[Audit Report on Agricultural Leasing and Grazing Activities, Fort Berthold Agency, Bureau of Indian Affairs]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 99-i-102

Title: Audit Report on Agricultural Leasing and Grazing Activities,
       Fort Berthold Agency, Bureau of Indian Affairs

Date:  November 25, 1998




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U.S. Department of the Interior
Office of Inspector General


AUDIT REPORT


AGRICULTURAL LEASING AND GRAZING
ACTIVITIES, FORT BERTHOLD AGENCY,
BUREAU OF INDIAN AFFAIRS


REPORT NO. 99-I-102

NOVEMBER 1998




MEMORANDUM

             TO:  The Secretary

           FROM:  Eljay B. Bowron
                  Inspector General

SUBJECT SUMMARY:  Final Audit Report -
                  "Agricultural Leasing and Grazing
                  Activities, Fort Berthold Agency, Bureau
                  of Indian Affairs" (No. 99-i-102)

Attached for your information is a copy of the subject final
audit report.  The objective of the audit  was  to determine
whether   the   Fort   Berthold  Agency  adequately  managed
agricultural  leases  and  grazing  permits  for  the  Three
Affiliated  Tribes  of the  Fort  Berthold  Reservation  and
individual Indian landowners  in accordance with regulatory,
lease, and permit requirements  and whether agricultural and
grazing revenues in special deposit  (suspense) accounts had
been distributed.

We found that agricultural leases and  grazing  permits were
not  adequately  managed  and  agricultural lease rents  and
grazing fees and related interest  were not distributed from
special  deposit accounts.  Specifically,  (1)  agricultural
leases were  not  approved  in a timely manner, (2) interest
applicable to late grazing fee  payments was not assessed or
collected, (3) lease rent and grazing  fee payments were not
forwarded  to  the  Aberdeen Area Office for  deposit  in  a
timely manner, and (4) lease rents and grazing fees were not
distributed to landowners in a timely manner.  Consequently,
we determined that (1)  agricultural lease rents for 1997 of
approximately $165,000 and grazing fees for 1996 and 1997 of
about $489,000 were not paid  timely,  (2) interest of about
$4,800  relative  to  late  grazing  fee  payments  was  not
assessed  or  collected,  and (3) interest of  about  $2,000
relative to untimely deposits of lease rents and grazing fee
payments was not realized.   In addition, agricultural lease
rent payments for 1997 of at least  $110,000  had  not  been
distributed  to  landowners.   Furthermore,  at December 31,
1996,  the  Agency  had  293 special deposit accounts,  with
balances  totaling  about  $671,000,   that   consisted   of
undistributed  agricultural  lease  rents  and  grazing fees
which were received in calendar year 1996 and prior years.

In its response to the draft report, the Bureau agreed  with
four  of the draft report's eight recommendations to address
these issues.   In  its  response, the Office of the Special
Trustee   for  American  Indians   agreed   with   the   two
recommendations addressed to the Special Trustee.
Based on the  responses,  we considered four recommendations
resolved and implemented and  revised one recommendation and
requested   that   the  Bureau  respond   to   the   revised
recommendation.   Also,  based  on  the Bureau's response to
three recommendations in our draft report,  which related to
grazing  rates,  and  subsequent  discussions  with   Bureau
officials,  we  have  deleted  the  recommendations from the
final report. We will address grazing  rates  in  a separate
advisory letter.

If   you  have any questions concerning this matter,  please
contact me  at  (202)  208-5745  or  Mr. Robert J. Williams,
Assistant Inspector General for Audits, at (202) 208-4252.


Attachment




                                    C-IN-BIA-002-97(C)


Memorandum

     To:  Assistant Secretary for Indian Affairs
          Special Trustee for American Indians

   From:  Robert J. Williams
          Assistant Inspector General for Audits

Subject:  Audit Report on Agricultural Leasing
          and Grazing Activities, Fort Berthold Agency,
          Bureau of Indian Affairs (No. 99-i-102)


This  report  presents  the  results  of  our audit of
agricultural and grazing activities of the  Bureau  of
Indian Affairs Fort Berthold Agency.  The objective of
the   audit   was  to  determine  whether  the  Agency
adequately managed  agricultural  leases  and  grazing
permits  for  the  Three Affiliated Tribes of the Fort
Berthold Reservation and individual Indian landowners.

We found that agricultural  leases and grazing permits
were  not  adequately managed and  agricultural  lease
rents and grazing  fees  and related interest were not
distributed    from    special    deposit    accounts.
Specifically,   (1)  agricultural  leases   were   not
approved in a timely  manner,  (2) interest applicable
to  late  grazing  fee payments was  not  assessed  or
collected, (3) lease  rent  and  grazing  fee payments
were  not  forwarded  to the Aberdeen Area Office  for
deposit in a timely manner,  and  (4)  lease rents and
grazing fees were not distributed to landowners  in  a
timely  manner.   Consequently, we determined that (1)
agricultural lease  rents  for  1997  of approximately
$165,000 and grazing fees for 1996 and  1997  of about
$489,000  were not paid timely, (2) interest of  about
$4,800 relative  to  late grazing fee payments was not
assessed  or collected,  and  (3)  interest  of  about
$2,000 relative  to  untimely  deposits of lease rents
and  grazing  fee  payments  was  not   realized.   In
addition, agricultural lease rent payments for 1997 of
at   least  $110,000  had  not  been  distributed   to
landowners.

Furthermore,  at December 31, 1996, the Agency had 293
special deposit accounts, with balances totaling about
$671,000, that consisted of undistributed agricultural
lease rents and  grazing  fees  which were received in
calendar year 1996 and prior years.

In our draft report we made eight  recommendations for
the  Bureau  to improve the agricultural  leasing  and
grazing activities  at  the  Agency.   In its response
(Appendix 1) to the draft report, the Bureau concurred
with  Recommendations  1, 3, 4, and 5 and nonconcurred
with Recommendation 2.   In its response (Appendix 2),
the Office of the Special Trustee for American Indians
concurred with Recommendations  4 and 5.  Based on the
responses, we consider Recommendations  1, 3, 4, and 5
resolved    and    implemented    and   have   revised
Recommendation 2 and request that the  Bureau  respond
to the revised recommendation (see Appendix 3).  Also,
based  on the Bureau's response to Recommendations  6,
7, and 8 in our draft report, which related to grazing
rates,  and   subsequent   discussions   with   Bureau
officials,  we  have  deleted the recommendations from
the final report. We will address the issue of grazing
rates in a separate advisory letter.

