[Audit Report on Followup of Recommendations for Improving General Controls Over Automated Information Systems, Bureau of Indian Affairs]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 99-i-654

Title: Audit Report on Followup of Recommendations for Improving
       General Controls Over Automated Information Systems, Bureau
       of Indian Affairs


Date:  July 26, 1999




                  **********DISCLAIMER**********

This file contains an ASCII representation of an OIG report.
No attempt has been made to display graphic images or
illustrations. Some tables may be included, but may not resemble
those in the printed version.

A printed copy of this report may be obtained by referring to the
PDF file or by calling the Office of Inspector General, Division
of Acquisition and Management Operations at (202) 208-4599.

                  ******************************





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



AUDIT REPORT
FOLLOWUP OF RECOMMENDATIONS FOR
IMPROVING GENERAL CONTROLS OVER
AUTOMATED INFORMATION SYSTEMS,
BUREAU OF INDIAN AFFAIRS



REPORT NO. 99-I-654

JULY 1999




MEMORANDUM

             TO:  The Secretary

           FROM:  Robert J. Williams
                  Acting Inspector General

SUBJECT SUMMARY:  Final Audit Report - "Followup of
                  Recommendations for Improving General Controls
                  Over Automated Information Systems, Bureau of
                  Indian Affairs" (No. 99-i-654)

Attached for your information is a copy of the subject final
audit report. The objective of our audit was to determine whether
the Bureau of Indian Affairs had satisfactorily implemented the
recommendations made in our April 1997 audit report (No.
97-I-771) on the general controls over automated information
systems of the Bureau's Operations Service Center and in our June
1998 audit report (No. 98-I-483) on the followup of  the Center's
general controls.  We also determined whether any new
recommendations were warranted. 

The general controls over the Bureau's automated information
systems were ineffective in the areas of its security program,
access controls, software development and change controls,
segregation of duties, and continuity of service.  This occurred
because Bureau management had not ensured that the
recommendations contained in our April 1997 and June 1998 audit
reports were implemented. 

Since the recommendations have not been implemented, the Bureau
is at risk of loss, misuse, modification of, or unauthorized
access to the data in its automated information systems.  Because
the Bureau has not made significant progress in correcting
deficiencies in the general controls over its automated systems,
we believe that the Bureau is not in compliance with the Federal
Financial Management Improvement Act and should report these
deficiencies to the Department of the Interior as a material
weakness in the Bureau's annual assurance statement on management
controls, which is required by the Federal Managers' Financial
Integrity Act.

Based on the Bureau's response to the draft report, we considered
the one new recommendation contained in our current report
resolved but not implemented.  Regarding our April 1997 report,
we considered 2 recommendations resolved and implemented and 10
recommendations resolved but not implemented. Regarding our June
1998 report, we considered three recommendations resolved and
implemented and the remaining five recommendations resolved but
not implemented. 

If you have any questions concerning this matter, please contact
me at (202) 208-4252.


Attachment

cc:Chief of Staff
Assistant Secretary for Indian Affairs
Director, Office of Communications



                                                A-IN-BIA-002-98-M

AUDIT REPORT

Memorandum

     To:  Assistant Secretary for Indian Affairs

   From:  Robert J. Williams
          Assistant Inspector General for Audits

Subject:  Audit Report on Followup of Recommendations for
          Improving General Controls Over Automated Information
          Systems, Bureau of Indian Affairs (No. 99-i-654)


INTRODUCTION

This report presents the results of our audit of the
implementation of recommendations contained in our April 1997
audit report titled "General Controls Over Automated Information
Systems, Operations Service Center, Bureau of Indian Affairs"
(No. 97-I-771) and our June 1998 audit report titled "Followup of
General Controls Over Automated Information Systems, Operations
Service Center, Bureau of Indian Affairs" (No. 98-I-483).  The
objective of our audit was to determine whether the Bureau of
Indian Affairs had satisfactorily implemented the recommendations
made in our prior audit reports and whether any new
recommendations were warranted.  This audit supports the Office
of Inspector General's opinion on the financial statements of the
Bureau and the Office of the Special Trustee for American Indians
by evaluating the reliability of the general controls over
computer-generated data that support the Bureau's and the Office
of the Special Trustee's  financial statements.

