the CIO of reported bureau accomplishments." Bureaus and offices have not had an opportunity to review "identified weaknesses." These findings will be reviewed to determine their validity. OCIO is currently conducting such an examination. OCIO is working with OIG to determine a clear inventory of findings, which will be incorporated into the POA&M process in accordance with OMB guidance. By maintaining a managed and accountable effort, Interior expects to continue to translate budget into value-added results for the IT security program. Given the comprehensive nature of FISMA, meeting its requirements affirms the focus and responsibility Interior takes in protecting the confidentiality, integrity, and availability of its information systems. Delays and Obstacles There are many challenges that must be addressed regarding the integration, performance, funding, security, and data integrity of Interior IT systems. Interior initiated or completed steps to address some of the challenges reported in this and previous reporting periods. However, delays and obstacles listed here still impede progress in achieving Interior's IT management goals: Litigation · Employee fears about becoming personally implicated in the Cobell litigation are undermining creativity and decision-making. This impediment has worsened within Interior as new restrictions on communication have been placed on Interior employees by the Court.

Funding · Funding availability will continue to dictate the timing of IT-related initiatives. Interior's FY2005 budget will require managing a variety of IT-related requirements and tradeoffs. The additional resources (time, personnel, and funding) provided for IT security have limited the funding for other IT-related activities, which on occasion has adversely impacted overall systems performance.

Reengineering Effort · Interior is conducting a business process reengineering effort to standardize and streamline trust business processes. IT system specifications, design, and procurement may depend upon the timing and results of the reengineering effort and available funding.

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004 Information Technology

Denied Internet Access · Several Interior bureaus and offices (BIA, OHA, OST and SOL) have not been permitted by the Court to have Internet access since December 5, 2001. Lack of Internet access impedes work processes and the ability to communicate effectively, both internally and externally. For example, not having access to the Internet continues to deny the public electronic access to OHA administrative decisions. Maintaining security on internal systems is more difficult without access to the Internet for research, reporting, and patch management.

Assurance Statement I concur with the content of the information contained in the Information Technology section of the Status Report to the Court Number Nineteen. The information provided in this section is accurate to the best of my knowledge. Date: October 27, 2004 Name: Signature on File W. Hord Tipton Interior Chief Information Officer

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004 B. Records Management

OST-OFFICE OF THE CHIEF INFORMATION OFFICER 1. RECORDS MANAGEMENT

Introduction The Office of Trust Records was established in 1999 to develop and implement a program for the economical and efficient management of trust records, consistent with the 1994 Act, the Federal Records Act and other statutes and implementing regulations. The OTR records management program has been developed and implemented, and continues to evolve, to ensure that necessary Indian records are maintained, records retention schedules are consistent with retention needs, and records are safeguarded throughout their life-cycles. Accomplishments and Completions American Indian Records Repository During this reporting period, approximately 23,300 boxes of indexed inactive Indian records were moved to the AIRR in Lenexa, KS, both from OTR's facilities in Albuquerque and from the Lee's Summit FRC in Kansas City, MO. A total of approximately 64,200 indexed boxes are located in the AIRR, as of the end of this reporting period. Records Indexing Project A total of 86,868 boxes had been indexed by the end of this reporting period. Priority for the indexing of boxes of Indian records continues to be given to those boxes of records potentially responsive to tribal trust litigation, and includes boxes required by OHTA for litigation discovery requests. With the conclusion of the Lee's Summit portion of the indexing project in July 2004, OTR's indexing contractor moved its work site from Kansas City, MO, to Lenexa, KS (the Lenexa Annex) in order to be located closer to the AIRR. Approximately 8,700 boxes of records were moved from Albuquerque to Lenexa for indexing. Also, during this reporting period, OTR relocated to Lenexa approximately 11,700 boxes of records from the GSA Indian Trust Accounting Division warehouse in Lanham, MD. Indexing of these boxes also will be conducted at the Lenexa Annex. All indexecl boxes then will be stored in the AIRR. It is anticipated that the Albuquerque portion of the indexing project will conclude during the next reporting period, and all indexing will occur in Lenexa thereafter. Haskell Indian Nations University Records Management Certificate Program As reported in the Status Report to the Court Number Fifteen, Interior and NARA agreed to develop an archival and records management studies program at Haskell Indian Nations University in Lawrence, KS. Pursuant to this agreement, the first records management class was