In accordance with the  Departmental  Manual  (360  DM
5.3),  we  are  requesting a written response from the
Assistant Secretary  for Indian Affairs to this report
by December 31, 1998.  The response should provide the
information requested in Appendix 3.

The legislation, as amended,  creating  the  Office of
Inspector General requires semiannual reporting to the
Congress on all audit reports issued, actions taken to
implement audit recommendations, and identification of
each  significant  recommendation  on which corrective
action has not been taken.

We  appreciate  the assistance of  Bureau  and  Office
personnel in the conduct of our audit.


                            CONTENTS


                                                       Page

INTRODUCTION..............................................1

   BACKGROUND.............................................1
   OBJECTIVE AND SCOPE....................................3
   PRIOR AUDIT COVERAGE...................................4

   FINDINGS AND RECOMMENDATIONS...........................5

   A.LEASE AND GRAZING PERMIT MANAGEMENT..................5
   B.SPECIAL DEPOSIT ACCOUNTS............................14

APPENDICES

   1.RESPONSE FROM THE BUREAU OF INDIAN AFFAIRS .........16
   2.RESPONSE FROM THE OFFICE OF THE SPECIAL TRUSTEE
       FOR AMERICAN INDIANS .............................21
   3.STATUS OF AUDIT REPORT RECOMMENDATIONS .............23


                          INTRODUCTION


BACKGROUND

According to the Code of Federal Regulations (25 CFR 162 for
leasing and 25 CFR 166 for grazing), the Bureau  of  Indian
Affairs is responsible for approving leases and grazing
permits for individually owned land[1] and tribal land held
in trust that is negotiated by the landowners or their
representatives. The Bureau may also approve leases or issue
permits on individually owned land on behalf of incompetent
persons, orphaned minors, undetermined heirs of estates,
landowners who have not been able to agree upon a lease or
permit,
landowners  who  have  given  the Secretary of the  Interior
written  authority  to  execute  leases   or   permits,  and
landowners  whose  whereabouts  are  unknown.   The Code  of
Federal Regulations also states that leases and permits  may
be  executed either through negotiation or advertisement and
that  annual  rents should provide for a fair annual return.
Specifically, the  Code  states that (1) agricultural leases
are not to exceed 5 years  for dry-farming land and 10 years
for irrigable land but that  when  lessees  are  required to
make  substantial improvement to the land for the production
of specialized  crops,  leases  can be approved for 25 years
and (2) grazing permits are not to  exceed  5  years  except
when substantial development or improvement is required,  in
which case the maximum period "shall be" 10 years.

To  improve  the management, productivity, and use of Indian
agricultural lands  and  resources, the Congress enacted the
American  Indian Agricultural  Resource  Management  Act  in
December 1993.   The  Act  states  that  the Secretary is to
manage  Indian agricultural lands to achieve  the  following
objectives:  (1) protect and maintain the highest productive
potential on the  lands,  (2) increase production and expand
diversity  on the lands, (3) manage  lands  consistent  with
integrated resource  management plans, (4) enable Indians to
maximize  the  potential   benefits  available  to  them  by
providing   technical   assistance,    (5) develop    Indian
agricultural  lands  to promote self-sustaining communities,
and (6) assist trust and  restricted  Indian  landowners  in
leasing their land for a reasonable annual return consistent
with prudent management and conservation practices.  To meet
these  objectives,  the  Act  requires  that  10-year Indian
agricultural  resource  management and monitoring  plans  be
prepared  and  implemented  for  Indian  agricultural  lands
"within  three  years  of  the  initiation  of  activity  to
establish the plan."

The Act stipulates  that the management and monitoring plans
be developed by tribes under self-determination contracts or
self-governance compacts  or  by the Bureau if tribes choose
not to contract or compact for  the  plans.   The  Act  also
requires  that  the  Bureau,  by  June 1994, contract with a
non-Federal entity to conduct an independent  assessment  of
Indian agricultural land management and practices, which was
to  include  a  comprehensive assessment of the improvement,
funding, and development  needs  for all Indian agricultural
lands.   However,  the  Bureau had not  contracted  for  the
assessment as of August 1997.  In addition, the Act requires
that the Bureau issue final regulations to implement the Act
by December 1995.  In June  1996, the Bureau issued proposed
regulations; however, the regulations had not been finalized
as of August 1997.  Further,  the  Act  changed  many of the
requirements  specified  in the Code of Federal Regulations.
For  example,  the  Act  (1) authorizes   the   leasing   of
agricultural  lands to the highest bidder at rates below the
appraisal  amount  after  "satisfactorily"  advertising  the
leases when such action would be in the best interest of the
landowner, (2) provides  preference  to  Indian operators of
agricultural leases when authorized by tribal resolution and
when  the  landowner received fair market value,  (3) waives
the  requirement   for   bonds  when  authorized  by  tribal
resolution and when other  collateral  is  posted in lieu of
bonds,   and   (4) extends   the  maximum  lease  term   for
dry-farming land from 5 to 10 years.

The  Fort  Berthold  Agency of the  Bureau's  Aberdeen  Area
Office is responsible for leasing and grazing activities for
the Three Affiliated Tribes  (Arikara,  Hidatsa, and Mandan)
and   individual  Indian  landowners  on the  Fort  Berthold
Indian  Reservation.   The  Reservation  encompasses   about
454,700  acres  in  western  North Dakota, which consists of
about 337,300 acres of individually owned land, about 83,700
acres of tribal land, and about  33,700 acres  of Government
land.   The  ownership  interests in the individually  owned
land are severely fractionated.[2]  As of December 31, 1996,
the   Agency  administered  401 agricultural   leases   that
encompassed  about  29,800  acres  of farm and pasture lands
which  had annual lease rents totaling  about  $781,000  and
administered  94  grazing  permits  that  encompassed  about
221,000  acres  of  pasture  lands  with annual grazing fees
totaling about $440,000.

The Fort Berthold Agency had six individuals assigned to the
real estate services program and four  individuals  assigned
to the land operations program.  However, at the time of our
review  in May 1997, the Realty Officer position was vacant.
The work  load  of realty and land operations staff included
the following administrative  duties:  (1) approving  leases
and  issuing permits; (2) collecting, forwarding collections
for deposit,  and  distributing lease rents and permit fees;
(3) ensuring compliance  with  the  terms  of the leases and
permits; (4) processing land acquisitions and disposals; and
(5) processing  probates.  The fiscal year 1997  budget  for
the Agency's real  estate  services was $258,000 and for the
land operations programs was $227,000.

