[Final Audit Report on Improvements Needed in the Bureau of Indian Affairs Process for Conducting Background Investigations of Indian Education Employees]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. C-IN-BIA-0014-2004

Title: Final Audit Report on Improvements Needed in the Bureau
       of Indian Affairs Process for Conducting Background Investigations
       of Indian Education Employees

  

Date:  March 5, 2004

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Please refer to Memorandum dated March 5, 2004 on PDF file.


Subject: Final Audit Report on Improvements Needed in the Bureau of Indian Affairs Process for Conducting Background Investigations of Indian Education Employees (No. C-IN-BIA-0014-2004)

Attached is our final report.
 
EXECUTIVE SUMMARY

Introduction


We audited the Bureau of Indian Affairs (BIA) education employee background investigation process.  Our objective was to determine whether BIAï¿½s process prevents the hiring and retaining of individuals with unsuitable backgrounds for positions having regular contact with or control over Indian children.   

Prior to our audit, BIA had moved the background investigation process into a newly created Office of Indian Education Security Services (Security Office) within the BIAï¿½s Office of Indian Education Programs (OIEP).  To improve the background investigation process, the new Security Office has:

> Provided training to local school officials regarding preparing preliminary security packages.

> Dramatically reduced the backlog of personnel security files awaiting final determination.

> Worked with the Office of Personnel Management (OPM) to obtain the results of Federal Bureau of Investigations (FBI) fingerprint and name checks (FBI checks) in much less time than it previously took.

> Begun a process to identify employees without required background investigations.

Results in Brief
We found, however, that the pre-screening process still allows potentially unsuitable persons to be hired.  Further, the process does not ensure that the employment of unsuitable individuals is terminated in a timely manner.  We concluded that BIAï¿½s background investigation process is not sufficient to prevent Indian children from potentially being in danger.  For example:

> One year and five months after a home living assistant at a school dormitory in New Mexico was hired a local law enforcement inquiry was completed.  It identified 26 offenses for this individual including battery and endangering the welfare of a minor.  This individual was subsequently removed from this position.  The new process still relies on local school officials to initiate the local law enforcement inquiries.

> Seven months after an education aide in New Mexico was hired, the FBI check for this aide was completed.  The FBI check revealed a battery and child endangerment conviction.  The education aideï¿½s employment at the school was subsequently terminated.  The new process still allows applicants to be hired before completion of the FBI check.

> A school secretary in New Mexico convicted of voluntary manslaughter and aggravated assault had a final unsuitable determination in November 2001 but remained employed for about nine months until a final resolution in August 2002.

Recommendations
We are recommending that BIA take steps to strengthen its pre-screening process and improve accountability over the complete process.  In all, we made five recommendations.

BIA Actions
Based on our audit, the Office of Indian Education Security Services is taking steps to improve the background screening process.  These steps include:

> Amending its procedures and submitting fingerprint charts to the Office of Personnel Management as soon as the security package is received, rather than waiting until the security package has been reviewed and is properly complete.

> Entering into a Memorandum of Understanding with the Office of Personnel Management to conduct child-care investigations which include checks of all relevant state criminal history repositories.

> Monitoring completion of pre-employment screening.

> Eliminating a large backlog of incomplete background investigations.

> Reconciling Federal Personnel Payroll System records of current employees to the background investigations log on a monthly basis.

> Developing and delivering needed training to various personnel.

> Meeting with the Deputy Director, OIEP, on a weekly basis to keep him informed of security issues.

> Receiving and reconciling monthly reports of new appointments and terminations for all OIEP schools and the OIEP Central Office. 

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INTRODUCTION


This report presents the results of our audit of the Bureau of Indian Affairsï¿½ (BIA) Office of Indian Education Programsï¿½ (OIEP) employee background investigation process.  Our objective was to determine whether BIAï¿½s process prevents the hiring and retaining of individuals with unsuitable backgrounds for positions having regular contact with or control over Indian children.  


