[Final Report, “Evaluation of the Bureau of Indian Affairs’ Process to Approve Tribal Gaming Revenue Allocation Plans"]
[From the U.S. Government Printing Office, www.gpo.gov]
Report No. 2003-I-0055
Title: Final Report, �Evaluation of the Bureau of Indian Affairs�
Process to Approve Tribal Gaming Revenue Allocation Plans�
June 11, 2003
Memorandum
To: Aurene M. Martin
Acting Assistant Secretary for Indian Affairs
From: William J. Dolan, Jr.
Regional Audit Manager, Eastern Region
Subject: Final Report, �Evaluation of the Bureau of Indian Affairs� Process to
Approve Tribal
Gaming Revenue Allocation Plans� (No. 2003-I-0055)
At the request of the Secretary, we evaluated the process the Bureau of Indian
Affairs (BIA)
uses to review and approve Revenue Allocation Plans (plans) submitted by Indian
tribes participating
in gaming operations.
BIA reviews the plans to ensure that tribes distribute gaming revenues
responsibly. In
accordance with the Indian Gaming Regulatory Act (IGRA), tribes are expected to
distribute earnings
to promote �tribal economic development, self sufficiency, and strong tribal
governments� - the
purpose of IGRA. Tribes must have a plan approved by the Secretary if they
intend to distribute
gaming revenues to tribal members - known as per capita payments.
We concluded that BIA�s approval process contained weaknesses and
inconsistencies, such as:
BIA did not consistently determine whether tribes reserved adequate amounts of
gaming
profits for tribal government programs and economic development projects.
BIA did not consistently document deliberations made during the review
process.
We made three recommendations to improve BIA�s approval process.
Our evaluation also found that no one monitors tribal compliance with or
systematically
enforces against non-compliance with approved plans. Although BIA reviews and
approves
plans, it does not have the authority to ensure that tribes actually comply with
the terms of these
plans. The National Indian Gaming Commission (NIGC), under authority given to it
by IGRA,
may monitor tribal compliance with approved plans and impose civil penalties
against a tribe for
making per capita payments that are not in compliance with an approved plan. The
NIGC,
however, does not have a mechanism for systematic monitoring of revenue
distributions to
�ext Box: United States Department of the Interior
Office of Inspector General
Eastern Region Audits
381 Elden Street
Sui�ext Box: E-EV-BIA-0071-2002
enable identification of instances of noncompliance. Our report presents three
options for the
Department to consider to address the lack of monitoring.
We received responses to the draft report from the Acting Assistant Secretary
for Indian
Affairs, with an attached memorandum from the Office of the Solicitor (Appendix
3) and from
the Acting Chief of Staff for the National Indian Gaming Commission (Appendix
4). Based on
the responses, we revised the report as appropriate and included additional
information regarding
the role of NIGC. Based on the response from the Acting Assistant Secretary, we
consider the
recommendations resolved but not implemented. (Appendix 5)
Since the report�s recommendations are resolved, no further response to the
Office of
Inspector General is required. We would, however, appreciate being informed of
any action
taken to establish a process to monitor revenue allocation plans.
The legislation, as amended, creating the Office of Inspector General requires
that we
report to Congress semiannually on all reports issued, actions taken to
implement our
recommendations, and recommendations that have not been implemented.
If you have any questions, please do not hesitate to contact me at (703) 487-
8011.
cc: Deputy Commissioner for Indian Affairs
Director, Office of Audits and Evaluation
Director, Office of Indian Gaming Management
Executive Director, National Indian Gaming Commission
TABLE OF CONTENTS
Page
Background......................................................................
..............1
History of Indian Gaming
...........................................................1
Legislation.....................................................................
..............2
Regulations
................................................................................