The Secretary of the Interior  has  been  designated  as the
trustee  of  funds  held  in trust by the Government for the
benefit  of  Indian  tribes  and  individual  Indians.   The
Secretary's authority for the  management of trust funds was
delegated to the Assistant Secretary  for  Indian Affairs in
the  Departmental  Manual (109 DM 8) and was redelegated  to
the Bureau's Aberdeen  Area Director in the Bureau of Indian
Affairs Manual (10 BIAM, Bulletin 13).  On October 26, 1989,
Secretarial  Order No. 3137  was  issued  to  establish  the
Office of Trust Funds Management within the Bureau of Indian
Affairs.   The   Office   of   Trust  Funds  Management  was
responsible for providing oversight of some of the financial
trust   service   functions,   which  included   collecting,
investing, distributing, and accounting for the trust funds.
However,  the  Office of the Special  Trustee  for  American
Indians was authorized  by  the  American  Indian Trust Fund
Management  Reform  Act  of  1994 to provide more  effective
management of and accountability for the proper discharge of
the Secretary's trust responsibilities  to Indian tribes and
individual   Indians.    Further,   on   February 9,   1996,
Secretarial  Order  No. 3197  was  issued  to establish  the
Office  of the Special Trustee for American Indians  and  to
transfer  the  Bureau's Office of Trust Funds Management and
other financial trust service functions to the Office of the
Special Trustee.

OBJECTIVE AND SCOPE

The objective of the audit was to determine whether the Fort
Berthold Agency  adequately  managed agricultural leases and
grazing  permits  on  the  Fort  Berthold   Reservation   in
accordance  with regulatory, lease, and permit requirements.
The audit was  performed  at  the  Fort  Berthold  Agency in
Newtown,  North Dakota.  During the audit, we also contacted
Bureau officials  from  the Division of Real Estate Services
in Washington, D.C., and  the  Aberdeen  Area  Office.   Our
audit  focused  on  agricultural  leasing and grazing permit
activities that occurred in calendar  years  1996  and 1997;
however,  we  expanded  the  scope  of our review to include
revenues in special deposit (suspense) accounts to determine
whether  agricultural  lease  rents and  grazing  fees  were
distributed  to landowners.  In  addition,  in  testing  the
timeliness of  disbursements  made to landowners, we did not
attempt  to  validate  or  test  any  specific  disbursement
transactions to determine whether  funds  were  paid  to the
proper   landowners   because   of   long-standing  problems
associated with the Bureau's land title  records  system and
the  Bureau's  Integrated  Records  Management  System  land
ownership subsystem.

Our  audit  was conducted 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 that were  considered
necessary  under  the circumstances.  As part of our review,
we assessed the Bureau's  system  of  internal  controls and
found   weaknesses  related  to  approving  expired  leases,
assessing  and  collecting  interest  on  delinquent grazing
permit payments, collecting and depositing  lease  rent  and
grazing  fee  payments in a timely manner, distributing rent
and fee collections  timely,  and  clearing  special deposit
accounts.   These  weaknesses are addressed in the  Findings
and   Recommendations   section   of   this   report.    Our
recommendations, if implemented, should improve the internal
controls in these areas.

We also  reviewed the Department's Accountability Report for
fiscal years  1996  and 1997 to determine whether any of the
reported weaknesses were  directly  related to the objective
and  scope  of  our  audit.  The Report cited  long-standing
material weaknesses in  the Bureau's (1) management of trust
funds, the responsibility  for which has been transferred to
the Office of the Special Trustee  for American Indians; (2)
debt collection practices; and (3) land  records management.
These weaknesses were considered in planning  and conducting
our review.

PRIOR AUDIT COVERAGE

Neither  the  Office  of  Inspector General nor the  General
Accounting Office has issued an audit report during the past
5 years on agricultural leases  and  grazing permits managed
by the Fort Berthold Agency.  However,  in January 1998, the
Office   of  Inspector  General  issued  the  audit   report
"Financial Statements for Fiscal Year 1996 for the Office of
the Special  Trustee for American Indians Tribal, Individual
Indian Monies,  and Other Special Trust Funds Managed by the
Office  of  Trust Funds  Management"  (No.  98-I-206).   The
report presented  the  results of the audit of the Statement
of  Assets and Trust Fund  Balances  and  the  Statement  of
Changes in Trust Fund Balances for Tribal, Individual Indian
Monies, and Other Special Trust Funds as of and for the year
ended  September  30,  1996,  performed  by  an  independent
certified  public  accounting  firm.  The report on internal
controls  states  that  "the  OTFM [Office  of  Trust  Funds
Management] and the Bureau continue to be hampered by a lack
of   adequate  information  systems   to   support   various
trust-related  activities, including land inventory systems,
lease  management   systems,   ownership  systems,  accounts
receivable and an adequate trust  accounting  system for IIM
[Individual  Indian  Money."   The  report  identified   six
reportable  conditions that impacted the scope of our audit:
(1) receipts  were not mailed to the area office for deposit
on a daily basis;  (2) collection and disbursement functions
were  performed  by  the   same   individuals;  (3) suspense
accounts  were  not  analyzed; (4) the  accounts  receivable
system contained inaccuracies;  (5)  policies and procedures
regarding   special  deposit  accounts  were   lacking   and
practices regarding  these  accounts  were inconsistent; and
(6)  the system of policies and procedures  for  determining
interest  earnings for Individual Indian Monies accounts was
inadequate, which adversely impacted the complete and timely
distribution  of funds to account holders.  These conditions
identified and the resultant recommendations were considered
in the preparation of our current report.

**FOOTNOTES**

[1]:"Individually owned land" as used in the Code of Federal
Regulations (25 CFR 162  for leasing and 25 CFR 166 for grazing)
is defined as "land or any interest therein held in trust by the
United States for the benefit of individual Indians and land or
any interest therein held by individual Indians subject to
Federal restrictions against alienation or encumbrance."

[2]:Fractionated ownership has resulted because many Indians
died without wills. As a result, over a period of generations,
many allotments became jointly owned by hundreds of heirs.