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004 Records Management

offered to Haskell students as classes began in September. OTR is providing the instructor for the fifteen students enrolled in the class this semester. Training OTR provided records management training for 355 BIA/OST-identified records contacts during this reporting period. In FY2004, OTR trained 1,397 BIA/OST employees and 35 tribal employees. Equipment Purchases During FY2004, OTR provided more than 400 items of fireproof filing equipment to BIA and OST programs and 13 items to one Tribe. During an evaluation of this Tribe's ability to manage trust functions, as required in its compact, it was noted that the Tribe was in need of such equipment. Records Movement During this reporting period, revised policy and guidance for requesting approval to move inactive records was implemented. Pursuant to this guidance, Interior bureaus and offices that have completed certifications regarding Indian trust records now may move certified non-trust records without prior approval from the Associate Deputy Secretary. Instead, disposition of nontrust records once again is governed by NARA-approved record retention schedules. Bureaus and offices still are required to submit a move plan and receive approval from the Assistant Deputy Secretary, acting on behalf of the Associate Deputy Secretary, before moving trust records. Additionally, the policy and guidance delegates authority to OTR for approving move plans submitted by BIA and OST, in that all of their inactive records are to be moved to the AIRR under OTR's direction. Records Management Liaison During this reporting period, OTR filled the records management specialist position in the BIA Central Office. Current Status Safeguarding Records A contract was awarded on September 30, 2004, for services to assess and prescribe treatment for records that were or may have been damaged or contaminated by mold, mildew, mouse droppings, and other adverse elements. During the next reporting period, OTR and the contractor expect to concentrate on boxes requiring remediation that are located in OTR facilities in Albuquerque. As of the end of this reporting period, OTR has 269 boxes that need to be assessed.

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STATUS REPORT TO THE CO UR T NUI~BER NINETEEN November 1, 2004 Records Management

Record Keeping Requirements NBC completed the identification of all offices under the Office of the Secretary that maintain Indian fiduciary trust records. NBC will work with these offices to perform records inventories and to update records retention schedules, as appropriate. This will be an ongoing project. Ultimately, NBC is expected to update record schedules, which will be submitted to the Archivist of the United States for approval. The Tribal/Federal Trust Records Management Work Group met on August 24, 2004, in Nashville. The Work Group continued discassions on tribal responsibility for creation and maintenance of trust records for contracted/compacted trust programs. It is anticipated that a letter to all tribal leaders will be sent in the next reporting period providing an update and soliciting comments on the work of the group. Site Assessments During this reporting period, OTR completed records management site assessments of BIA programs located at Pawnee Agency, Southern Ute Agency, Laguna Agency, Northern Pueblos Agency, Anadarko Agency, Shawnee Agency, Horton Field Office and Southern Plains Regional Office, and completed site assessments at the OST field offices located at Pawnee Agency, Anadarko Agency, Shawnee Agency, Horton Field Office and the Southern Plains Regional Office. Written reports are expected to be provided to each office in the next reporting period. Records Retention Schedules Draft records retention schedules for sixteen non-fiduciary-trnst BIA programs were submitted for comment to NARA and BIA. After comments are received, OTR will revise the schedules, as necessary. Delays and Obstacles Lack of Internet access continues to hinder OTR's ability to provide access to the record index database for authorized users of the records. If Internet access were available, authorized researchers could conduct their searches remotely from their respective work sites and only visit OTR when necessary to inspect specific boxes. Use of the limited space in OTR facilities continued to affect OTR's daily work activities as OTR staff attempted to respond to requests for boxes of records from federal attorneys, plaintiffs' tribal trust litigation attorneys and their contractors, and f~deral agencies and their contractors. Due to tribal trust litigation court orders and agreements regarding discovery, several thousand boxes of indexed records must remain in Albuquerque. Otherwise, these boxes could be moved to Lenexa and discovery could take place in the AIRR, a state-of-the-art archive facility.

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STATUS REPORT TO THE COURT NU~fBER NINETEEN
I

November 1, 2004 Assurance Statement

Records Management

I concur with the content of the information contained in the Records Management section of the Status Report to the Court Number Nineteen. The information provided in this section is accurate to the best of my knowledge. Date: October 28, 2004 Name: Signature on file Ethel J. Abeita Director, Office of Trust Records Office of the Special Trustee for American Indians

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STATUS REPORT TO THE COURT NUMBER NINETEEN November 1, 2004 Indian Fiduciar~ Trust Trainin~ Program