.2
Review and Approval of
Plans......................................................3
Process for
Approval..................................................................3
Weaknesses in
Process...............................................................4
Recommendations
..........................................................................5
Monitoring Indian Tribal Compliance ........................................7
Summary of Responses to the Draft Report................................7
Acting Assistant Secretary for Indian Affairs.............................7
National Indian Gaming Commission ........................................8
Office of Inspector General Reply..............................................8
Options for the Department of the Interior Regarding
Revenue Allocation
Plans........................................................9
Objective, Scope and Methodology ............................................11
Appendices
Appendix 1: Indian Gaming Regulatory Act Provisions ........13
Appendix 2: Revenue Allocation Plans ..................................17
Appendix 3: BIA Response ....................................................19
Appendix 4: NIGC Response..................................................23
Appendix 5: Status of Recommendations...............................25
This Page Intentionally Left Blank
BACKGROUND
History of Indian Gaming
Indian gaming began in the late 1970s when the Seminole tribe of Florida opened
a high
stakes bingo hall. As more tribes began to engage in gaming operations, states
began filing
lawsuits opposing tribal gaming. However, the Supreme Court in California v.
Cabazon Band of
Mission Indians1 (in 1987) ruled that where state law did not expressly prohibit
a type of
gambling, tribes could offer gaming under their own regulatory scheme.
In October 1988, Congress passed the Indian Gaming Regulatory Act2 (IGRA or
Act).
Provisions of the Act that address Indian tribal per capita payments and
selected authority of the
NIGC are presented in Appendix 1. Congress intended the Act to establish (1) a
statutory basis
for operating and regulating tribal gaming, (2) Federal standards for gaming
operations on Indian
lands, and (3) the National Indian Gaming Commission (NIGC) as the Federal
regulatory
authority responsible for overseeing the Indian Gaming Industry.
Gaming has become an important source of income for many tribes. Tribal gaming
revenues have steadily increased from about $7.5 billion in 1997 to $12.7
billion in 2001, as
illustrated in the following chart:
1 480 U.S. 202 (1987).
2 25 U.S.C. �� 2701-2721 (1988) Legislation
IGRA requires that the Bureau of Indian Affairs (BIA), through authority
delegated by
the Secretary of the Interior, review and approve Revenue Allocation Plans.
These plans must
detail how tribes intend to allocate profits to fund one or more of the
following:
Tribal government operations or programs.
The general welfare of the tribe and its members (which includes payments to
individual
tribe members � per capita payments).
Tribal economic development.
Charitable organizations or operations of local government agencies.
Only tribes that use profits to make per capita payments are required to submit
these
plans. Tribes that use earnings solely for government, economic, and charitable
purposes are not
required to submit plans because the Act assumes that all funds are directed
toward these areas,
promoting tribal government and self-sufficiency.
IGRA3 also authorizes the NIGC to approve all tribal gaming ordinances including
those
regarding the use of gaming revenues pursuant to an approved revenue allocation
plan. Since the
approved gaming ordinance identifies the authorized uses of any gaming revenue,
we believe
that NIGC can impose civil penalties against tribes for making per capita
payments that violate
the approved plan or making per capita payments without an approved plan.
Regulations
In March 2000, BIA issued formal regulations4 for tribes to follow when
preparing their
allocation plans. Tribes must include:
A percentage breakdown of how profits will be distributed.
Information showing that the plan complies with IGRA.
Provisions to protect the interests of minors and other legally incompetent
persons.
A mechanism to notify tribal members of tax liabilities for per capita
payments.
The regulations do not require tribes to submit information to BIA showing
actual
distributions of gaming profits.
3 25 U.S.C. � 2710
4 25 CFR 290.4
REVIEW AND APPROVAL OF PLANS
Process for Approval
The distribution plan approval process was centralized in the Office of Indian
Gaming
Management (OIGM), an entity within BIA, in 1999. As shown below, Indian tribes
submit
plans to OIGM through their Agency Superintendents or Regional Directors for
review. OIGM
analyzes the plan, obtains a legal review by the Solicitor and forwards it to
the Deputy
Commissioner of Indian Affairs for approval.