                  FINDINGS AND RECOMMENDATIONS


A.  LEASE AND GRAZING PERMIT MANAGEMENT

Agricultural leases and grazing permits of the Fort Berthold
Indian    Reservation    were    not   managed   adequately.
Specifically,  the  Agency did not (1) approve  agricultural
leases  timely,  (2) assess  or  collect  interest  on  late
grazing fee payments,  (3) deposit  agricultural  lease rent
and  grazing  fee  collections  timely,  and  (4) distribute
agricultural  lease  rents  and  grazing  fees to landowners
timely.    The   American   Indian   Agricultural  Resources
Management  Act  requires the Bureau (1)  to  assist  Indian
landowners  in  leasing   their  agricultural  lands  for  a
reasonable annual return and  (2)  provide  a  preference to
Indian operators in the issuance and renewal of agricultural
leases  and  permits so long as the landowners receive  fair
market value for  their property.  The standard agricultural
lease and grazing permit  provisions provide for the payment
of rents and fees.  The Treasury  Financial  Manual  (TFM 6-
8000)   contains   the  billing  and  collection  procedures
relating to delinquent  debts  and  the  deposit  procedures
which  ensure  that  revenues collected are deposited  in  a
timely manner.  However,  the  Agency  had  not  effectively
managed  its  work  load  to  ensure  that  realty  and land
operations staffs complied with all regulatory, leasing, and
permitting  requirements  in  a timely manner.  As a result,
Reservation lands were farmed without leases, landowners did
not receive agricultural lease  rent  ($165,000) and grazing
fee ($489,000) payments timely, interest on late grazing fee
payments ($4,800) was not assessed or collected, interest of
about ($2,000) related to untimely deposits  of  lease rents
and  grazing  fees  was  not realized, and 1997 agricultural
lease  rent  ($110,000)  payments  for  1997  had  not  been
distributed.

Expired Leases

The Agency did not approve  agricultural  leases in a timely
manner.[3]    Specifically,  we  found  that  of   the   118
agricultural leases which expired on December 31, 1996, only
18 were approved  by the effective date of the new lease; 10
parcels offered for  lease had received no bids or bids that
were below the minimum  acceptable level; 52 leases had been
approved an average of 123  days after the effective date of
the new lease, with a range of  3 to 191 days; and 38 leases
had not been approved as of July 31,  1997  (212 days), even
though  lessees  farmed  the  land pending approval  of  the
leases.  We believe that because  the Agency was not able to
approve leases timely, the potential  risk was increased for
landowners  not  to receive rents for lands  farmed  without
having an approved  lease  agreement.   The  lack  of timely
approval of new leases delayed the collection of rents  from
successful   bidders   and  the  distribution  of  rents  to
landowners until the leases  were  approved.   For  example,
rents totaling about $165,000 for 73 leases were collected 1
to 7 months after the advertised effective date for the  new
leases.

New  agricultural leases for leases that expired on December
31, 1996,  were  not  approved timely because the Agency did
not start the leasing process until January 1997 and did not
issue a competitive advertisement  for  parcels of land that
were available for lease until February 19,  1997  (50  days
after the leases expired).  The advertisement specified that
bids  were  to  be received at the Agency by March 19, 1997,
and the rent payment for the first year was to accompany the
bid.   The  leasing   process   was   also  delayed  because
successful  bidders  had  not provided bonds  and/or  signed
lease contracts timely.  We  found  that agencies which were
successful  in approving new leases before  the  old  leases
expired started  the  leasing  process  approximately 1 year
before the leases expired.[4]

Collection of Grazing Fees and Lease Rents

The  Agency  did  not  assess  or collect interest  on  late
payments  of  grazing fees.  The grazing  permit  provisions
specify that fees  are  due  on  December  1  of  each year;
however,  the  provisions  do not specify a grace period  or
specify that interest is to  be  assessed  on late payments.
In  December  1994,  at the beginning of the current  5-year
grazing  permit  period,  the  Tribes  passed  a  resolution
requiring all grazing  fees  to  be  due  on  December 1 and
interest   to   be  assessed  on  all  delinquent  payments.
However,  the  Agency   did  not  include  a  provision  for
assessing interest on late  payments in the grazing permits.
Of grazing fees totaling $841,000  that were received by the
Agency for 1996 and 1997, fees of about $489,000 relative to
97 payments were paid an average of 72 days, with a range of
32 to 154 days, after the December 1 due date.  By using the
interest  rates  specified  in  the Tribes'  resolution,  we
estimated  that interest of about  $4,800  could  have  been
collected had  the Agency included a provision for assessing
interest on grazing fees that were paid late.

In contrast, according  to  lease  provisions,  agricultural
lease  rents  are  due  on January 1 of  each year, and  the
lessee  is  required  to  pay   rents   without  any  formal
notification   from   the  Agency.   The  lease   provisions
(1) allow a 30-day grace  period  from  the date the rent is
due before interest on late payments is to  be  assessed and
(2) specify  that  interest  assessed retroactively  to  the
January 1 payment due date must  be  based  on  the  average
prime  rate  in effect on the last day of each month plus  3
percent.  However, we were not able to determine whether the
Agency assessed  and collected interest on late agricultural
lease rent payments  because  the  automated  database  that
contained lease payment information was destroyed in January
1997 by water from a broken pipe in the building that houses
the    Agency   Office.   Agency   realty   personnel   were
reconstructing  the  automated  database  at the time of our
site  visit to the Agency in May 1997 because  the  database
had not  been  maintained  or  backed up (copied) since June
1996.

We  also  noted  a  weakness in the  internal  controls  for
grazing fee and lease  rent  collections.  Specifically,  we
found  that  the  Agency's  realty clerk and its range clerk
were individually collecting  lease  rents  and grazing fees
made  by  permittees  and  lessees  in person at the  Agency
Office,  forwarding the collections for  deposit,  recording
the receipts  in the accounting system, and distributing the
fees to the owners.   The American Indian Trust Funds Reform
Act   of   1994   states   that    the   Secretary's   trust
responsibilities  include  providing  adequate  systems  for
accounting  and  reporting trust funds balances  to  include
adequate controls  over receipts.  Since the Act was passed,
the Secretary established  the Office of the Special Trustee
in February 1996.  Under this  reorganization, we noted that
supervisory responsibilities for  an  accounting  technician
position which is located at the Agency to account for trust
funds  in  Individual Indian Money accounts were transferred
from the Bureau's Agency Superintendent to the Office of the
Special Trustee.   However, the Bureau, in coordination with
the  Office  of the Special  Trustee,  had  not  established
(1) adequate administrative  controls  over  receipts at the
agency  level  that  provide  for  sufficient separation  of
duties  and  (2)  written policies and  procedures  for  the
receipt and deposit of trust funds.  Because of this lack of
separation of duties,  an internal control weakness existed.
Although  we  did  not  find  any  instances  of  misuse  by
collection personnel, the  lack  of the separation of duties
increases  the  risk  for  fee  and  rent   payments  to  be
misappropriated.