BACKGROUND

The Bureau's Office of Information Resources Management, through
its Operations Service Center, both located in Albuquerque, New
Mexico, is responsible for administering the general controls
over the Bureau's and the Office of the Special Trustee's
automated information systems.  The Center provides computer
services such as communications networks, software development,
operations, and maintenance; systems recovery; and user support.
The Center operates a Unisys server that is used to run the
Office of the Special Trustee's applications, such as the
Individual Indian Monies, and Bureau applications that support
Indian trust fund accounts.  The Center also operated an IBM
mainframe computer until December 1997, when the Bureau
transferred its IBM operations and data processing functions to a
host IBM mainframe computer owned by the U.S. Geological Survey's
Enterprise Data Service Center, located in Reston, Virginia.  The
Geological Survey's IBM computer is used to run Bureau
applications, such as the Land Records Information System and the
National Irrigation Information Management System. 

SCOPE OF AUDIT

Our audit included an evaluation of actions taken by Bureau
management to implement the 12 recommendations contained in our
April 1997 audit report and the 8 recommendations contained in
our June 1998 audit report and a review of the general controls
in place during fiscal year 1998.  To accomplish our objective,
we interviewed personnel at the Operations Service Center of the
Bureau's Office of Information Resources Management, contractor
personnel, and personnel at the Geological Survey's Enterprise
Data Service Center.  We reviewed the Bureau's policies and
procedures as they related to the Bureau's computer operations,
analyzed system security, and reviewed and tested implementation
of the prior audit reports' recommendations.  Because the highest
priority of Center personnel at the time of our review was
remedying applications for year 2000 (Y2K) compliancy, the
availability of Center personnel was limited.  Therefore,  we
performed limited testing of controls over the Unisys server.  

The 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 to accomplish our audit objective.

As part of our audit, we evaluated the Bureau's general controls
over its automated information systems that could adversely
affect the data processing environment.  The control weaknesses
identified are discussed in the Results of Audit section.
Because of inherent limitations in any system of internal
controls, losses, noncompliance, or misstatements may occur and
not be detected.  We also caution that projecting our evaluations
to future periods is subject to the risk that controls or the
degree of compliance with the controls may diminish.

RESULTS OF AUDIT

We concluded that the general controls over the Bureau of Indian
Affairs automated information systems were ineffective in the
areas of its security program, access controls, software
development and change controls, segregation of duties, and
continuity of service. The Bureau continued to have ineffective
general controls because Bureau management had not ensured that
the recommendations contained in our April 1997 and June 1998
audit reports were implemented (see Appendices 1 and 2,
respectively).  Specifically, of the 20 recommendations from our
prior audit reports, the Bureau had implemented 3 recommendations
and had partially implemented 6 recommendations, but it had not
implemented the remaining 11 recommendations.  Office of
Management and Budget Circular A-123, "Management Accountability
and Control," states:  

Resolution of Audit Findings and Other Deficiencies.  Managers
should promptly evaluate and determine proper actions in response
to known deficiencies, reported audit and other findings, and
related recommendations.  Managers should complete, within
established time frames, all actions that correct or otherwise
resolve the appropriate matters brought to management's
attention. . . . Correcting deficiencies is an integral part of
management accountability and must be considered a priority by
the agency. [Managers are required to report in their annual
integrity report to the President and the Congress any
significant deficiencies and related risks.]  

In addition, Circular A-123 states that deficiencies which are
significant should be considered a "material weakness."  It
further states that deficiencies are significant when the
management controls (1) do not provide assurance that assets are
safeguarded against waste, loss, unauthorized use, or
misappropriation and (2) are not adequate to protect the
integrity of Federal programs or to ensure that resources are
used consistent with the agency's mission; laws and regulations
are followed; and reliable and timely information is obtained,
maintained, reported, and used for decision making.