Note: According to the OIGM, some Revenue Allocation Plans are submitted by the
Agency Superintendent while
other plans are submitted through the Regional Director because some Regions do
not have designated staff to
conduct these reviews.
OIGM does not systematically review every tribe�s proposed use of net gaming
revenues
and, therefore, does not assess the adequacy of profit distribution. OIGM
officials examine a
tribe�s financial health5 only when a tribe proposes to use 50 percent or more
of its earnings for
per capita payments. OIGM has not, however, established standards for measuring
a tribe�s
financial health when evaluating proposed distribution of profits. The
Solicitor�s Office
�ext Box:
5 A review of sufficient depth is needed to determine whether the plan reserves
enough revenue for funding
government operations and programs, providing for the �general welfare� of the
tribe or its members, promoting
economic development, donating to charitable organizations, or helping to fund
local government operations. (Solicitor) reviews the plans to ensure that they
comply with IGRA, but the Solicitor does not
perform an assessment of the tribe�s financial health.
After OIGM and the Solicitor review a plan, the Deputy Commissioner signs either
a
letter of approval or a written notice informing the tribe why the plan does not
conform to the
regulations and how to bring the plan into compliance. The BIA will work
informally with tribes
to modify plans to obtain approval.
If a tribe decides to change how it distributes gaming profits, the tribe must
submit an
amendment to the existing plan to BIA for approval. After BIA approves a plan,
however, it
does not monitor tribal compliance nor does it have the authority to enforce
penalties if a tribe
does not comply.
As of December 2001, of 207 Indian tribes that conducted gaming operations,
75 submitted gaming-profit distribution plans, acknowledging that they intend to
use a portion of
their earnings for per capita payments (Appendix 2 contains a list of these
tribes). However, BIA
has no assurance that it knows the actual number of tribes making per capita
payments. Tribes
submit plans at their own will, and BIA has no way of ensuring that all tribes
making per capita
payments actually submit plans.
Weaknesses in Process
BIA�s process for reviewing and approving Revenue Allocation Plans is not
consistently
performed and contains flaws.
Assessing a tribe�s economic health
BIA is required, by regulation, to determine whether plans reserve adequate
amounts of
money to fund tribal government programs and economic development. However, BIA
does not
effectively make this determination because it does not require sufficient
information about a
tribe�s financial condition. BIA only requests additional information when a
tribe intends to use
over 50 percent of its earnings for per capita payments. In order to make an
accurate assessment
of each tribe�s financial conditions, BIA needs to secure adequate financial
information from all
tribes seeking per capita distribution plan approval.
There were 75 plans submitted to BIA for approval through September 2002, 73 of
which
were approved. Of the 73 approved plans, only 24 contained any information that
might assist in
evaluating a tribe�s economic health. Of these 24, only 5 provided comparative
information
about gaming profits, tribal enrollment levels, and tribal operations budgets �
all of which are
essential for a reasoned evaluation of a tribe�s economic health.
During our evaluation, however, we did find an excellent example of a plan that
provided
BIA with sufficient information for approval. One Michigan tribe provided BIA
with historical
and projected tribal enrollment; gaming revenues; tribal budgets; historical and
projected tribal
services provided; other potential sources of tribal revenue; balances,
earnings, and projected earnings from capital investment reserve accounts; and
capacity of gaming operations and other
related facilities. This allowed BIA to adequately evaluate the proposed
distribution of earnings.
Documenting the deliberative process
BIA did not always document its deliberative process for reviewing and approving
plans.
During the review process, BIA did not use checklists to ensure that plans met
all regulatory
requirements nor did it consistently maintain records containing reasons for
approving a plan.
For example, an Idaho tribe�s file contained only the tribal ordinance and BIA�s
approval
letter. Neither of these documents indicated that BIA had performed a
substantive review of the
plan.
In addition, we found that BIA did not:
Have a tracking system in place to document when a plan was received,
reviewed, and approved, or when a tribe was contacted about issues regarding
its plan.