While a recent reorganization has yielded some improvements in BIAï¿½s process, we ultimately concluded that BIAï¿½s education employee background investigation process is still not ensuring that unsuitable individuals are prevented from having contact with Indian children.

Background

Individuals who have been convicted of certain offenses, such as sexual assault or molestation, are precluded by law from holding positions that have regular contact with or control over Indian children.  Therefore, each individual who is employed or is being considered for employment in a position having duties or responsibilities including regular contact with or control over Indian children is required to undergo a background investigation.  Exact numbers are unavailable, but it is clear that only a few applicants are ever shown to be unsuitable by the background investigation process.  At the time of our audit, the BIA records showed that out of 7,664 background investigations initiated, only 165 identified issues for further investigation, and only 50 (or less than one percent of the total) were ultimately found to be unsuitable. 


BIAï¿½s current procedures require the pre-screening of applicants by the school hiring officials and pre-approval of hiring by the OIEP Office of Indian Education Security Services (Security Office).  Pre-screening includes verifying applicantsï¿½ information regarding previous employment, contacting references, and obtaining information from local law enforcement agencies.  The hiring officials complete and forward to the Security Office the information they obtain through the pre-screening process on an affidavit.  The Security Office reviews the pre-screening information and then sends the school hiring officials back written recommendations on whether to tentatively hire applicants.  Each new employee then completes a more detailed security package.  This security package contains information about the new employeeï¿½s history including his or her education and previous employment, former residences, aliases, substance abuse, and legal convictions, if any.  The completed security package is sent to the Security Office which reviews the package and, if it is complete, forwards it to the Office of Personnel Management (OPM).  OPM performs the actual background investigation, which includes obtaining a Federal Bureau of Investigation (FBI) fingerprint and name check (FBI check) of the new employee.  



RESULTS OF AUDIT

The Current Process Does Not Prevent Unsuitable Individuals From Having Contact with Indian Children at BIA Schools 
Most applicants successfully pass a background investigation; only a few individuals are found to be unsuitable.  However, the BIAï¿½s background investigation process allows those few unsuitable individuals to be hired and possibly have contact with Indian children.  We found that Indian children could be in danger because:

> Applicants were hired without timely initiation of local law enforcement checks.

> Applicants were hired before the FBI checks were completed.

> There is insufficient accountability in the process to ensure background investigations are completed promptly or employees who are determined to be unsuitable by background checks are removed from their positions promptly.  

Local Law Enforcement Checks

Applicants were hired without timely initiation of local law enforcement checks.  Local law enforcement checks generally involve contacting police departments for records checks at locations where applicants previously lived or worked.  Depending on the applicant, this may mean contacting multiple local police agencies throughout the nation.  

Although it has long been BIA policy that local law enforcement reviews be completed during the pre-screening process, these reviews are seldom completed before an individual is hired.  The current process requires the local hiring official to conduct the local law enforcement check.  In actuality, the hiring officials rarely even start this check.  Frequently, OPM is the initiator of the local law enforcement check during the full background investigation.  Thus the local law enforcement check, which requires a long time to complete, is not started until after the applicant is tentatively hired.  Also, OPM is only required to request information, it is not required to get a response before completing its investigation.  To complete the local law enforcement check, BIA security personnel have generally needed to make additional inquires after OPM completes its investigation.  We reviewed the files of 57 new employees.  Only 4 files (seven percent) had documentation showing that local hiring officials started the local law enforcement checks.  We were able to obtain complete information regarding the hire dates and the initiation of the local law enforcement checks for 31 new hires.  For those 31 new employees, the average length of time between the hire date and initiation of the local law enforcement check was 243 days, or about eight months.  