Additionally, publications of the Office of Management and Budget
and the National Institute of Standards and Technology require
Federal agencies to establish and implement management and
internal controls to protect sensitive information in general
support[1] and major application systems.  Office of Management
and Budget Circular A-130, Appendix III, "Security of Federal
Automated Information Resources," states:

Agencies shall implement and maintain a program to assure that
adequate security is provided for all agency information
collected, processed, transmitted, stored, or disseminated in
general support systems and major applications.  Adequate
security means security commensurate with the risk and magnitude
of the harm resulting from the loss, misuse, or unauthorized
access to or modification of information.  This includes assuring
that systems and applications used by the agency operate
effectively and provide appropriate confidentiality, integrity,
and availability, through the use of cost-effective management,
personnel, operational, and technical controls.

Since the recommendations from our prior audit reports have not
been implemented, the Bureau is at risk of loss, misuse,
modification of, or unauthorized access to the data in its
automated information systems. Further, because the Bureau had
not made significant progress in correcting deficiencies in the
general controls over its automated systems, we believe that the
Bureau is not in compliance with the Federal Financial Management
Improvement Act and should report these deficiencies to the
Department as a material weakness in the Bureau's annual
assurance statement on management controls, which is required by
the Federal Managers' Financial Integrity Act.

The impact on the Bureau's general controls as a result  of the
Bureau's lack of implementation of the related recommendations is
discussed in the sections that follow. 

System Security Program

The Bureau did not have an effective system security program that
included an information resource management strategic plan,
periodic risk assessments, periodic assessments of the system
security program's effectiveness, and personnel security policies
and procedures to ensure that appropriate security clearances for
personnel in sensitive or critical automated data processing
(ADP) positions were obtained.  We made nine recommendations
relating to this weakness in the prior reports (Nos. A.1, A.2,
A.3, and B.1 in our April 1997 report (see Appendix 1) and Nos.
A.1, A.2, A.3, A.4, and A.5 in our June 1998 report (see Appendix
2)). During our current audit, we found that the Bureau had
implemented one recommendation and had partially implemented two
recommendations, but it had not implemented the remaining six
recommendations.  Therefore, the Bureau had little assurance that
its information resources were used and managed effectively to
accomplish its mission or that established controls could be
relied on to protect mission-based sensitive computer systems and
data.  

Access Controls 

Physical and logical access controls over the Bureau's automated
information systems were ineffective.  Specifically, the Bureau
did not classify its resources to determine the level of security
necessary, monitor visitor activities while at the Center,
perform periodic reviews to ensure that users' access levels to
the mainframe computers were appropriate, and change passwords to
access the Unisys computer periodically.  We made six
recommendations relating to this weakness in the prior reports
(Nos. C.1, D.1, D.2, and E.1 in our April 1997 report (see
Appendix 1) and Nos. A.6 and A.7 in our June 1998 report (see
Appendix 2)).  During our current audit, we found that the Bureau
had partially implemented two recommendations but had not
implemented four recommendations.  Therefore, the Bureau had
little assurance that the most cost-effective access controls
were in place to protect its computer resources; that the
computer resources located in the Center's computer operations
room, such as the mainframe computer, local area network (LAN)
equipment, and daily backup tape libraries, were safeguarded from
dust or fire hazards; that user access was assigned at the
appropriate level; and that password controls were adequate.  

Software Development and Change Controls

Software development and change controls were inadequate to
ensure that the proper version of an application was used in
production.  For example, the programmers of the National
Irrigation Information Management System and the Loan Management
Accounting System not only programmed the application but also
tested, authorized, and approved the movement of the modified
programs from test or development into production.  In addition,
requests to change or modify the applications were not fully
documented. We made one  recommendation relating to this weakness
in the prior report (No. G.1 in our April 1997 report (see
Appendix 1)).  During our current audit, we found that the Bureau
had not implemented this recommendation.  Therefore, the Bureau
had little assurance that only authorized programs and authorized
modifications were implemented; that all programs and program
modifications were properly authorized, tested, and approved; and
that access to and distribution of programs were carefully
controlled.  