Document standard operating procedures.
RECOMMENDATIONS
We recommend that the Assistant Secretary for Indian Affairs improve its
approval
process by:
1. Amending the applicable regulations to require tribes to submit sufficient
financial information, modeled after the Michigan tribe, including: historical
and projected tribal enrollment; gaming revenues; tribal budgets; historical
and projected tribal services provided; other potential sources of tribal
revenue; balances, earnings, and projected earnings from capital investment
reserve accounts; and capacity of gaming operations and other related
facilities.
2. Developing and publishing a standard to determine what is �adequate�
funding for each tribe�s government and economic development programs.
3. Developing and producing written operating procedures for reviewing plans,
including forms, surnames, documentation of tribal contacts, modifications to
plans, and final disposition of plans.
This Page Intentionally Left Blank
�ext Box: United States Department of the Interior
Office of Inspector General
Eastern Region Audits
381 Elden Street
Sui
MONITORING INDIAN TRIBAL
COMPLIANCE WITH PLANS
Neither the BIA nor the NIGC is monitoring Indian tribes to determine whether
tribes
comply with approved revenue allocation plans or whether tribes are making per
capita
distributions of gaming revenues without an approved plan. IGRA does not
specifically provide
the BIA a mechanism to ensure that tribes making per capita payments actually
submit plans or
make payments in compliance with approved plans. While IGRA does provide the
NIGC
authority to enforce Indian tribal compliance with the requirements of the Act,
including the
revenue allocation plan requirements, NIGC does not have a mechanism for
monitoring revenue
distributions.
An example of problems that can occur when tribes make per capita payments
without
approved plans is found in a U.S. District Court case.6 A South Dakota tribe had
made per capita
payments to tribal members without a distribution plan approved by the Secretary
(or BIA).
Several members who were excluded from the payments filed suit against the
tribe. The court
ruled that all of the tribe�s gaming profits be held until the Secretary
approved a plan, which
prevented the tribe from using gaming profits for government projects and
economic
development, as well as per capita payments.
Without a process for systematic monitoring of tribal revenue distributions, the
Secretary�s approval of the plan serves little practical purpose. The approval
process is one of
voluntary self-compliance.
SUMMARY OF RESPONSES TO THE DRAFT REPORT
Acting Assistant Secretary for Indian Affairs Response
The March 25, 2003, response agreed with the three recommendations. It stated
that
proposed amendments to the regulations requiring tribes to submit sufficient
financial
information would be developed within 60 days of publication of the final
report, that a standard
to determine what is adequate funding for tribal government and economic
development
programs would be formulated in conjunction with the proposed amendment, and
that operating
procedures for reviewing plans would be prepared pursuant to completion of the
other two
actions. In response to a suggestion in our draft report that consideration be
given to amending
IGRA to give the Secretary of the Interior authority to enforce compliance with
approved plans,
the response stated that such an amendment may not be necessary because �the
National Indian
Gaming Commission (NIGC) already has the authority to enforce compliance with
provisions of
IGRA.� and that �BIA would not have the financial resources to monitor
compliance� if
provided the statutory authority to do so. Finally, the response requested that
the �Related
Matters� section of the report referring to media coverage and future
evaluations be deleted from
the final report.
Ross v. Flandreau Santee Sioux Tribe, 809 F. Supp. 738 (1992). Attached to the
response from the Acting Assistant Secretary for Indian Affairs was a
January 30, 2003, memorandum from an Attorney-Advisory in the Office of the
Solicitor to the
Director, Office of Indian Gaming Management. The January 30, 2003, memorandum
stated
that the Secretary �might consider seeking an amendment to IGRA in order to
clarify her
authority to monitor tribal compliance or enforce against non-compliance with
RAPs [Revenue
Allocation Plans]. If so, the regulations could be amended to require tribes to
submit proof of
actual distribution of gaming profits.� The memorandum stated further that all
�tribes who
dispense per cap payments are required to submit a RAP . . . if they don�t the
regulation states
that �[I]f you refuse to comply, the DOJ or NIGC may enforce this requirement�.�
In addition,
the memorandum clarified that the Office of the Solicitor does not perform an
assessment of a
tribe�s financial health when it reviews proposed plans and amendments.