The January 1998 Office of Inspector General report (see the
Prior  Audit  Coverage section) identified internal  control
weaknesses that  existed between the area and agency offices
because  of  ineffective   implementation  of  policies  and
procedures.   In  that  regard,   we   also  identified  two
deficiencies that were similar to the weaknesses included in
that  report: (1) collection and disbursing  functions  were
performed by the same individuals, and (2) receipts were not
mailed  to the Area Office for deposit on a daily basis.  To
correct  these   deficiencies,   the   January  1998  report
recommended  that  the  Office  of  Trust  Funds  Management
consider alternatives such as restructuring trust accounting
responsibilities at the Agency offices which do not maintain
Office   of  Trust  Funds  Management  staff  positions   by
centralizing  and streamlining transaction processing within
area or agency offices with sufficient Office of Trust Funds
Management personnel.   However,  the report did not suggest
that   the  Office  of  Trust  Funds  Management   eliminate
accounting  technicians  at the agency offices because these
individuals perform valuable  services  for account holders.
In  addition,  the  recommendation stated that  the  use  of
either  a  centralized  or  a  decentralized  lockbox  would
eliminate some  of  the more serious control deficiencies by
eliminating the handling  of  cash  receipts  at  the agency
offices.

In  its response to the recommendation, the Office of  Trust
Funds  Management  stated  that  it had initiated a plan for
implementation  of  a  nationwide lockbox  program  for  the
collection of tribal and  individual  Indian trust funds.[5]
The Office of Trust Funds Management also specified that the
timely implementation of a nationwide lockbox  program would
depend  upon  the  availability  of  appropriated  funds  to
implement  the program.  The Office stated that a nationwide
lockbox program  could  be  fully  operational by the end of
fiscal year 1998 if sufficient funding  was  available.   If
the  nationwide  lockbox  program is implemented, we believe
that it will eliminate the  issues  dealing with the lack of
separation  of  duties  at  the Agency and  the  problem  of
timeliness of deposit, as discussed  in the section "Deposit
of    Lease Rents   and   Grazing   Fees."    Given    these
circumstances,  we  have  not  made any recommendations with
respect to these deficiencies.

Deposit of Lease Rents and Grazing Fees

The  Agency  did not deposit agricultural  lease  rents  and
grazing fees in  a  timely  manner.   The  Bureau  of Indian
Affairs  Manual (42 BIAM Supplement 3) specifies that  field
collections   are   to   be   transmitted  to  a  depositing
collections officer (at the Aberdeen  Area Office) within 24
hours   of   receipt.    Section  8030.20  ("Timeliness   of
Deposits")  of the Treasury  Financial  Manual  states  that
"[a]gencies  will  deposit  or  mail  receipts  for  deposit
totaling $5,000  or more on the same day received prior to a
depositary cutoff  time.   Collections  totaling  less  than
$5,000  may  be  accumulated  and  deposited  when the total
reaches $5,000, but will be made by Thursday of  each week ,
regardless  of the amount."  Collections of lease rents  and
grazing fees  were not transmitted to the Area Office timely
because  of inadequate  staffing  and  because  an  existing
automated  database  was  not  maintained  or  used  by  the
Agency's  realty  staff  to  identify  the  sources of lease
collections.  We reviewed 71 payments of agricultural  lease
rents  and  grazing  fees  totaling about $231,000 that were
received by the Agency in 1996  and 1997 and found that none
of  the  71 payments were transmitted  to  the  Area  Office
within 24  hours  of  receipt.   Specifically,  32 payments,
totaling about $160,000, were transmitted from 14 to 49 days
after they were received in 1996, and 39 payments,  totaling
about $71,000, were transmitted from 9 to 56 days after they
were received in 1997.  Consequently, Indian landowners  did
not  earn  and receive an estimated $2,000 in interest[6] on
the 71 payments of agricultural lease rents and grazing fees
from the date of receipt to the date of deposit.

Distributions

The Agency did  not  distribute agricultural lease rents and
grazing   fees   to   landowners   in   a   timely   manner.
Specifically,  we found  that  the  Agency  did  not  timely
distribute rents and fees collected during 1997 (information
related to 1996  distributions was not readily available for
analysis) as follows:

     - Based on our  review  of payments from 44 lessees, we
found  that  rents  of $110,000 out  of  $191,000  paid  for
agricultural leases had not been distributed as of April 30,
1997. The Agency took an average of 57 days, with a range of
7 to 83 days, to distribute  the  remaining  $81,000 in rent
payments.

     - Based on our review of grazing fee payments for 93 of
the 94 range units, we found that the Agency took an average
of  37 days, with a range of 6 to 156 days, to  collect  and
distribute fees totaling $441,000.  (Payment information for
the remaining  permit was not available when we analyzed the
information in the automated database.)

We  found  that  lease  rents  and  grazing  fees  were  not
distributed timely for the following reasons:

     - Agency realty  personnel  had  to  manually  research
lease  files and distribute rents to landowners because  the
automated  database for leases was destroyed in January 1997
and Agency realty  personnel  had not backed up (copied) the
lease automated database files  since June 1996 (see section
"Collection of Grazing Fees and Lease Rents").

     -  The  realty  clerk  and the range  clerk,  who  were
responsible for administering  leases  and  grazing permits,
including distributing lease rent and grazing  fee payments,
stated  that  they  spent  about  45  percent of their  time
performing  the  additional duties of a collection  officer,
which reduced the  amount  of time available for their full-
time duties.

     - Agency officials said  that  they  did not distribute
partial payments because they might have to cancel the lease
or permit for nonpayment and refund the partial payment.

     - Some Individual Indian Money accounts  that  were  to
receive  rent and fee distributions had been closed by other
agencies.