Segregation of Duties

Duties were inadequately segregated for the systems support
functions in the areas of system design, applications
programming, systems programming, quality assurance/testing,
library management, change management, data control, data
security, and data administration.  We made one recommendation
relating to this weakness in the prior report (No. H.1 in our
April 1997 report (see Appendix 1)).  During our current audit,
we found that the Bureau had partially implemented this
recommendation because the IBM computer operations, such as
system design and system programming, were transferred to the
Geological Survey.  However, the Bureau's separation of duties
for system functions continued to be inadequate in the areas of
applications programming, quality assurance/testing, library
management, change management, data security, and data
administration.  Therefore, the Bureau had little assurance that
programmers were making only authorized program changes; that
computer programmers were independently writing, testing, and
approving program changes; or that errors or illegal acts would
be detected or detected timely.  

Service Continuity

The Center did not have an effective means of recovering or of
continuing computer operations in the event of system failure or
disaster.  Specifically, the Bureau's backup information, such as
software applications and databases, was stored on-site in the
Center's computer operations room rather than in an off-site
storage facility.  We made two recommendations relating to this
weakness in the prior reports  (No. J.1 in our April 1997 report
(see Appendix 1) and No. A.8 in our June 1998 report (see
Appendix 2)).  During our current review, we found that the
Bureau had implemented one recommendation and had partially
implemented the other recommendation.  Therefore, there was no
assurance that the Center would be able to recover or resume
critical computer operations in the event  a system failed or a
disaster occurred. 

Recommendation

We recommend that the Assistant Secretary for Indian Affairs
report the Bureau's ineffective general controls over its
automated information systems as a material weakness in the
Bureau's annual assurance statement, which is required by the
Federal Managers' Financial Integrity Act.  

Bureau of Indian Affairs Response and Office of Inspector General
Reply

In the June 3, 1999, response (Appendix 3) to the draft report
from the Assistant Secretary for Indian Affairs, the Bureau
concurred with the recommendation.  Based on the response and
subsequent discussions, we consider the recommendation resolved
but not implemented.  Accordingly, the recommendation will be
forwarded to the Assistant Secretary for Policy, Management and
Budget for tracking of implementation (see Appendix 4).  

Regarding our April 1997 report, the Bureau, in its June 1999
response, included a revised corrective action plan.  Based on
our current audit and the Bureau's response, we consider 2
recommendations (Nos. H.1 and I.1) resolved and implemented and
10 recommendations (Nos. A.1, A.2, A.3, B.1, C.1, D.1, D.2, E.1,
G.1, and J.1) resolved but not implemented.  Accordingly, the
updated information on the prior recommendations will be
forwarded to the Assistant Secretary for Policy, Management and
Budget (see Appendix 5).

Regarding our June 1998 report, the Bureau, in its June 1999
response, included a revised corrective action plan.  Based on
our current audit and the Bureau's response, we consider three
recommendations (Nos. A.1, A.3, and A.8) resolved and implemented
and the remaining five recommendations (Nos. A.2, A.4, A.5, A.6,
and A.7) resolved but not implemented.  Accordingly, the updated
information on the prior recommendations will be forwarded to the
Assistant Secretary for Policy, Management and Budget (see
Appendix 6).

Since the recommendation contained in this report is considered
resolved, no further response to the Office of Inspector General
is required (see Appendix 4).

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 personnel in the conduct
of our audit.

**FOOTNOTES**

[1]:Office of Management and Budget Circular A-130 defines a
general support system or system to mean "an interconnected set
of information resources under the same direct management control
which shares common functionality.  A system normally includes
hardware, software, information, data, applications,
communications and people."