National Indian Gaming Commission�s Response
In a March 10, 2003, response, the National Indian Gaming Commission�s Acting
Chief
of Staff stated, �the report should more fully describe the potential
involvement of the National
Indian Gaming Commission�s oversight of revenue allocation plans.� In that
regard, the
response noted that while NIGC has civil enforcement authority against
noncompliant tribes, it
does �not have a mechanism for systematic monitoring of revenue distributions.�
The Acting
Chief of Staff also stated the Secretary �is in the best position to interpret
an approved RAP and
make a determination as to whether or not a particular distribution complies
with the plan.� The
Acting Chief of Staff added that �the Department may wish to consider
instituting a reporting
requirement to facilitate monitoring� and that NIGC is willing to discuss a
cooperative
arrangement for pursuing cases of misuse of gaming revenue identified by the
Department.
Office of Inspector General�s Reply
Based on the responses, we modified the report as appropriate. In particular, we
added to
the report information about NIGC�s authority to monitor compliance with the Act
and removed
the suggestion that consideration be given to seeking an amendment to the Act.
We also
changed the report to address the technical issues raised by BIA regarding the
definition of net
revenues, the approval process, the role of the Solicitor, and amendments to
approved revenue
allocation plans.
Regarding the NIGC�s comments, the scope of this assignment was the processes
and
functions used by the BIA in reviewing and approving plans. We agree that IGRA
provides
NIGC and DOJ the authority to enforce the requirements pertaining to revenue
allocation plans.
We believe, however, that the enforcement authority is not supported by
systematic mechanism
for monitoring compliance and therefore is not effectively exercised.
OPTIONS FOR THE DEPARTMENT OF THE INTERIOR REGARDING
REVENUE ALLOCATION PLANS
As concluded in this report, currently there is a requirement that tribes submit
revenue allocation plans
for review and approval, without a systematic mechanism for monitoring
compliance to this
requirement. Based on our review of the responses to the draft evaluation
report, we submit the
following options to address this issue. In consultation with gaming tribes the
Department could:
1. Enter into an agreement with NIGC to implement an oversight process for
tribal
compliance with revenue allocation plan requirements. This would require the
Department to identify a source of funding for the agreement because the NIGC
Chairman advised us that NIGC currently lacks the resources to finance this
process. The
Chairman also said that it is NIGC�s policy to consult with tribes before
considering an
effort such as this.
2. Require all gaming tribes to submit an annual independent audit report to the
Secretary.
The audit would determine whether a tribe made per capita payments and, if so,
complied
with an approved revenue allocation plan. Currently, gaming tribes that receive
Federal
financial assistance for the operation of Indian programs have two audit
reporting
requirements: (1) an annual independent audit of the financial statements of
each gaming
operation is required (25 CFR 571.13) to be submitted to NIGC and (2) an annual
or
biennial audit of a tribe�s financial statements and a schedule of its Federal
assistance is
required (Office of Management and Budget Circular A-133) to be submitted to the
cognizant Federal audit agency. It may be possible to incorporate into the scope
of one
of these audits a review of tribal compliance with revenue allocation plan
requirements.
3. Seek relief from the requirement for the submission and approval of tribal
gaming
revenue allocation plans.
Future Evaluations
We have tentatively identified a number of other areas in which IGRA fails to
confer to
the Secretary the requisite authority to meet the Department�s responsibilities
under the Act. We
are undertaking further evaluations to clearly identify the gaps in authority
that prevent the
Secretary from carrying out her responsibilities most effectively and ensuring
that the intent of
the statute is met. We will issue a comprehensive report with recommendations
when those
evaluations are completed.