Although Bureau  regulations  do  not prescribe a time frame
for   distributing   these  revenues  to   landowners,   the
Government Performance  Results  Act  requires that agencies
establish performance measures.  As such,  we  believe  that
the  Bureau,  in coordination with the Office of the Special
Trustee, should  establish  a  time  frame  for distributing
lease rents and grazing fees to landowners.

Recommendations

We recommend that the Assistant Secretary for Indian Affairs
ensure that the Fort Berthold Agency:

1. Initiates  the  lease renewal process in  sufficient
time to complete the  process  before  leases expire on
December 31.

We recommend that the Assistant Secretary for
Indian Affairs:

2. Include a provision in all new grazing permits which
requires  permittees  to  pay  interest on grazing fees
that are paid after the due date.

We recommend that the Assistant  Secretary  for  Indian
Affairs ensure that the Fort Berthold Agency:

3. Maintains the realty automated database used for the
collection   and   distribution   of  lease  rents  and
establishes   procedures   for   the  timely   recovery
(periodic backups) of the database  to  preclude future
loss during a catastrophic event.

We  recommend that the Assistant Secretary  for  Indian
Affairs  and  the  Special Trustee for American Indians
coordinate actions to:

4.  Assess and collect interest on late payments.

5. Establish a time  frame for distributing lease rents
and grazing fees to landowners in a timely manner.

Bureau of Indian Affairs  and  Office  of  the  Special
Trustee  for  American Indians Responses and Office  of
Inspector General Reply

In the September 11, 1998, response (Appendix 1) to the
draft report from  the  Assistant  Secretary for Indian
Affairs,  the Bureau concurred with Recommendations  1,
3, 4, and 5 and nonconcurred with Recommendation 2.  In
the September  25, 1998, response (Appendix 2) from the
Special Trustee for American Indians, the Office of the
Special Trustee concurred with Recommendations 4 and 5.
Based on both responses, we consider Recommendations 1,
3, 4, and 5 resolved  and implemented, and based on the
Bureau's response, we have revised Recommendation 2 and
request  that  the  Bureau   respond   to  the  revised
recommendation (see Appendix 3).

Also,  in  response  to  Recommendations 6,  7,  and  8
included in our draft report,  which related to grazing
rates, the Bureau requested that this issue be included
in an other matters section of the  report  because  of
the  "acknowledged  limitations  on  the  scope  of the
appraisal  review"  and because, as stated in our draft
report, that "`a more  in-depth  review  of the methods
and   techniques   used   to  establish  grazing  rates
Bureau-wide  may  disclose  different  results.'"   The
Bureau also stated that the "General  Accounting Office
has  initiated  a  thorough  review  of  the   Bureau's
appraisal   process"  at  the  request  of  the  Senate
Committee  on   Appropriations   and   that  the  Trust
Management Improvement Project "includes  a  subproject
relating  solely  to"  the  Bureau's appraisal program.
Based  on  the  response, subsequent  discussions  with
Bureau  officials,  and  the  actions  cited,  we  have
deleted   the    discussion   of   grazing   fees   and
Recommendations 6,  7, and 8 from the final report.  We
plan to address the grazing  rates  issue in a separate
advisory letter.

Recommendation 2.  Nonconcurrence stated.

Bureau   of   Indian  Affairs  Response.   The   Bureau
nonconcurred with the recommendation, stating, "With no
statutory requirement to assess and collect interest on
late  payments on  grazing  permits,  we  consider  the
revokable   authority  provided  in  25  CFR  166.15(b)
adequate to ensure  prompt payment."  Additionally, the
Bureau stated, "Grazing  fees  are  assessed  through a
permit process which is unlike the lease process common
to   agricultural  lands  in  that  grazing  agreements
(permits)  are  revokable  on  30-days  written  notice
pursuant  to  25  CFR  166.15(b)."   According  to  the
Bureau, "The tribal resolution mentioned in the report,
is  not  sufficient  in  and  of  itself to require the
assessment of interest: it would be  necessary  for the
tribe  to enact a grazing ordinance which has not  been
done."

Office of Inspector General Reply.  As discussed in the
report (page  6),  we  found  that more than 58 percent
($489,000  of  $841,000)  of the grazing  fee  payments
which were received by the  Agency  for  1996  and 1997
were paid an average of 72 days, with a range of  32 to
154 days, after the December 1 due date.  Therefore, we
concluded  that use of the revokable authority provided
in the Code  (25  CFR  166.15(b))  to ensure the prompt
payment  of  grazing  fees  has  not  been   effective.
Further,  we  believe  that  it  is  a prudent business
practice  to  assess  and  collect  interest   on  late
payments,  whether  from  agricultural  leases  or from
grazing  permits.   The  Chief  of the Division of Real
Estate  Services  said  that  there  is  "no  statutory
requirement"   to   assess  and  collect  interest   on
agricultural leases but  that  the  Bureau  did include
such a provision in the agricultural leases because  it
has  the  discretionary authority  to ensure compliance
with the lease  terms.   Also, the Chief indicated that
there was no reason why such  a  provision could not be
implemented  for  grazing  permits.    By  including  a
provision that requires permittees to pay  interest  on
late  grazing  fees in grazing permits, we believe that
the Bureau would  be protecting the financial interests
of the Indian landowners.   In  addition,  by including
the  assessment  of  interest as a permit provision,  a
formal  notice would not  be  required  by  the  Agency
because the  permit  would  specify  that  interest  is
assessed  from  the due date on late payments.  We have
revised  the  recommendation  to  a  Bureauwide  action
because we believe  that  interest  on late grazing fee
payments  should be applicable to all  grazing  permits
issued by the  Bureau  and  not  just the Fort Berthold
Agency.   Accordingly,  the  Bureau  is   requested  to
respond to the revised recommendation.

In regard to whether the tribal resolution mentioned in
the report or a tribal ordinance would be necessary for
the  Bureau  to  assess  interest  on late grazing  fee
payments,  as discussed previously, the  Chief  of  the
Division of  Real  Estate Services indicated that there
was  no  reason  why such  a  provision  could  not  be
implemented for grazing permits.

Additional Comments

In  its  response,  the   Bureau   provided  additional
comments on the finding as follows:

- General Comments.  The Bureau disagreed  with the our
use  of  the  words  "issuing" and "reissuing" when  we
referred to agricultural  leases rather than "granting"
or "approval," which it said were the terms used in the
statutes and regulations.   However,  the  Bureau  said
that  the terms  "issuing" and "reissuing" are accurate
when "used  in  conjunction  with grazing permits."  We
have revised the report as appropriate.