Some of these applicants were found by the local law enforcement reviews to be potentially unsuitable for employment in positions having contact with or control over Indian children.  For example:


> A home living assistant at a school dormitory in New Mexico was hired in October 1998 and did not receive the required local law enforcement check during the employee pre-screening.  The FBI check revealed no offenses, but a local law enforcement inquiry in March 2000 identified 26 offenses including battery and endangering the welfare of a minor.  This unsuitable individual remained a school employee for approximately 17 months before the local law enforcement inquiry was made.  Also, after the local law enforcement review identified the offenses, this individual remained employed for approximately six months before a final determination to remove the employee was made.


The current local law enforcement check process is time consuming and convoluted.  It may result in three separate inquiries to a local law enforcement agency (one from the hiring official, one from OPM, and one from the Security Office.)  The Security Office has the ultimate responsibility to complete the local law enforcement check.  To do that, the Security Office first must determine what steps the hiring official and OPM may have completed and then complete the remaining steps.  In our opinion, shifting the responsibility to initiate the local law enforcement check from the local hiring officials to the Security Office will help streamline and hasten the process.  The Security Office should initiate the local law enforcement check and make follow-up inquiries while OPM is conducting its background investigation.  The local law enforcement agencies would then be able to have a single point of contact for all Indian education background inquiries and the Security Office would be able to ensure that the checks are initiated and completed in a timely manner, without repeating steps that may have been started by others.

FBI Fingerprint and Name Checks
Applicants were hired before completion of the FBI fingerprint and name checks.  Some of these applicants were subsequently found by the FBI check to have a criminal record that caused the individual to be potentially unsuitable for employment in a position that may have contact with Indian children.  For example:

> An education aide in New Mexico was hired in August 1999 and had a background investigation completed around March 2000.  The FBI check revealed a battery and child endangerment conviction.  A final determination was issued in September and employment was terminated in October 2000.

The Security Office has worked with OPM to have the FBI check completed earlier in the process.  The new procedures include having OPM report the results of the FBI fingerprint check within about 15 days after the fingerprints and the security package are submitted.  However, this could be months after the employee is hired.  The Security Office currently cannot submit the security packages to OPM until all the forms are complete.  From the 57 new hire files we reviewed, we were able to identify 49 files that had both the employeesï¿½ hire date and the date the security package was properly completed.  We identified 23 individuals (47 percent) who were hired prior to the security package being completed.  The average elapsed time between the date these individuals were hired and the date the security package was completed was 107 days or about three and a half months.  

We understand that there needs to be a balance between the timing for hiring critical employees, such as teachers, and completing the prescreening of applicants.  However, we believe that changing the process to allow completion of the FBI check after an offer of employment has been made, but before the employee is hired, is a necessary safeguard that causes only a minor delay in getting the new employee on board.  We contacted OPM and asked if the FBI check could be completed prior to submission of the full security package for the complete background investigation process.  OPM indicated that it could accept the fingerprint form separately from the rest of the investigation process and provide the results of the FBI check to the Security Office.  
 
Accountability 
The current process does not provide sufficient accountability to ensure that background investigations are completed in a timely manner or that unsuitable employees are removed from their positions promptly.  We found that local school officials were not always:

> Completing required pre-screening steps.

> Waiting for the Security Officeï¿½s pre-approval before hiring applicants.

> Ensuring that applicants prepare a complete security package for submission to OPM for the background investigation.

> Promptly removing employees determined to be unsuitable.

Also, the Security Office needs to improve its tracking of the background investigation workload.  

Performing Pre-screening Steps
Hiring officials were not completing the required pre-screening affidavits properly.  We reviewed 57 pre-screening affidavits for new employees and found only one completed properly, including verification of all required background information.  The pre-screening process includes verifying prior employment and checking references.  The Security Office then evaluates the pre-screening information before pre-approving the applicant to be tentatively hired.  However, the Security Office does not currently collect, analyze, or report information on the completion of the pre-screening affidavits by the hiring officials.