3. INDIAN FIDUCIARY TRUST TRAINING PROGRAM Introduction Interior has a continuing responsibility to provide adequate staffing, supervision and training for trust fund management and accounting activities. Fiduciary trust training is essential to the success of Interior's trust reform efforts and forms an integral part of all training for Interior employees who are involved in the management of Indian trust assets. Accomplishments and Completions OST offered one session of the course, Fiduciary Overview Program, presented by Cannon Financial Institute, with 27 BIA, OST, MMS and tribal personnel attending during this reporting period. A total of 473 people have attended this course since March 2003. This course compares and contrasts the federal Indian trust administered through Interior with private sector trusts administered through banks and other financial institutions. Additional sessions are scheduled to be held during the next reporting period. During this reporting period, OST training staff conducted six sessions to provide training in TFAS, StrataVision and Historical Query to 37 OST, BIA and contractor staff. The three-day course, Trust Fundamentals, which is a comprehensive orientation program tailored to meet the needs of employees in m~st-related positions, was presented to BIA and OST employees in Billings and Phoenix. This course is expected to be taught three or four times a year by regional BIMOST employees. OST offered the first orientation program for trust officers and deputy superintendents for trust. OST regional ~ust administrators, trust officers, BIA deputy superintendents for trust and a superintendent attended the first two weeks of this three-week orientation program in Albuquerque. Goals of the program include providing an overview of federal Indian law and policy; introducing the participants to each other and helping them understand the importance of working together; and providing the technical training necessary to perform their jobs. The third week is scheduled to be held during the next reporting period. Another three-week orientation program is scheduled to begin during the next reporting period for additional participants. OST and BIA completed development of two trust certification programs in conjunction with the Cannon Financial Institute. Specialty courses have been developed and are expected to be presented by Cannon personnel during the next reporting period. Upon completion of the required courses, participants take a comprehensive exam resulting in the designation of Certified Indian Fiduciary Trust Analyst or the higher-level Certified Indian Fiduciary Trust Specialist.

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STATUS REPORT TO THE CO (JR T NUMBER NINETEEN November 1, 2004 Indian Fiduciary Trust Trainin~ Program

Current Status As previously reported, OST has contracted for the development ofa CD version of the Fiduciary Trust Foundations: An Introduction to Trust Reform and Change course. The CD version is designed to provide trust personnel with a basic understanding of the federal government's fiduciary responsibilities. Changes requested by SOL were completed and OST training staff received the completed product this reporting period. Training deficiencies identified in the Training Inventory and Identification of Critical Functional Training Areas for the Department of the Interior's Indian Trust Training Program are being reviewed and course development is underway. OST training staff expects to meet with senior management as courses are developed. The draft Manager's Handbook for New Hires was circulated for comment to BIA and OST management, who suggested several modifications. The draft handbook was revised based on these comments and has been approved by senior management. Final publication is expected to occur during the next reporting period. Delays and Obstacles The lack of Internet access inhibits electronic communication with other governmental agencies and contractors, hinders the research of trainJEng tools and potential contractors, and restricts OST's ability to access online training programs. Assurance Statement I concur with the content of the information contained in the Indian Fiduciary Trust Training Program section of the Status Report to the Court Number Nineteen. The information provided in this section is accurate to the best of my kalowledge. Date: October 22, 2004 Name: Signature on File Dianne M. Moran Director, Trust Training Office of the Special Trustee for American Indians

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Exhibit 20

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Status Report to the Court Number Twenty
For the Period October 1, 2004 through December 31, 2004

February 1, 2004
Ilil II il Ii I ..................... ,~ ' ......................... ~'

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STATUS REPORT TO THE COURT NUMBER TWENTY Februar~ 1, 2005 TABLE OF CONTENTS

Io

INTRODUCTION ................................................................................................................ SECRETARY GALE NORTON'S OBSERVATIONS .....................................................

1 2 4 . .... 10 13 15 26 29 31 31 34 34 37 40 42 43 45 45 48 48 53 53 56 58 60

II.

A. INFORMATION TECHNOLOGY ................................................................................. B. C. CADASTRAL SURVEY ........................................................................................... MINERALS MANAGEMENT SERVICE ...................................................................

D. OFFICE OF HISTORICAL TRUST ACCOUNTING ............................................... III. OFFICE OF THE SPECIAL TRUSTEE FOR AMERICAN INDIANS ....................... A. TRUST REVIEW AND AUDIT .................................................................................... B. 1. OST-OFFICE OF THE CHIEF INFORMATION OFFICER ................................... RECORDS MANAGEMENT ....................................................................................

C. TRUST ACCOUNTABILITY ....................................................................................... 1. 2. 3. 4. 5. TRUST BUSINESS PROCESS MODELING .......................................................... TRUST DATA QUALITY AND INTEGRITY ........................................................ INDIAN FIDUCIARY TRUST 'TRAINING PROGRAM ...................................... RISK MANAGEMENT .............................................................................................. REGULATIONS, POLICIES AND PROCEDURES ..............................................

D. FIELD OPERATIONS ................................................................................................... 1. APPRAISAL ................................................................................................................

E. TRUST SERVICES ........................................................................................................ 1. CURRENT ACCOUNTING ACTIVITIES .............................................................

IV. BUREAU OF INDIAN AFFAIRS ..................................................................................... A. TRUST REGULATIONS, POLICIES AND PROCEDURES ................................... B. FRACTIONATION ........................................................................................................ C. PROBATE .......................................................................................................................

ACRONYMS AND ABBREVIATIONS ...................................................................................