APPENDIX 1
Page 1 of 7

SUMMARY OF RECOMMENDATIONS AND CORRECTIVE ACTIONS 
FOR AUDIT REPORT

"GENERAL CONTROLS OVER AUTOMATED INFORMATION SYSTEMS,
OPERATIONS SERVICE CENTER, 

BUREAU OF INDIAN AFFAIRS" (NO. 97-I-771)


Recommendations

A.1.  The information technology security function is elevated
organizationally to at least report directly to the Director,
Office of Information Resources Management; is formally provided
with authority to implement and enforce a Bureauwide system
security program; and is provided staff to perform the required
duties, such as providing computer security awareness training
and performing periodic risk assessments.

Status of Recommendations and 
Corrective Actions

Partially implemented.  The Bureau of Indian Affairs stated that
the Information Technology (IT) Security Manager had reported to
the Director, Office of Information Resources Management, since
October 1997 and that the position had Bureauwide authority for
the information technology security program. The Bureau also
stated that sufficient staff would be available to manage
security requirements once the transfer to the host IBM computer
at the U.S. Geological Survey had taken place.  We found that the
Security Manager reported to the Director, Office of Information
Resources Management; however, we did not find that the Security
Manager had acted on the authority to implement a Bureauwide
security plan.  Although authority is implied in the position
description, the Bureau had not ensured that the Security
Manager's authority was recognized by all Bureau personnel.  In
addition, the Security Manager  is physically located  at the
Operations Service Center and has focused on Center security and
user access to the IBM mainframe and Unisys server rather than on
Bureauwide system security issues.  We also found that additional
staff had not been assigned to assist in providing security
awareness training and performing risk assessments when the IBM
operations were transferred to the host computer at the
Geological Survey. 

A.2   A system security program is developed and documented which
includes the information required by the Computer Security Act of
1987 and Office of Management and Budget Circular A-130, Appendix
III, "Security of Federal Automated Information Resources," and
policies and procedures are implemented to keep the system
security program current.

Not implemented. The Bureau stated that it had entered into an
agreement with the Geological Survey's Washington Administrative
Service Center - West to develop, by July 31, 1998, a
comprehensive security plan.  The "Bureau of Indian Affairs
Logical Security Internal Procedures Manual"  was delivered to
the Bureau during our site visit in September 1998.  However, the
plan was not Bureau specific but rather an overview of the
Geological Survey's security for its IBM computer located in
Reston, Virginia. Additionally, we found that policies and
procedures were not developed and implemented to keep the system
security program current.

A.3.  The Bureau's security personnel perform risk assessments of
the Bureau's automated information systems environment and, as
appropriate, provide assurance that the necessary changes are
implemented to manage the risks identified.

Not implemented.  The Bureau stated that its information systems
security staff would oversee this effort beginning in fiscal year
1999.  However, we found that management had not developed a
security program; therefore, plans had not been developed to
begin risk assessments in fiscal year 1999. 

B.1.  Ensure that personnel security policies and procedures are
developed, implemented, and enforced, including those for
obtaining appropriate security clearances for personnel in
sensitive or critical automated data processing (ADP) positions
and for informing the security staff, in writing, whenever
employees who are system users terminate their employment or are
transferred.

Partially implemented.  The Bureau stated that it had reorganized
its position sensitivity program and that, as part of the effort,
it had begun to review all sensitive positions.  We found that
personnel policies and procedures had not been developed or
implemented to ensure that appropriate security clearances for
personnel in sensitive or critical ADP positions were obtained or
that security staff were notified in writing when employees
terminated their employment or were transferred.  However, during
our site visit, the Security Manager was working with the
Bureau's Central Office in reviewing the sensitivity levels of
personnel assigned to the Operations Service Center.  In
addition, the Bureau stated that the Security Manager would
ensure that the employee termination report was received and
reconciled with system users.  During our site visit, Bureau
management had not agreed on how the termination report would be
provided to the Security Manager.