Obtaining Security Office Approval
Schools hired applicants without the required pre-approval by the Security Office.  For example:

> A counselor technician in Oklahoma was hired three months before the school was sent the notice of tentative hire by the Security Office.

> A teacher in Arizona was hired two and a half months prior to the school receiving the notice of tentative hire from the Security Office.  

The Security Office reviews the pre-screening package to identify any obvious problems before providing a recommendation on the tentative hiring of the applicant.  If the schools do not wait for the Security Officeï¿½s preliminary review, the schools are increasing the risk that an unsuitable person will be hired.

Additionally, the Security Office uses the pre-screening and pre-approval process to identify new hires that will need a background investigation.  If schools are hiring without the pre-approval, it may mean that the Security Office is unaware of the need to conduct a background investigation for that new employee.  This increases the chance that an employee will never have a background investigation and that unsuitable individuals will not be identified or prevented from having contact with Indian children.  

To identify OIEP employees who may not have had background investigations, we compared the background investigation log for OIEP employees to the information in the Federal Personnel/Payroll System (FPPS) for OIEP.  We identified 146 OIEP employees that were not listed on the log and may never have had a background investigation completed.  We provided this information to the Security Office immediately.  As a result, the Security Office took action to reconcile the background investigation log.  Since February 2003 the Security Office has performed this reconciliation monthly.  


Completing Security Packages
Hiring officials were not ensuring that new employees properly completed the security forms needed to initiate a background investigation.  When the Security Office receives incomplete forms it must return the forms to be completed.  This lengthens the time it takes to complete background investigations.  The Security Office has developed and delivered training about the security package to local school officials to help them ensure that the packages are complete prior to submission.  The Security Office maintains information about when a security package is received, when it is completed, and when it is forwarded to OPM to start an investigation.  However, the Security Office does not analyze or report information on the length of time it takes to get a completed package or the number of times it needs to return a package to the employee before it is completed properly.  

Removing Unsuitable Employees
School officials were not always promptly removing employees who have been determined to be unsuitable.  For 26 security files reviewed, we found that removal of an unsuitable employee from his or her position could be as quick as six days or as long as one year from the date the unsuitability was determined.  For instance:


> A school secretary in New Mexico convicted of voluntary manslaughter and aggravated assault had a final unsuitable determination in November 2001 but remained employed for about nine months until a final resolution in August 2002.

The Security Office does not currently collect, analyze, or report information on the length of time unsuitable employees are retained after the final suitability determination.  

Tracking Security Office Workload
The Security Office maintains a database or log of the background investigation workload.  The log includes information on an applicantï¿½s name, dates actions are taken or documents are submitted, and the outcome of the investigation when completed.  The Security Office does not track the number of investigations needed, in process, or completed.  Nor does it track its timeliness in completing its portion of the process.  When the current Security Office took over the process in August 2002 there was a large backlog of incomplete investigations.  Some of these incomplete investigations had been unresolved for a long period.  This backlog has been generally resolved; however, the Security Office should track and report workload statistics to help prevent a reoccurrence and to help measure its own performance.


The Security Office needs to develop procedures to collect statistics on hiring officialsï¿½ performance in completing the pre-screening steps and obtaining pre-approval from the Security Office before hiring individuals.  It should also collect statistics on the completeness and timeliness of security packages being sent to OPM for the background investigations.  In addition, data should be collected on the numbers of persons who have been determined unsuitable but not removed from their positions.  This information should be reported to OIEP management to help monitor and improve program performance. 

BIA Actions
Based on our audit, the Office of Indian Education Security Services (Security Office) is taking steps to improve the background screening process.  These steps include:

> Amending its procedures and submitting fingerprint charts to the Office of Personnel Management as soon as the security package is received, rather than waiting until the security package has been reviewed and is properly complete.

> Entering into a Memorandum of Understanding with the Office of Personnel Management to conduct child-care investigations which include checks of all relevant state criminal history repositories.

> Monitoring completion of pre-employment screening.