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STATUS REPORT TO THE COURT NUMBER TWENTY February 1, 2005 A. Introduction This section describes the status of Interior IT systems, particularly the systems that house or provide access to IITD or provide various computing capabilities, including functions critical to the proper administration of the individual Indian trust responsibilities within Interior. In addition, this section describes various efforts being made to improve IITD security within Interior, pursuant to OMB Circular A-130 Appendix III, and the status of Internet connectivity. Accomplishments and Completions Computer Security: Interior continues to make progress in ensuring IT security and, in particular, addressing the potential risks associated with unauthorized access to IITD from the Internet. A primary focus for this reporting period has been conducting reviews of C&A documentation. The most noteworthy accomplishments and completions during the reporting period are described below. Training and Awareness · A revised version of mandatory annual end-user IT security awareness training was completed and will be deployed in January 2005 for the new annual cycle of training. The latest version of the training incorporates updates to Interior guidance and OIG recommendations for content. OCIO conducted POA&M training for bureau and office IT security personnel. Interior targeted CISSP certification because CISSP credentials indicate those certified have demonstrated experience in the field of information security, passed a rigorous examination, subscribe to a code of ethics and maintain certification with continuing education. To date, 63 Interior personnel representing all bureaus and offices have been awarded the CISSP certification. INFORMATION TECHNOLOGY Information Technology

· ·

Prevention and Monitoring · BIA purchased and distributed new equipment that will allow standard, secure operating systems to replace a major portion of BIA legacy operating systems, a requirement that enables bureau-wide deployment of patch management capability. Where equipment and operating systems meet configuration requirements, patch management has been implemented, which might have mitigated or prevented the previously-reported Blaster incident. The Interior OIG began unannounced penetration testing exercises for systems connected to the Internet. The OIG is expected to continue these exercises for all bureaus and offices throughout FY2005. In the initial testing, the intrusion attempts were detected and blocked by the subject agency. Even when all intrusion attempts are successfully blocked, testing

·

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STATUS REPORT TO THE COURT NUMBER TWENTY February 1, 2005 Information Technology

·

may provide information on potential vulnerabilities. Correction of such vulnerabilities is expected to be incorporated into the POA&M process for remediation. Interior implemented a policy and procedures requiring each bureau and office to establish a monthly vulnerability scanning program utilizing the Interior standard for high-risk internal network segments.

Policies and Guidance · The Memorandum "E-Authentication Risk Assessment," dated October 6, 2004, from Interior's CIO was sent to bureau and office CIOs.2 The Memorandum "Homeland Security Presidential Directive - 12 Compliance," dated December 27, 2004, from Interior's Assistant Secretary for Policy, Management and Budget was sent to assistant secretaries and heads of bureaus and offices.3 These memoranda continue Interior's aggressive efforts to improve IT security and efficiency. The MMS CIO issued the Memorandum "FY2005 IT Security Training Requirements for Information Technology (IT) Professionals," dated October 14, 2004. MMS requires IT professionals to accumulate a minimum of eight credit hours of IT security training annually. The Memorandum "Certification and Accreditation Package Reviews," dated October 20, 2004, from Interior's CIO was sent to assistant secretaries and heads of bureaus and offices. This memorandum describes the C&A documentation quality review process, as described in the previous report to the Court. It directs bureau and office CIOs to resolve identified deficiencies in C&A documentation within 180 days. The BLM CIO issued Instruction Memorandum 2005-009, dated October 21, 2004, "Eliminating Access to Critical Business Systems by Employees No Longer with BLM." This memorandum is in response to financial systems audit findings and documents additional requirements to ensure terminated employee access to financial systems is promptly removed. The Memorandum "Findings and Recommendations Database Status Certification," dated October 29, 2004, from Interior's CIO was sent to the CIOs for OST, BLM, OHA and SOL and the AS-IA. This memorandum provides the results of an independent contractor review of the process for closing items in the audit findings database described in the Eighteenth Status Report to the Court.

· ·

·

·

E-Authentication is designed to provide a trusted and secure standards-based authentication architecture. This approach would provide a uniform process for establishing electronic identity and eliminate the need to develop redundant solutions for the verification of identity and electronic signatures. E-Authentication's distributed architecture would also allow citizens and businesses to use non-government-issued credentials to conduct transactions with the government. HSPD-12 would establish a common identification standard for all federal government employees and contractors for physical and computerized systems and data access while providing a roadmap for other applications. The HSPD-12 policy establishes sound criteria for verifying an employee's identity designed to be strongly resistant to identity fraud, tampering, counterfeiting and terrorist exploitation. The standard includes graduated criteria, from least secure to most secure, to ensure flexibility in selecting the appropriate level of security for each application.
3

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STATUS REPORT TO THE COURT NUMBER TWENTY February 1, 2005 · · · Information Technology

The Interior CIO issued the Memorandum "Freezing of Patch Management Software Purchases," dated November 3, 2004, which began the process for establishing a standard solution for the deployment of patch management software. The Interior CIO issued the Memorandum "VPX Configuration Requirements," dated November 10, 2004, which established standardized bureau-to-bureau network connectivity. The BLM CIO issued Instruction Memorandum 2005-023, dated November 15, 2004, "Requirements for User Access to Automated Systems." This memorandum addresses a POA&M requirement and documents the established practice of requiring IT security awareness training prior to allowing access to BLM systems.