C.1.  Develop and implement policies to classify the Bureau's
computer resources in accordance with the results of periodic
risk assessments and guidance contained in Office of Management
and Budget Circular A-130, Appendix III.

Not implemented. The Bureau stated that risk assessments and
classifications of its automated information systems environment
would be performed beginning in fiscal year 1999 in accordance
with its security program plan.  According to the Bureau,
assessments would be performed by teams consisting of personnel
from the Bureau's Office of Information Resources Management and
program offices.  We found that policies which would ensure that
computer resources were classified in accordance with Circular
A-130 had not been developed or implemented.

D.1.  Ensure that sufficient staff are provided to adequately
monitor all visitor activities.

Not implemented.  The Bureau stated that the recommendation had
been implemented to the extent possible given the Bureau's
available resources.  The Bureau further stated that the
organizational element receiving the visitors would monitor
visitor activities.  We found, during our site visit, that Center
management did not consistently monitor visitors' activities.

D.2. Ensure that funding is provided for adequate maintenance of
the computer operations room, such as providing daily
housekeeping services, or that fire-producing equipment and
supplies are removed from the computer room.

Partially implemented.  The Bureau stated that it had provided
funds to the Center for full-time housekeeping and maintenance
services for the computer room beginning in fiscal year 1998.  We
found that the Bureau had provided for daily housekeeping
services and that the fire-producing equipment was no longer in
use.  Although housekeeping services were being performed and the
fire-producing equipment identified in the prior report was no
longer in use, the Center was using the computer operations room
as a storage facility, which increased the risk of equipment
failure and other fire hazards.  For example, cardboard boxes of
old records and old computer equipment were stored in the
computer operations room.

E.1.  Ensure that policies are developed and implemented which
match personnel files with system users periodically, that user
identifications (IDs) are deleted from the system for users whose
employment had been terminated, and that verification and
approval are obtained from user supervisors and application
owners or managers that the levels of access are appropriate.

Not implemented.  The Bureau did not address this recommendation.
We found that  new or revised policies had not been developed
which would  match personnel files with system users
periodically, delete user IDs from the system for users whose
employment had been terminated, and ensure that verifications and
approvals were obtained from users' supervisors and application
owners that the users' levels of access were appropriate.  

F.1.  Ensure that a higher priority is given to moving the
applications that reside on the Unisys mainframe to the IBM
mainframe.

Resolved.  In the June 1998 audit report, we recognized that the
recommendation was no longer applicable because the Bureau had
determined that the Unisys applications could not be moved to the
IBM mainframe.  

G.1.  Ensure that policies and procedures are developed and
implemented which clearly identify the individuals responsible
and accountable for application development and changes.

Not implemented.  The Bureau stated that the Applications Support
Branch would develop the policies and procedures.  However, we
found that the Branch's highest priority was the Bureau's Y2K
effort;  thus, the policies and procedures had not been
developed.

H.1.  Ensure that staffing at the Center is evaluated and
adjusted so that duties for critical system support functions are
adequately segregated and fully utilized.

Implemented.  The Bureau did not address this recommendation  in
its responses to our prior audit reports; however, for the IBM
mainframe applications, the recommendation was resolved with the
transfer of the Bureau's mainframe operations to the Geological
Survey's host computer. We could not verify whether the critical
system support functions for the Unisys server were adjusted
during our fieldwork because Center personnel were involved with
the Bureau's Y2K testing and were therefore not available.  Based
on the Bureau's  June 3, 1999, response to the draft report, we
consider the  recommendation implemented because the Bureau
stated that it is examining organizational changes and personnel
assignments to ensure that duties are separated.  The Bureau
further stated that it will continue to monitor its progress in
separating critical system support  functions.

I.1.  Ensure that access and activities of the Center's system
programmers are controlled and monitored by security staff and
that RACF controls are established to protect system resources.

Implemented.  The Bureau transferred its IBM computer operations
to the Geological Survey's host computer.  After the transfer,
the Geological Survey established the appropriate RACF controls
that would protect the system resources, which included denying
the Bureau's system programmer access to the IBM computer's
system controls.  