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OBJECTIVE, SCOPE, AND METHODOLOGY
Our objective was to determine whether BIA�s approval process ensures that
Revenue
Allocation Plans fulfill the purposes of the Indian Gaming Regulatory Act. This
evaluation was
performed in response to a request from the Secretary. We reviewed BIA�s
processes and
procedures used to review and approve plans. We also interviewed officials from
the BIA�s
Office of Indian Gaming Management, the Solicitor�s Office, the National Indian
Gaming
Commission, and the National Indian Gaming Association. In addition, we analyzed
statistics
regarding tribal gaming and per capita distributions, and we reviewed about
6,235 pages of
documents containing BIA Revenue Allocation Plan files. We did not obtain
information
directly from the tribes or review tribal accounting records to determine actual
payments made.
We conducted our evaluation in accordance with the President�s Council on
Integrity and
Efficiency�s Quality Standards for Inspections. Accordingly, we conducted tests
and reviews of
records that we considered necessary under the circumstances.
Neither the OIG nor the General Accounting Office has issued public reports
within the
last five years addressing the BIA�s administration of Revenue Allocation Plans.
This Page Intentionally Left Blank
Indian Gaming Regulatory Act
Provisions Addressing Tribal Per Capita Payments
From Net Gaming Revenues
(25 USC �� 2710, 2713)
Note: Sections (a) through (b)(1) of 25 USC � 2710, were omitted by the OIG as
not
applicable to the subject of this report.
Section 2710 Tribal Gaming Ordinances
(b)(2) The Chairman [of the National Indian Gaming Commission] shall approve any
tribal
ordinance or resolution concerning the conduct or regulation of class II gaming
on the Indian
lands within the tribe�s jurisdiction if such ordinance or resolution provides
that-
Section (A) omitted.
(B) Net revenues from any tribal gaming are not to be used for purposes other
than:
(i) To fund tribal government operations or programs;
(ii) To provide for the general welfare of the Indian tribe and its members;
(iii) To promote tribal economic development;
(iv) To donate to charitable organizations; or
(v) To help fund operations of local government agencies;
Sections (C) through (F)(ii)(III) omitted
(3) Net revenues from any class II gaming activities conducted or licensed by
any Indian tribe
may be used to make per capita payments to members of the Indian tribe only if:
(A) The Indian tribe has prepared a plan to allocate revenues to uses authorized
by
paragraph (2)(B);
(B) The plan is approved by the Secretary as adequate, particularly with respect
to uses
described in clause (i) or (iii) of paragraph (2)(B);
(C) The interests of minors and other legally incompetent persons who are
entitled to receive
any of the per capita payments are protected and preserved and the per capita
payments
are disbursed to the parents or legal guardian of such minors or legal
incompetents in
such amounts as may be necessary for the health, education, or welfare, of the
minor or
other legally incompetent person under a plan approved by the Secretary and the
governing body of the Indian tribe; and
(D) The per capita payments are subject to Federal taxation and tribes notify
members of
such tax liability when payments are made.
�ext Box: Appendix 1
Page 1 of 3
Sections (4) (A) through (c) omitted.
(d)(1) Class III gaming activities shall be lawful on Indian lands only if such
activities are-
(A) authorized by ordinance or resolution that �
(i) is adopted by the governing body of the Indian tribe having
jurisdiction over such lands,
(ii) meets the requirements of subsection (b) of this section, and
(iii) is approved by the Chairman
Section 2713 � Civil Penalties
(a) Authority; amount; appeal; written complaint
(1) Subject to such regulations as may be prescribed by the Commission, the
Chairman shall have authority to levy and collect appropriate civil fines, not
to
exceed $25,000 per violation, against the tribal operator of an Indian game or a
management contractor engaged in gaming for any violation of any provision of
this chapter, any regulation prescribed by the Commission pursuant to this
chapter, or tribal regulations, ordinances, or resolutions approved under
section
2710 or 2712 of this title.