Certification and Accreditation: As previously reported, accreditation packages of federal agencies prepared for compliance with FISMA and A-130 vary in quality and standards of content. Interior is addressing this challenge faced by federal agencies by establishing a quantitative checklist for C&A package quality and applying it to accredited systems. This process was established by memorandum of October 20, 2004, as noted above. Although not required by FISMA or A-130, two quality assurance reviews have been conducted by qualified third parties for completed trust system C&A packages. Although some of the reviews indicated documentation of the C&A packages was sufficient, the reviews also indicated a need for improved documentation in some instances and disclosed insufficient documentation in other instances. This lack of documentation may indicate that in some cases the C&A itself was incomplete or improperly organized. While many areas in C&A packages identified for improvement have already been corrected, issues needing resolution are expected to be tracked via the POA&M process. Interior is working with bureaus and offices to supplement these supporting documents within the next two reporting periods. IT Systems Architecture: Phase 3B of the DEAR data validation and population was launched during this reporting period and is expected to be completed during the next reporting period. This phase focuses on crossmapping Interior's system inventory to the functions and activities performed by the system as defined in the OMB and Interior BRMs. The Interior BRM is an extension of the OMB BRM that details at a more granular level the functions and activities performed within Interior. This cross-mapping supports Interior's modernization blueprint analyses for determining potentially duplicative systems and systems that may benefit from integration, thus improving overall portfolio management. DOI Land and Resource Management System DLRM is being designed as a new, integrated land and natural resource management system and is currently in the requirements review stage. By memorandum dated December 14, 2004, Interior bureaus and offices were requested to review for approval the FRD for the DLRM

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STATUS REPORT TO THE COURT NUMBER TWENTY February 1, 2005 Information Technology

system. The FRD identifies the high-level functional and performance requirements that were gathered in a series of meetings with subject matter experts across Interior. Interior is moving forward on acquiring a tailored COTS system. After approval of the FRD, this project is expected to enter the acquisition phase. Leasing System Module Independent Verification and Validation An independent software assurance test of the CGI leasing software module, formerly a part of the TAAMS project, was conducted during the week of October 18, 2004. Interior contracted technical expertise in conducting IV&V testing and software assurance services. The independent contractor developed test plans for each of the leasing functions, and coordinated and conducted testing of the leasing software module viability. The test demonstrated that the leasing software module can provide an interim solution for the existing high-risk BIA legacy realty systems. The DLRM system is expected to provide a long-term solution for the legacy functionality. TrustNet During this reporting period, TrustNet, an internal secured network, was expanded as follows: · All SOL WAN segments are now routed through the ESN operations center in Herndon, VA. Final SOL connection to TrustNet was delayed to upgrade facilities for communications circuits, which is now complete. SOL expects to be operational by the end of the third quarter of FY2005. OHA's Arlington office, two field offices, and its ZANTAZ connection have been connected to Interior's ESN. OHA's remaining field offices are expected to be connected to ESN during the next reporting period.

·

Current Status Prevention and Monitoring Interior continued testing Internet-accessible systems against the SANS Top 20 vulnerability list. For the third consecutive reporting period, no hosts were found to have vulnerabilities listed in the SANS Top 20. OIG FY2004 FISMA Evaluation and Plans of Action and Milestones Interior bureaus and offices are reviewing findings identified by OIG as part of its FY2004 annual FISMA and financial audits. Bureaus and offices incorporate findings that are not already corrected into their POA&M, once those findings are validated. Those findings are expected to be resolved through the normal process of working through POA&M. Findings lacking sufficient specificity are not incorporated into POA&M.