J.1.  Ensure that a contingency plan is developed and tested and
that funding is provided for acquiring a secure off-site storage
facility.

Partially implemented.  The Bureau stated that it had a disaster
recovery contract which fully tested and certified the
Unisys-hosted applications.  However, although a contingency plan
had not been developed, the Bureau had contracted for a backup
site for the Unisys server in the event of a disaster and had
tested the functionality of the backup site.  The Geological
Survey is responsible for contingency planning for the Bureau's
IBM applications that reside on the Geological Survey's host
computer.  Additionally, although the Bureau had provided funding
for off-site storage of its backup media, the Center had not used
the site.  The Bureau's backup media were stored on-site in the
Center's computer operations room.


APPENDIX 1
Page 2 of 7

Recommendations

Status of Recommendations and
Corrective Actions

SUMMARY OF RECOMMENDATIONS AND CORRECTIVE
ACTIONS FOR AUDIT REPORT
"FOLLOWUP OF GENERAL CONTROLS OVER AUTOMATED INFORMATION
SYSTEMS, OPERATIONS SERVICE CENTER,
BUREAU OF INDIAN AFFAIRS" (NO. 98-I-483)


Recommendations

Status of Recommendations and 
Corrective Actions

A.1.  Establish as a high priority the use of the Geological
Survey's host computer's operating, security, and automated job
scheduling systems.

Implemented.  The Bureau of Indian Affairs transferred its IBM
mainframe operations to the Geological Survey's host computer in
December 1997.  We reported this recommendation as implemented in
our June 1998 audit report.

A.2.  Develop and approve an Office of Information Resources
Management strategic plan that provides direction to and defines
the functions of the Operations Service Center.

Not implemented.  The Bureau stated that a strategic plan for the
Office of Information Resources Management was being developed
and finalized under a contract.  The strategic plan was to have
been completed by September 30, 1998. We found that the contract,
dated March 9, 1998, was to support the Bureau's overall
Information Resources Management strategic and tactical plans.
However, contract  performance was based on task orders, and at
the time of our site visit, a task order had not been  issued to
develop a strategic plan.

A.3.  Hold the Information Technology (IT) Security Manager
accountable for performing the position responsibilities.

Implemented.  The Bureau stated that the IT Security Manager
would be held accountable through the performance appraisal
process.  However, we found that the IT Security Manager had not
been held accountable for not implementing a Bureauwide security
program, providing security awareness training, or performing
risk assessments.  Additionally, the IT Security Manager
performed the functions of a local area network (LAN)
administrator, which was not part of the IT Security Manager's
duties.  Based on the Bureau's June 3, 1999, response to the
draft report, we considered the recommendation implemented
because the Bureau stated in its response that the IT Security
Manager will be evaluated based on his performance standards and
position description.  The response further stated that the
Division of Information Resources Management is in the process of
"augmenting its IT security staff."

A.4.  Periodically perform an evaluation of the system security
program's effectiveness and include any resultant corrective
actions in future Bureau security plans.

Not implemented.  The Bureau stated that it had entered into an
agreement with the  Washington Administrative Service Center -
West to develop a comprehensive computer security plan.  The
plan's operating procedures and the management control reviews
required by the Department of the Interior's Office of
Information Resources Management would ensure that the plan would
be reviewed periodically and updated.  The plan was to have been
developed by July 31, 1998.  The Center received the "Bureau of
Indian Affairs Logical Security Internal Procedures Manual" in
September 1998.  We found that the "Manual" was not Bureau
specific but generally related to the Geological Survey and did
not provide procedures for performing evaluations of the  system
security program.  In addition, an evaluation of the system
security program's effectiveness had not been performed in fiscal
years 1996, 1997, or 1998.

A.5.  Redetermine, based on the Office of Information Resources
Management's strategic plan, when the Bureau can begin performing
risk assessments and classifying its resources.  Also, personnel
who will be responsible for the risk assessments and resource
classifications should be identified.