> Eliminating a large backlog of incomplete background investigations.

> Reconciling Federal Personnel Payroll System records of current employees to the background investigations log on a monthly basis.

> Developing and delivering needed training to various personnel.

> Meeting with the Deputy Director, OIEP, on a weekly basis to keep him informed of security issues.

> Receiving and reconciling monthly reports of new appointments and terminations for all OIEP schools and the OIEP Central Office.



RECOMMENDATIONS


We recommend that the Assistant Secretary for Indian Affairs:





BIA Response











OIG Conclusion
1. Transfer responsibility for initiating local law enforcement checks from the schools to the Office of Indian Education Security Services (Security Office).

In its December 31, 2003, response to the draft report (Appendix 4), BIA concurred with the audit finding, but did not concur with the recommendation.  Instead BIA offered an alternative action to have the OIEP Security Office work with individual schools to establish local points of contact with local law enforcement agencies and negotiate agreements with these agencies where circumstances warrant.  If schools are unable to obtain these checks timely, then the matter would be referred to the local law enforcement district office official for resolution.

OIG considers this recommendation unresolved.  As the BIA points out in its response:

ï¿½ obtaining records from local law enforcement agencies is a complex issue that has just about as many procedural scenarios as there are law enforcement agencies.  Some law enforcement agencies require payment, some require written agreements, some require additional releases, and others will not release (information) to non-law enforcement agencies such as BIA schools.  

We agree this is often a complex and difficult requirement to meet.  In addition, the term local law enforcement agency can be misleading because it does not refer to being geographically local to a schoolï¿½s location.  Rather it refers to the level of the law enforcement agencyï¿½s jurisdiction, local as opposed to state or national.  Because of an applicantï¿½s work experience, a rural school in one state will often be required to make local law enforcement inquiries in multiple jurisdictions in other states.  As pointed out in the report, using local school officials from multiple schools for these checks is a time-consuming and convoluted process.  Because of these complexities and necessity to perform these checks in a timely manner, we believe a single group of well trained individuals at the OIEP Security Office would be much more effective in performing these inquiries.  We are requesting the BIA reconsider the recommendation and provide the information requested in Appendix 5.    




BIA Response







OIG Conclusion


2. Prohibit employment of new education personnel until after the FBI check is completed.

BIA concurs with this recommendation.  OIEP is amending its standard operating procedures to require that new hires have an OIEP security services approved advanced fingerprint check from the FBI before appointment to the position within OIEP.  The new standard operating procedures are to be implemented by January 2004.

OIG considers this recommendation resolved but not implemented.  The recommendation will be referred to the Assistant Secretary for Policy, Management and Budget for tracking of implementation.




























BIA Response










OIG Conclusion
3. Strengthen the accountability of the background investigation process by establishing the following requirements:
 
a. Provide the OIEP Deputy Directors a monthly list of any persons determined unsuitable whose employment has not yet been terminated. 

b. Provide the OIEP Education Line Officers a quarterly report identifying deficiencies, such as not completing reference checks or submitting incomplete security packages, in schoolsï¿½ performance in the background investigation process.  

c. Provide the OIEP Director a quarterly report indicating average time for investigations, number of cases pending, average age of pending cases, and number of cases decided during the quarter.

d. Reconcile a listing of new employees from the Federal Personnel Payroll System (FPPS) records to the Security Office records at least monthly.

BIA concurs with this recommendation.  The BIA has instituted weekly meetings with the OIEP Deputy Director and quarterly presentations to the OIEP Director, the OIEP Deputy Director, the Law Enforcement Services Deputy Director, and the Education Line Officers.  These meetings and presentations address the issues raised in this recommendation.  To establish a documented history, OIEP has begun providing written reports to these officials.

OIG considers this recommendation resolved and implemented.  No further action is required. 
 




BIA Response







OIG Conclusion
4. Ensure that the appropriate officials act on the information provided in the oversight reports as necessary.