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STATUS REPORT TO THE COURT NUMBER TWENTY February 1, 2005 Trust Network Connection Interior continued progress on ESN to consolidate departmental Internet connections, add centrally-managed network perimeter security, provide secure connectivity between bureaus and offices (Intranet) and implement 24-hour network security monitoring. BIA Live E-mail Capture On December 9, 2004, a new e-mail system administrator identified two BIA internal mail servers that were not configured properly, and as a result were not sending copies of email between or within these servers to the ZANTAZ digital safe. An investigation of the situation disclosed that mail between and within these two servers had not been sent to ZANTAZ from July to December 2004. The configuration was immediately corrected with the installation of a new version of the ZANTAZ software. BIA captured e-mail between and within the two servers during the time in question on back-up tapes. During the next reporting period, BIA expects to transfer the content of back-up tapes to ZANTAZ to ensure the digital safe has a copy of the emails that were not captured live. Reports: · Interior issued its annual Report on Performance and Accountability, Fiscal Year 2004 on November 15, 2004. This report contains a summary of FISMA findings, as well as financial system audits conducted during the second and third quarters of FY2004. The report notes that the IT-security material weakness, identified in FY2003, was downgraded to a reportable condition as a result of improvements in Interior's security position and general compliance with FISMA. The Interior OIG issued Evaluation Report: Department of the Interior's Use of Wireless Technologies, Report No. A-IN-MOA-0004-2004, December 6, 2004. This report found that "although DOI has taken some steps to control this technology, it needs to develop and implement an overall strategy to manage DOI's wireless capabilities." Information Technology

·

Delays and Obstacles There are many challenges that must be addressed regarding the integration, performance, funding, security, and data integrity of Interior IT systems. Interior initiated or completed steps to address some of the challenges reported in this and previous reporting periods. However, delays and obstacles listed here still impede progress in achieving Interior's IT management goals: Litigation · Employee fears about becoming personally implicated in the Cobell litigation are undermining creativity and decision making. This impediment has worsened within Interior as new restrictions on communication have been placed on Interior employees by the Court.

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STATUS REPORT TO THE COURT NUMBER TWENTY February 1, 2005 · Information Technology

Uncertainty over reconnection status and process is hampering progress on several IT projects that would improve efficiency and IT security.

Funding · Funding availability will continue to dictate the timing of IT-related initiatives. Interior's FY2005 budget will require managing a variety of IT-related requirements and tradeoffs. The additional resources (time, personnel, and funding) provided for IT security have limited the funding for other IT-related activities, which on occasion has adversely impacted overall systems performance.

Reengineering Effort · Interior is conducting a business process reengineering effort to standardize and streamline trust business processes. IT system specifications, design, and procurement may depend upon the timing and results of the reengineering effort and available funding.

Denied Internet Access · Several Interior bureaus and offices (BIA, OHA, OST and SOL) have not been permitted by the Court to have Internet access since December 5, 2001. Lack of Internet access impedes work processes and the ability to communicate effectively, both internally and externally. Maintaining security on internal systems is more difficult without access to the Internet for research, reporting, and patch management.

Assurance Statement I concur with the content of the information contained in the Information Technology section of the Status Report to the Court Number Twenty. The information provided in this section is accurate to the best of my knowledge. Date: February 1, 2005 Name: Signature on File W. Hord Tipton Interior Chief Information Officer

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STATUS REPORT TO THE COURT NUMBER TWENTY Februar~ 1, 2005 B. Records Management OST-OFFICE OF THE CHIEF INFORMATION OFFICER 1. Introduction The Office of Trust Records was established in 1999 to develop and implement a program for the economical and efficient management of trust records, consistent with the 1994 Act, the Federal Records Act and other statutes and implementing regulations. The OTR records management program has been developed and implemented, and continues to evolve, to ensure that necessary Indian records are maintained, records retention schedules are consistent with retention needs, and records are safeguarded throughout their life-cycles. Accomplishments and Completions American Indian Records Repository During this reporting period, approximately 10,900 indexed boxes of inactive Indian records were moved to the AIRR in Lenexa, KS, from OTR's facilities in Albuquerque, NM. Approximately 75,300 indexed boxes are located in the AIRR as of the end of this reporting period. Records Indexing Project Indexing of 97,220 boxes was completed by the end of this reporting period. Priority for the indexing of boxes of Indian records continued to be given to those boxes of records potentially responsive to tribal trust litigation, and included boxes required by OHTA for litigation discovery requests. Approximately 3,490 boxes of records were moved from BIA/OST locations and OTR to the Lenexa Annex for indexing. Once indexed, these boxes then will be stored in the AIRR. The Albuquerque portion of the indexing project concluded in November 2004, and all indexing now occurs in Lenexa. In December 2004, OTR and its contractor worked at the Southern Plains Regional Office and the Anadarko Agency to prepare and ship inactive records to Lenexa. It is anticipated that this project will conclude during the next reporting period, and approximately 1,200 boxes of inactive records will have been sent to Lenexa for indexing and subsequent storage in AIRR. Training OTR provided records management training for 40 OST-identified records contacts and provided a records management briefing for 31 OST managers during this reporting period. OTR also conducted records management training for attorneys hired by the Department of Justice, RECORDS MANAGEMENT

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STATUS REPORT TO THE COURT NUMBER TWENTY Februar~¢ 1, 2005 Records Management