Not implemented.  The Bureau stated that risk assessments and
classifications of its automated information systems environment
would be performed beginning in fiscal year 1999 in accordance
with its security program plan.  However, the Bureau had not
developed a security program; therefore, plans had not been
developed to begin risk assessments in fiscal year 1999, and
personnel responsible for the risk assessments and resource
classifications had not been identified.

A.6.  Obtain security clearances for ADP personnel who are not
assigned to the Center that are commensurate with their
positions.

Not implemented.  The Bureau had begun  to review and reassign
security clearances for ADP personnel as a result of a Bureauwide
initiative started in February 1998.  During our site visit, the
Security Manager was reviewing security clearances for Center
personnel but had not begun to review clearances for personnel
outside the Center.

A.7.  Require Bureau staff to review and validate the
appropriateness of users' levels of access to the Bureau's IBM
applications.  If the users' levels of access are not reviewed
and validated by Bureau personnel, the Bureau should modify its
agreement with the Geological Survey to include the requirements
that access reviews and verifications should be performed for the
IBM applications by the Geological Survey.

Partially implemented.  Under the direction of personnel of the
Geological Survey's Enterprise Data Service Center, the Security
Manager had begun to review the appropriateness of users' levels
of access to the Bureau's IBM applications.  Although the Bureau
had begun negotiations with the Geological Survey  to ensure that
users' levels of access were reviewed jointly by the Bureau and
the Geological Survey, the Bureau had not finalized the
negotiations by signing the agreement.

A.8.  Remove all safety hazards from the computer operations
room.  

Implemented.  The Bureau stated that safety hazards had been
removed.  During our site visit, we found that the safety hazards
had been removed.  


APPENDIX 2
Page 4 of 4

Recommendations

Status of Recommendations and 
Corrective Actions           


APPENDIX 4

STATUS OF CURRENT AUDIT REPORT RECOMMENDATION


Finding/Recommendation
Reference

Status

Action Required
1
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.


APPENDIX 2
Page 4 of 4

Recommendations
Status of Recommendations and 
Corrective Actions


APPENDIX 5

STATUS OF APRIL 1997 AUDIT REPORT RECOMMENDATIONS

Finding/Recommendation
Reference

Status

Action Required
H.1 and I.1

Implemented.
No further action is required.

A.1, A.2, A.3, B.1, C.1, D.1, D.2, E.1, G.1, and J.1
Resolved; not implemented.

No further response to the Office of Inspector General is
required.  The recommendations and the revised corrective action
plan will be forwarded to the Assistant Secretary for Policy,
Management and Budget for tracking of implementation.


APPENDIX 2
Page 4 of 4

Recommendations

Status of Recommendations and 
Corrective Actions


APPENDIX 6

STATUS OF JUNE 1998 AUDIT REPORT RECOMMENDATIONS


Finding/Recommendation
Reference

Status

Action Required
A.1, A.3, and A.8
Implemented.
No further action is required.

A.2, A.4, A.5, A.6, and A.7
Resolved; not implemented.

No further response to the Office of Inspector General is
required.  The recommendations and the revised corrective action
plan will be forwarded to the Assistant Secretary for Policy,
Management and Budget for tracking of implementation.




ILLEGAL OR WASTEFUL ACTIVITIES SHOULD BE REPORTED

TO THE OFFICE OF INSPECTOR GENERAL BY:

Sending written documents to:



Within the Continental United States

U.S. Department of the Interior
Office of Inspector General
1849 C Street,N.W.
Mail Stop 5341
Washington, D.C. 20240

Calling:

Our 24 hour
Telephone HOTLINE
1-800-424-5081 or
(202) 208-5300

TDD for hearing impaired
(202) 208-2420 or
1-800-354-0996



Outside the Continental United States


Caribbean Region

U.S. Department of the Interior
Office of Inspector General
Eastern Division- Investigations
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