Regarding  the reservation minimum  acceptable  grazing
rate, the Bureau stated:

     "Fair annual  return"  can  be defined as the
     amount  which,  in  a competitive  market,  a
     well-informed and willing permittee would pay
     and a well-informed and  willing  land  owner
     would  accept  for  the  temporary use of the
     property.  "Fair annual return" should not be
     confused  with the 25 CFR 116.13  requirement
     that  the  Bureau  establish  a  "reservation
     minimum acceptable grazing rental rate" which
     establishes a base amount for lease rates, as
     opposed to an average or a ceiling.


We eliminated the  discussion  in  the  draft report on
whether the Area Director's minimum acceptable  grazing
rates  provide  a "fair annual return" to the landowner
from the final report.   In  that  regard,  the Code of
Federal Regulation (25 CFR 116.13(b)) states  that  the
"Area  Director  shall  establish a reservation minimum
acceptable grazing rental  rate"  that "shall provide a
fair annual return to the land owners."   This could be
interpreted as equating the rental rate to  fair annual
return.   However,  the  Bureau  states,  "`Fair annual
return'  should  not be confused with the 25 CFR 116.13
requirement that the  Bureau  establish  a `reservation
minimum acceptable grazing rental rate,'"  which  could
be  interpreted  to  mean  that  there  is a difference
between  the  minimum  acceptable rate and fair  annual
return.  Further, Section 101 (a)(6)  of  the  American
Indian Agricultural  Resources  Management  Act  states
that  the  Bureau  is  to  assist landowners in leasing
their  agricultural  lands  for  a  "reasonable  annual
return,"  whereas Section 105 (b)(1)  states  that  the
lessor (landowner)  should  receive "fair market value"
for  his  property.   The terms  "minimum  acceptable,"
"reasonable,"   and   "fair"   are   not   defined   or
interrelated in the regulations,  statutes,  or  Bureau
guidance.   As  such, we believe that the issue of what
the rate represents needs to be better defined .

Regarding  the Bureau's  comment  that  a  "reservation
minimum acceptable  grazing  rental rate" establishes a
base amount for lease rates as opposed to an average or
a ceiling,  we noted, as discussed in the draft report,
that the Aberdeen Area Office  appraiser had determined
the Director's grazing reservation  minimum  acceptable
rates for range units on the Reservation based  on  the
"average"  of  the  previous  year's  available  market
grazing  rates  charged  for  6-month  seasonal grazing
periods.   This  supports  our belief that  the  Bureau
needs to better define how to determine grazing rates.

- Expired Leases.  The Bureau  stated  that  the report
"indicates  that  there should be a new lease in  place
upon the expiration  of  a  current  lease"  and   that
"there is no prescribed time frame or legal deadline by
which  lands  must  be  advertised  or leases granted."
Additionally,   the  Bureau  stated,  "There   are   no
statutory  or regulatory  time  frames  for  the  lease
approval  process."    According  to  the  Bureau,  "An
earlier  start to the lease  process  would  result  in
granting leases at an earlier date for those parcels on
which bids are actually received."  However, the Bureau
further stated,  "Even  with  early  initiation  of the
leasing  process,  there  are other circumstances which
affect  the  timing of the lease,  some  of  which  are
beyond   the  Bureau's   control."    Although   Bureau
regulations  do not prescribe a specific time frame for
approving   agricultural    leases,    the   Government
Performance Results Act requires that agencies  conduct
processes  in  a  businesslike  manner.   Regarding the
"various reasons" as to why a new lease may  not  be in
place when a current lease expires and the reasons that
are "beyond the Bureau's control," we believe that some
matters  may  be  beyond  the Bureau's control but that
some processes take longer  to  complete  than the Fort
Berthold   Agency   has  allowed  for  in  its  leasing
procedures.  In that regard, we believe that the Bureau
and the Agency should  determine  the  amount  of  time
necessary to complete the leasing process, establish an
effective  date  for  leases  based  on  Agency-related
conditions   for  beginning  farming  operations,   and
initiate the renewal  process  allowing sufficient time
to  complete actions by the effective  date.   Although
the Bureau  indicated  reasons  for  not  starting  the
process  earlier,  the  Agency  initiated  the  leasing
process  on  July  28,  1998,  for  leases  expiring on
December 31,  1998.  We believe that the Agency  should
review this year's  process  and  determine whether the
earlier  start  improved the timeliness  of  the  lease
approval process.   If  it  did  not, the Agency should
allow more time next year.

The  Bureau stated that our report  "states  that  `the
lack of  timely  approval  of  new  leases  delayed the
collection  of  rents  from successful bidders and  the
distribution of rents to  landowners  until  the leases
were   approved.'"   The  Bureau  requested  that  this
sentence  "be  revised"   because "[t]he landowners are
not due any rents until a lease  has been approved" and
stated  that  "[t]here  is no statutory  or  regulatory
deadline for approval of  a  lease."  However, we noted
that  Agency  agricultural  leases   which  expired  on
December 31, 1996, were not approved timely because the
Agency did not begin the leasing process  until January
1997 and did not issue a competitive advertisement  for
parcels  of  land  that  were available for lease until
February 19, 1997 (50 days  after  the leases expired).
We believe that the Bureau should complete  the leasing
process  as  expeditiously  as  possible.   The  Bureau
should ensure that it initiates the leasing process  so
that  it has the opportunity to complete the process by
the effective  date  of  the new lease, thus maximizing
returns to landowners, and  to  distribute  rents  in a
timely  manner.   As  discussed in the report (page 6),
agencies that were successful  in  approving new leases
before the old leases expired began the leasing process
approximately  1 year before the leases  expired.   Our
report (No. 97-I-1100)  on  the  Colorado  River Indian
Tribes' management of agricultural leasing showed  that
the  Tribes  "initiated  actions in  a timely manner to
ensure  that  expiring leases were reissued  [approved]
without a loss of revenue to the landowners."