Environment and Natural Resources Division, in order to familiarize them with BIA and OST records management programs. Equipment Purchases OTR provided 24 pieces of fireproof filing equipment to OST and 261 pieces to BIA programs during this reporting period. Current Status Safeguarding Records During this reporting period, the contractor assessed 283 boxes of records that were or may have been damaged or contaminated by mold, mildew, mouse droppings, or other adverse elements. It is anticipated that a written report regarding the contractor's assessment will be available early during the next reporting period. OTR expects to work with NARA on proposed remediation of damaged records where necessary. Record Keeping Requirements On October 1, 2004, tribal leaders were sent a letter with an update on the work of the Tribal/Federal Trust Records Management Work Group and asked to provide comments and suggestions on proposed language for management of fiduciary trust records that will be negotiated into the FY2006 funding agreeme, nts for compacted and contracted Tribes. On November 8, 2004, a meeting was held with tribal representatives to discuss the proposed language. Tribal representatives requested an extension through December 18, 2004, which was granted, to comment on the proposed language. Some comments have been received and are under consideration. During the next reporting period, it is anticipated that a Federal Register Notice will be published announcing tribal consultation meetings on the proposed policy. Site Assessments Site assessments are conducted to evaluate record management programs at BIA and OST offices. Ifa site assessment indicates a need for a corrective action plan, a plan is drafted by the agency and sent to OTR for review and approval. After approval, OTR monitors implementation of corrective actions. During this reporting period, OTR furnished written site assessment reports to the following BIA offices: Pawnee Agency, Southern Ute Agency, Laguna Agency, Northern Pueblos Agency, Anadarko Agency, Shawnee Agency, Horton Field Office and Southern Plains Regional Office. OTR also furnished written reports on the site assessments to the following OST offices: Pawnee Agency, Anadarko Agency, Shawnee Agency, Horton Field Office and Southern Plains Regional Office. OTR completed records management site assessments of BIA and OST programs located at the Eastern Oklahoma Regional Office, Okmulgee Agency, Talihina Agency, Osage Agency, Chickasaw Agency, Wewoka Agency and Miami Agency. In cooperation with OTRA, OTR

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STATUS REPORT TO THE COURT NUAIBER TWENTY February 1, 2005
I

Records Management

also completed records management site assessments of compacted and contracted trust programs at Creek Nation, Choctaw Nation, Chickasaw Nation, Osage Tribe and Wyandotte Tribe. Written reports are expected to be furnished to these offices during the next reporting period. Records Evaluation Some boxes of materials provided to attorneys conducting discovery for tribal trust litigation were found to contain torn documents. Thirty-one boxes were set aside by OTR for evaluation, because they were marked by the OST field office located in the BIA SWRO as containing duplicates or other non-record material. These boxes are being reviewed by OST to determine whether their contents might be federal/trust records or whether they had been properly marked as non-record duplicates. The review is expected to be completed during the next reporting period. Delays and Obstacles Lack of Internet access continues to hinder OTR's ability to provide access to the record index database for authorized users of the records. If Internet access were available, authorized researchers could conduct their searches remotely from their respective work sites and only visit OTR when necessary to inspect specific boxes. Use of the limited space in OTR facilities continued to affect OTR's daily work activities as OTR staff attempted to respond to requests f~)r boxes of records from federal attorneys, plaintiffs' tribal trust litigation attorneys and their contractors, and federal agencies and their contractors. Due to tribal trust litigation court orders and agreements regarding discovery, several thousand boxes of indexed records must remain in Albuquerque. Otherwise, these boxes could be moved to Lenexa and discovery could take place in the AIRR, a state-of-the-art archive facility. Assurance Statement I concur with the content of the information contained in the Records Management section of the Status Report to the Court Number Twenty. The information provided in this section is accurate to the best of my knowledge. Date: January 31, 2005 Name: Signature on File Ethel J. Abeita Director, Office of Trust Records Office of the Special Trustee for American Indians