BIA concurs with this recommendation.  The BIA has already amended its standard operating procedures to identify appropriate responsible officials and required actions related to security actions.  In addition, BIA has developed language and will amend critical elements for both performance standards and performance appraisals to reflect responsibilities for security related positions.

OIG considers this recommendation resolved but not implemented.  This recommendation will be referred to the Assistant Secretary for Policy, Management and Budget for tracking of implementation.  







BIA Response




OIG Conclusion
5. Ensure that the Security Office addresses the differences identified by our audit between the log of background investigations and the personnel records, including completing any necessary background investigations. 

BIA concurs with this recommendation.  BIA has already and will continue to identify and resolve differences between the log of background investigations and the personnel records.

OIG considers this recommendation resolved and implemented.  No further action is required.



Appendix 1


BACKGROUND

The BIA Office of Indian Education Programs (OIEP) is responsible for the support of 187 schools with an enrollment of about 48,000 students.  These 187 schools include 119 day schools, 54 boarding schools, and 14 dormitories that house Indian children who attend public schools.  BIAï¿½s schools are operated by either BIA or tribal organizations under grants or contracts from BIA.  During the 2001-2002 school year, BIA operated 68 schools and 1 dormitory and tribes or tribal organizations operated the rest.

In accordance with Executive Order 10450, Security Requirements for Government Employment, dated April 27, 1953, each individual who has been tentatively selected for employment with OIEP must undergo a minimum investigation to determine the individualï¿½s suitability for the position.  In accordance with 441 Department of the Interior Manual, Personnel Security and Suitability Requirements, OIEP contractors and consultants are subject to the same requirements as Federal employees.  Because OIEP employees are in contact with Indian children, they are also subject to Public Law 101-647 (codified in 42 U. S. Code 10341), Crime Control Act of 1990, Subchapter V-Child Care Worker Employee Background Checks, which requires Federal agencies involved with the provision of services to children under age 18 to assure that all existing and newly hired employees undergo a criminal background check.  In addition, OIEP is also subject to Public Law 101-630, The Indian Child Protection and Family Violence Protection Act (25 U.S.C. ï¿½ 3207), which requires background investigations of individuals who are employed or being considered for employment when the position has regular contact with or control over Indian children.  Individuals are not eligible for appointment if they have been found guilty of, or entered a plea of no contest or guilty to, any felony offense or any two or more misdemeanor offenses under Federal, State, or Tribal law involving crimes of violence; sexual assault, molestation, exploitation, contact, or prostitution; crimes against persons; or offenses committed against children.

In August 2002 responsibility for background investigations of education personnel at BIA-operated schools was transferred from the BIA Personnel and Physical Security Office to a newly created Office of Indian Education Security Services within the Human Resources Office of the OIEP (Security Office).  The Department of the Interior provided the Security Office authority to perform background investigations in December 2002.  The Security Office hired six employees to run its program.

The Security Office is responsible for ensuring compliance with Federal law governing access and suitability, and special statutory requirements for employees assigned duties and responsibilities involving regular contact with or control over Indian children, possession of a firearm, access to and management of information technology resources, and access to individual Indian and tribal trust resources.  This includes ensuring all BIA positions, including those in OIEP, are appropriately designated and the appropriate screening is conducted and/or background investigations performed for all BIA personnel, as well as contractor and Public Law 93-638 tribal employees, seeking access to information technology and individual Indian and tribal trust resources.