(2) The Commission shall, by regulation, provide an opportunity for an appeal
and
hearing before the Commission on fines levied and collected by the Chairman.
(3) Whenever the Commission has reason to believe that the tribal operator of an
Indian game or a management contractor is engaged in activities regulated by
this
chapter, by regulations prescribed under this chapter, or by tribal regulations,
ordinances, or resolutions, approved under section 2710 or 2712 of this title,
that
may result in the imposition of a fine under subsection (a)(1) of this section,
the
permanent closure of such game, or the modification or termination of any
management contract, the Commission shall provide such tribal operator or
management contractor with a written complaint stating the acts or omissions
which form the basis for such belief and the action or choice of action being
considered by the Commission. The allegation shall be set forth in common and
concise language and must specify the statutory or regulatory provisions alleged
to have been violated, but may not consist merely of allegations stated in
statutory
or regulatory language.
(b) Temporary closure; hearing
(1) The Chairman shall have power to order temporary closure of an Indian game
for
substantial violation of the provisions of this chapter, of regulations
prescribed by
�ext Box: Appendix 1
Page 2 of 3
the Commission pursuant to this chapter, or of tribal regulations, ordinances,
or
resolutions approved under section 2710 or 2712 of this title.
(2) Not later than thirty days after the issuance by the Chairman of an order of
temporary closure, the Indian tribe or management contractor involved shall have
a
right to a hearing before the Commission to determine whether such order should
be made permanent or dissolved. Not later than sixty days following such
hearing,
the Commission shall, by a vote of not less than two of its members, decide
whether to order a permanent closure of the gaming operation.
(c) Appeal from final decision
A decision of the Commission to give final approval of a fine levied by the
Chairman or
to order a permanent closure pursuant to this section shall be appealable to the
appropriate Federal district court pursuant to chapter 7 of title 5.
(d) Regulatory authority under tribal law
Nothing in this chapter precludes an Indian tribe from exercising regulatory
authority
provided under tribal law over a gaming establishment within the Indian tribe's
jurisdiction if such regulation is not inconsistent with this chapter or with
any rules or
regulations adopted by the Commission.
�ext Box: Appendix 1
Page 3 of 3
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Revenue Allocation Plans Submitted to BIA
As of September 2002
Approved
Plans Tribe
Date of Last
Action
1 Absentee Shawnee of Oklahoma 29-Aug-00
2 Agua Caliente Band of Cahuilla Indians of California 11-Jan-02
3 Alturas Rancheria of California 5-Mar-02
4 Barona Band of Mission Indians of California 28-Dec-00
5 Berry Creek Rancheria of California 14-Feb-01
6 Big Sandy Rancheria of California 24-Jul-01
7 Big Valley Rancheria of California 27-Sep-01
8 Cahuilla Band of California 19-Mar-02
9 Chitimacha Tribe of Louisiana 3-Nov-98
10 Coeur d' Alene Tribe of Idaho 21-Mar-01
11 Colorado River Indian Tribe of Arizona 30-Jun-97
12 Coushatta Tribe of Louisiana 14-Apr-95
13 Cow Creek Band of the Umpqua Tribe of Oregon 29-Nov-00
14 Coyote Valley Tribe of California 19-Sep-95