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STATUS REPORT TO THE COURT NUMBER TWENTY Februarv 1. ?005 3. Introduction Interior has a continuing responsibility to provide adequate staffing, supervision and ttaining for trust fund management and accounting activities. Fiduciary trust training is essential to the success of Interior's trust reform efforts and forms an integral part of all training for Interior employees who are involved in the management of Indian trust assets. Accomplishments and Completions During this reporting period, construction began on the National Indian Programs Training Center in Albuquerque. The new training center will be managed by DOI University and is expected to develop and deliver courses to address Indian program needs at all levels and functions. The center also is expected to prepare Indian program staff in the use of technology and resources. OST expects to participate in the development and use of the new training facility. OST offered five sessions of the course, Fiduciary Overview Program, presented by Cannon Financial Institute, with 121 BIA, OST, MMS and tribal personnel attending during this reporting period. A total of 594 people have attended this course since March 2003. This course compares and contrasts the federal Indian trust administered through Interior with private sector trusts administered through banks and other financial institutions. Additional sessions are scheduled to be held during the next reporting period. During this reporting period, OST training staff conducted six sessions to provide training in TFAS, StrataVision and the historical query database to 24 OST, BIA and contractor staff. The three-day course, Trust Fundamentals, which is a comprehensive orientation program tailored to meet the needs of employees in trust-related positions, was presented to BIA and OST employees in Anchorage. This course is expected to be taught three or four times a year by regional BIA/OST employees. The New Hire Handbook for the Supervisor was published this reporting period. The handbook is expected to be distributed to all BIA and OST supervisors during the next reporting period. OST received the CD version of the course, Responsibilities for Indian Trust Assets (Fiduciary Trust Foundations: An Introduction to Trust Reform and Change). The CD is included in the new hire handbook. Current Status As previously reported, OST developed a three-week orientation program for OST regional trust administrators, trust officers, BIA superintendents and deputy superintendents for trust. During T:~ -~" ~,- ~i,hlci~ rv Trust Train~n- Pro,~ ...... INDIAN FIDUCIARY TRUST TRAINING PROGRAM

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STATUS REPORT TO THE COURT NU31BER TWENTY February 1, 2005 ]~;d]~n Fiduciary Trust Trainin~ Prc~-.;-m

this reporting period, 32 OST and BIA staff completed this program. Currently, 34 staff members are enrolled in the program. Cannon personnel presented the Fiduciary Behavior, Guardianship and Asset Management specialty courses to 35 OST t~-c~st officers. These three cour~c5 c~,~,_Zc :I~c ia~tial implementation of the previously reported certification program. Recommendations for improvements to training identified in the Training Inventory and Identification of Critical Functional Training Areas for the Department of the Interior's Indian Trust Training Program continue to be reviewed for course development in conjunction with implementation of the FTM. Delays and Obstacles The lack of Internet access inhibits electronic communication with other governmental agencies and contractors, hinders the research of training tools and potential contractors, and restricts OST's ability to access online training programs. Assurance Statement I concur with the content of the information contained in the Indian Fiduciary Trust Training Program section of the Status Report to the Court Number Twenty. The information provided in this section is accurate to the best of my knowledge. Date: January 25, 2005 Name: Signature on File Dianne M. Moran Director, Trust Training Office of the Special Trustee for American Indians

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Exhibit 21

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Status Report to the Court Number Twenty-One
For the Period January 1, 2005 through March 31, 2005

May 2, 2005

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STATUS REPORT TO THE COURT NUMBER TWENTY-ONE Ma~ 2, 2005

TABLE OF CONTENTS
It

INTRODUCTION ............................................................................................................. SECRETARY GALE NORTON'S OBSERVATIONS ................................... A. B.

1

II.

. ............. 2 4 11 14

INFORMATION TECHNOLOGY ................................................................................. CADASTRAL SURVEY ................................................................................................

C. MINERALS MANAGEMENT SERVICE ................................................................... D. OFFICE OF HISTORICAL TRUST ACCOUNTING ..................................... III.

. ......... 16 25 27 29 29 33 33 36 39 41 42 44 44 47 47 52 52 55 58 60

OFFICE OF THE SPECIAL TRUSTEE FOR AMERICAN INDIANS ...................

A. TRUST REVIEW AND AUDIT .................................................................................... B. 1. C. 1. 2.
3.

OST-OFFICE OF THE CHIEF INFORMATION OFFICER ................................... RECORDS MANAGEMENT .................................................................................... TRUST ACCOUNTABILITY ....................................................................................... TRUST BUSINESS PROCESS MODELING .......................................................... TRUST DATA QUALITY AND INTEGRITY ........................................................ INDIAN FIDUCIARY TRUST TRAINING PROGRAM ...................................... RISK MANAGEMENT ............................................................................................... REGIYLATIONS, POLICIES AuND PROCEDURES ..............................................

4. 5.

D. FIELD OPERATIONS .................................................................................................... 1. APPRAISAL .................................................................................................................

E. TRUST SERVICES ........................................................................................................ 1. CURRENT ACCOUNTING ACTIVITIES ............................................................. IV. BUREAU OF INDIAN AFFAIRS .................................................................................

A. TRUST REGULATIONS, POLICIES AND PROCEDURES ................................... B. C. FRACTIONATION ........................................................................................................ PROBATE .......................................................................................................................

ACRONYMS AND ABBREVIATIONS ...................................................................................

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STATUS REPORT TO THE COURT NUMBER TWENTY-ONE May 2, 2005 A. Introduction This section describes the status of Interior IT systems, particularly the systems that house or provide access to IITD or provide various computing capabilities, including functions critical to th