The OIEP employs approximately 5,000 individuals.  BIA has determined that all OIEP positions require at least a Child Care National Agency Check with Inquiries.  Since January 1998, the BIAï¿½s security offices have been involved in the various stages of background investigations for approximately 6,700 individuals.  The background investigation process includes prescreening of applicants and obtaining completed security forms from the applicants selected for positions.  It also includes the investigation and the adjudication (final determination of suitability) of current or potential employees as well as volunteers and contractors whose work brings them into contact with Indian children.  The Office of Personnel Management, Investigative Service, conducts all background investigations for OIEP employees, contractors, consultants, and volunteers.
Appendix 2


SCOPE AND METHODOLOGY

Our audit was conducted at the BIA Personnel and Physical Security Office and the Office of Indian Education Security Services (Security Office) in Albuquerque, New Mexico, and included interviews with BIA management, security staff, and employee relations staff.  We also contacted individuals with the Office of Personnel Management (OPM) to clarify background investigation requirements.  We reviewed documentation available from BIA and OPM for background investigations, and we reviewed selected background investigation files.  Our scope included background investigations conducted from January 1998 to January 2003.  

Our scope included background investigations for all Office of Indian Education Programs (OIEP) positions, volunteers, and contractors at BIA-operated schools and all individuals in the OIEP Human Resources Office.  We did not review the background investigation process for employees at contract and grant schools.  In addition, the audit did not include the background investigation process for positions outside OIEP, which remained with the BIA Personnel and Physical Security Office.

We obtained the BIA Personnel and Physical Security Officeï¿½s background investigation log as of November 2002.  Using this log we selected 74 security files for our audit.  Four of the selected files could not be located leaving 70 files included in our audit.  These individuals were selected because they were determined to be unsuitable or were noted as having a Public Law 101-630 issue.  In addition, we obtained the same background investigation log as of January 15, 2003, with updates made by the new Security Office.  Using this updated log we selected and reviewed 26 additional security files where the background investigation was started by the BIA Personnel and Physical Security Office and completed with a favorable determination by the new Security Office.

We conducted our audit in accordance with the Government Auditing Standards issued by the Comptroller General of the United States.  Accordingly, we included such tests of records and other auditing procedures as we considered necessary under the circumstances.


Appendix 3


PRIOR AUDIT COVERAGE

During the past 5 years, the General Accounting Office has not issued any audit reports regarding BIAï¿½s education employee background investigations.  The Office of Inspector General (OIG) issued three reports in December 1998 related to issues of BIA education employee background investigations:

> Background Investigations for Navajo Area Education Employees, Bureau of Indian Affairs

>  Background Investigations for Phoenix Area Education Employees, Bureau of Indian Affairs

> Background Investigations for Albuquerque Area Education Employees, Bureau of Indian Affairs

These reports stated that the Area Security Offices did not timely initiate and properly complete all background investigations for new and existing education employees.  The reports further stated that the BIA did not have effective processes, including written procedures, to identity all employees needing background investigations and to obtain the information necessary for the proper and timely completion of background investigations and security clearances.

In all three reports, the OIG recommended that (1) the Central Office Security Officer establish policies and procedures to ensure that education employees who have not received completed background investigations are identified and that all background investigation forms are obtained, properly completed, and submitted to the Office of Personnel Management; (2) the Central Office Security Officer establish polices and procedures to ensure that the Area Personnel Officers are notified of all relevant personnel actions; and (3) the Personnel Officer of the Office of Indian Education Programs (OIEP) establish a process to ensure that suitability determinations are adequately reviewed and implemented.

The OIG made an additional recommendation in the Navajo Area report that the Director, OIEP, review the three adverse suitability determinations cited in the report.

The BIA centralized the security process and established new policies and procedures as a result of these audits.  However, as this current report indicates, the changes made did not resolve the issues identified in the prior reports.










Appendix 5

STATUS OF AUDIT RECOMMENDATIONS

      
Recommendations
Status
Action Required

1

Management concurs with finding. Recommendation unresolved.

Reconsider the recommendation, and provide estimated target date and titles of officials responsible for implementation.
  
2 and 4
Resolved; not implemented.
No further response to the Office of Inspector General is required.  The recommendation will be referred to the Assistant Secretary for Policy, Management and Budget for tracking of implementation.

3 and 5
Resolved and implemented.
No further action is required.
      


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