15 Eastern Band of Cherokee Indians of North Carolina 10-Aug-01
16 Elk Valley Rancheria of California 9-Jan-01
17 Flandreau Sioux Tribe of South Dakota 29-Apr-99
18 Fond du Lac of Minnesota 23-Nov-01
19 Forest County Potawatomi of Wisconsin 10-Aug-01
20 Fort McDowell Mohave-Apache Indian Community of Arizona 27-Oct-98
21 Grand Ronde Community of Oregon 9-Nov-99
22 Grand Traverse Band of Michigan 2-Jun-00
23 Ho Chunk Nation of Wisconsin 11-Jan-02
24 Hopland Rancheria of California 1-Oct-97
25 Jackson Rancheria of California 19-Dec-95
26 Kalispel Tribe of Washington 11-Jan-02
27 Kickapoo Tribe of Kansas 24-Jul-01
28 Kootenai Tribe of Idaho 30-May-01
29 Lac du Flambeau Tribe of Wisconsin 26-Jun-00
30 Lac Vieux Desert Band of Michigan 14-Dec-94
31 Little Traverse Bay Bands of Michigan 11-Jan-02
32 Lower Sioux Indian Community of Minnesota 18-Jan-02
33 Menominee Tribe of Wisconsin 9-Dec-94
34 Middletown Rancheria Tribe of Pomo Indians of California 18-Dec-97
35 Mille Lacs Band of Minnesota 17-Dec-01
36 Mississippi Band of Choctaw Indians of Mississippi 19-Jun-96
37 Mohegan Tribe of Indians of Connecticut 16-Jul-01
38 Morongo Band of Cahuilla Mission Indians of California 4-Oct-96
39 Muckleshoot Indian Tribe of Washington 28-Dec-00
40 Oneida Tribe of Wisconsin 25-Jul-01
�ext Box: Appendix 2
Page 1 of 2
41 Pala Band of California 10-Aug-01
42 Pauma Band of California 1-Apr-02
43 Prairie Island Indian Community of Minnesota 7-Aug-96
44 Puyallup 10-Apr-98
45 Quechan Tribe of Arizona 18-Oct-00
46 Redding Rancheria of Pomo Indians of California 21-Oct-94
47 Robinson Rancheria of Pomo Indians of California 30-Jun-98
48 Rumsey Rancheria of Wintun Indians of California 19-Dec-95
49 Sac and Fox Nation of the Mississippi of Iowa 30-May-95
50 Sac and Fox Nation of Oklahoma 13-May-97
51 Saginaw Chippewa Tribe of Michigan 28-Mar-01
52 Salt River Pima Maricopa of Arizona 10-Oct-01
53 Santa Rosa Indian Community of California 15-Aug-00
54 Santa Ynez Band of Chumash Mission Indians of California 16-May-95
55 Seminole Tribe of Florida 18-Aug-93
56 Shakopee Mdewakanton Sioux Community of Minnesota 12-Nov-93
57 Sherwood Valley Rancheria of California 27-Jul-98
58 Shoshone-Bannock Tribes of Idaho 11-Jan-02
59 Siletz Tribe of Oregon 20-Nov-01
60 Sokaogon Chippewa Tribe of Wisconsin 15-Aug-94
61 Squaxin Island Tribe of Washington 14-Dec-01
62 St. Croix Tribe of Wisconsin 7-Jan-98
63 Stockbridge Munsee Tribe of Wisconsin 25-May-01
64 Table Mountain Rancheria of California 19-Dec-95
65 Tohono O'odham Nation of Arizona 25-Oct-00
66 Tonto Apache Tribe of Arizona 9-Aug-01
67 Tunica Biloxi Indians of Louisiana 14-Apr-94
68 Umatilla Tribe of Oregon 22-Nov-00
69 Upper Sioux Tribe of Minnesota 26-Jun-96
70 Viejas Band of Mission Indians of California 18-Dec-95
71 Winnebago Tribe of Nebraska 14-Jan-94
72 Yavapai Prescott Tribe of Arizona 12-Sep-95
73 Yselta del Sur 2-Jul-97
Subtotal of Approved Plans: 73
Denied Plans
1 Chicken Ranch 30-Nov-00
2 San Pasqual Band 5-Oct-01
Subtotal of Denied Plans: 2
Total Plans: 75
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Appendix 5
Status of Recommendations
Recommendation Status Action Required
1 through 3
Resolved; not
implemented
No further response to the Office of
Inspector General is necessary. The
recommendations will be referred to
the Assistant Secretary for Policy,
Management and Budget for
tracking of implementation.
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