The Bureau also  requested  that the report's statement
regarding  increased  risk for  landowners  be  revised
because the "Realty Specialist  at  the  Agency  cannot
recall  any  situations during  his 13-year tenure when
landowners were not compensated for use of their land."
According to the  Bureau,  there  were "instances where
potential lessees farmed land prior  to  completion  of
the   lease  process"  but  that  these  are  "isolated
instances."   As  discussed  in the report (page 5), we
noted that of the 108 agricultural leases which expired
on December 31, 1996, and for which there were adequate
bids, only 18 leases (17 percent)  were approved by the
effective date of the new lease.  Of  the  remaining 90
leases, 52 leases (48 percent) were approved an average
of about 4 months after the effective date of  the  new
lease, and 38 leases (35 percent) had not been approved
as  of  July 31,  1997  (7 months), even though lessees
farmed  the  land  pending  approval   of  the  leases.
Therefore, we do not believe that these  instances  are
"isolated."   Accordingly,  we believe that there is an
increased risk for landowners  not to receive rents for
lands  farmed when a lease agreement  is  not  approved
timely.

**FOOTNOTES**

[3]:Agricultural  leases  typically have a term of 5
years and expire on   December 31 of the last year
of  the  lease  term.   Subsequent  leases   granted
and approved by the Bureau typically become effective
on January  1 of the first year of the new lease term.

[4]:This  conclusion  is  based  on  our  reviews  of
agricultural lease operations at the Colorado River
Agency and the Rosebud Agency.

[5]:A lockbox is a service offered by a financial
institution.  Payments  are  sent  directly  to the
lockbox at the financial institution,  which  processes
the receipt  and  deposit  of  the  payment to the
appropriate  account on a daily basis.  Information
regarding  the  payment  received  would be sent to the
account holder.

[6]:Interest was estimated based on the average interest
rate applicable  to  special  deposit account balances
during the periods the collections  were retained at
the Agency Office.

     B.  SPECIAL DEPOSIT ACCOUNTS

     The  Fort  Berthold   Agency  did  not  distribute  all
     revenues   and   related   interest    earnings    from
     agricultural lease rents and grazing fees that had been
     deposited  into  special deposit accounts.[7]  The Code
     of Federal Regulations  (25  CFR  114)  specifies  that
     special  deposit  accounts  are  to  be  used  for  the
     temporary  deposit of funds which cannot be credited to
     specific accounts  or  readily  distributed.   The Code
     further states that the interest earned on principal in
     special deposit accounts is to be distributed with  the
     related  principal.   At  December 31, 1996, the Agency
     had  293  special  deposit  accounts,   with   balances
     totaling    about    $671,000,    that   consisted   of
     undistributed agricultural lease rents and grazing fees
     and  accrued  interest.  Based on our  analysis  of  66
     special deposit  accounts, with balances totaling about
     $290,000, we found  that the rents and fees and related
     interest  had not been  distributed  to  landowners  as
     follows:

                   ---------------------------
                   | Year         |Amounts
                   |Deposited     | Not
                   |              |Distributed
                   ---------------------------
                   1996               $101,744
                   ---------------------------
                   1995                 27,840
                   ---------------------------
                   1994                 10,118
                   ---------------------------
                   Prior to 1994       150,050
                   ---------------------------
                   Total|            |$289,752
                   ---------------------------

The  Agency's  realty   and   land   operations  staff  were
responsible for ensuring that funds in  the  special deposit
accounts,  including  interest  earned, were distributed  to
landowners.  However, the Agency  did not have procedures to
ensure that funds in special deposit  accounts were analyzed
and distributed, and the Agency did not  dedicate sufficient
personnel  resources  to  analyze  special  deposit  account
balances and land ownership records in order  to  distribute
these funds.  Consequently, landowners were not provided the
funds to which they were legally entitled.

The January 1998 Office of Inspector General audit report on
the Office of the Special Trustee's financial statements for
fiscal   year   1996   identified  significant  deficiencies
relating  to "reportable  conditions"  for  special  deposit
accounts.[8]    The  report  made  four  recommendations  to
correct  special deposit  account  deficiencies  similar  to
those that  we  identified during our current review.  These
recommendations included  performing an analysis of accounts
(Recommendation 20); establishing  policies  and  procedures
for  using  special  deposit  accounts (Recommendation  24);
establishing an adequate system,  policies,  and  procedures
for determining interest earned for Individual Indian  Money
account   holders   (Recommendation  25);  and  establishing
controls to verify that  items  are  cleared (Recommendation

7).   We considered these recommendation  resolved  but  not
implemented.    We  believe  that  implementation  of  these
recommendations will correct the deficiencies in the special
deposit accounts  that  we  identified  during  our  current
review.   In  addition,  the  deficiencies identified in the
January 1998 report have been incorporated  into  subproject
plans  of  the High Level Implementation Plan for the  Trust
Management Improvement  Project approved by the Secretary of
the Interior on July 31,  1998.   Implementation of the Plan
will  be monitored by the Assistant  Secretary  for  Policy,
Management   and   Budget.    Therefore,  we  have  made  no
recommendations in our current  report with respect to these
issues.


**FOOTNOTES**

[7]:The Bureau is responsible  for  administering  leases
and permits on tribal and individually owned land. However,
the Department's  Office of the Special Trustee for American
Indians is responsible for establishing proper   controls
for  managing  trust  funds,  including  trust  funds
deposited in the Individual Indian Money accounts system,
which includes special deposit accounts.

[8]:The report  defined a "reportable condition" as a matter
relating to significant deficiencies  in  the  design  or
operation  of the internal control  structure  that,  in
the  auditors'  judgment, could adversely affect  the
Office of  Trust  Funds  Management's  ability  to  record,
process,  summarize,  and  report  financial  data consistent
with  the assertions of management in the financial statements.


             STATUS OF AUDIT REPORT RECOMMENDATIONS


-----------------------------------------------------------------
Finding/
Recommendation
Reference        Status                           Action Required

-----------------------------------------------------------------
1, 3, 4,    Implemented.           No further action is required.
and 5
-----------------------------------------------------------------
2  Unresolved.  Provide a response to the revised recommendation.
If
     concurrence is indicated, provide a plan identifying actions
      to be taken, including the target date and the title of the
                         official responsible for implementation.
If nonconcurrence
                   is indicated, provide specific reasons for the
                                                  nonconcurrence.
-----------------------------------------------------------------




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1550 Wilson Boulevard
Suite 410
Arlington, Virginia 22209

Calling:
(703) 235-9221


North Pacific Region

U.S. Department of the Interior
Office of Inspector General
North Pacific Region
238 Archbishop F.C. F'lores Street
Suite 807, PDN Building
Agana, Guam 96910


Calling:
(700) 550-7428 or
COMM 9-011-671-472-7279