I , IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ELOUISE PEPION COBELL, A, Plaintiffs, V. 1 ) 1 1 1 1 Case No. 1 :96CV01285 (Judge Lamberth) GALE NORTON, Secretary of the Interior, gt &, Defendants. ) 1 1 NOTICE OF FILING OF INTERIOR'S COMPREHENSIVE TRUST MANAGEMENT PLAN Interior Defendants hereby give notice of the filing of their Comprehensive Trust Management Plan, as referenced in Interior's Status Report to the Court Number Thirteen. A copy of the Comprehensive Trust Management Plan is attached hereto. Respectfully submitted, Dated: May 1 , 2003 ROBERT D. McCALLUM Assis tan t Attorney General STUART E. SCHIFFER Deputy Assistant Attorney General SAmRA P. SPOONER Deputy Director D.C. Bar No. 261495 JOHN T. STEMPLEWICZ Senior Trial Counsel PETER B. MILLER Trial Counsel Commercial Litigation Branch Civil Division P.O. Box 875 Ben Franklin Station Washington, D.C. 20044-0875 (202) 5 14-7 194 CERTIFICATE OF SERVICE I declare under penalty of perjury that, on May 1,2003 I served the foregoing Notice of Filing of Interior's Comprehensive Trust Munagenrent Plan by Hand upon: Keith Harper, Esq. Native American Rights Fund 1712 N Street, N.W. Washington, D.C. 20036-2976 Dennis M Gingold, Esq. Mark Kester Brown, Esq 1275 Pennsylvania Avenue, N.W. Ninth Floor Washington, D.C. 20004 By US. Mail upon: Elliott Levitas, Esq 1 100 Peachtree Street, Suite 2800 Atlanta, GA 30309-4530 By Hand upon: Alan L. Balaran, Esq. Special Master 171 7 Pennsylvania Avenue, N.W. 13th Floor Washington, D.C. 20006 Per the Court's Order of April 17,2003, by U.S. Mail upon: Earl Old Person (Pro se) Blackfeet Tribe P.O. Box 850 Browning, MT 594 17 Department of the Interior ‘i I I Comprehensive Trust Management Plan March 28, 2003 Preface 001 Prop rie in ry In form a tion From 1998 until January 2002, the Department of the Interior’s (DOI’s) Indian fiduciary’ trust management reform efforts focused on completing the Trust Management Improvement Project, as outlined in the lfzgh Level Implementation PIun (HLIP). The HLIP, amended in February 2000, detailed numerous trust management reform tasks. Although many of the tasks in the HLIP have been completed, DO1 has not achieved the desired improvement in trust management because the tasks were not linked to an overall strategy. In January 2002, the Secretary of the interior, through the Office of Indian Trust Transition ( O l n ) , launched an effort to develop a comprehensive approach for improving Indian trust management. Working with the Office of the Special Trus- tee for American Indians and Bureau of Indian Affairs leadership, the OITT staff developed a set of goals, ohiectives, and tasks for reforming Indian trust manage- ment. This work was based upon statutes, regulations, guiding principles in the Dcrprtmentul Munuuf, and reports prepared by Electronic Data Systems. In May 2002, this effort was expanded and a DOI-wide strategic planning team was created that included representatives from national and regional offices of the Office of the Special Trustee for American Indians, Bureau of Indian Affairs, Minerals Management Service, and Bureau of Land Management. From May 2002 through December 2002, the DO1 strategic planning team met regularly to review and update the goals and objectives. It also presented them to the Joint DOUTribal Leaders Task Force for approval. After several meetings, the task force’s subcommittee on planning approved the goals and objectives, Although the DO1 strategic planning team is developing a comprehensive strategy for improving Indian trust management, many of the associated tasks that need to be accomplished have been held in abeyance awaiting completion of the “As-1s” business modeling project. That project is nearing completion with a draft report dated February 14,2003, having been submitted to Interior for consideration and review. As a result of the planning effort initiated by the Secretary in January 2002, this finid Comprehensive Trust Manngement Plan Version 1.0 was developed. It pres- ents a strategic plan to guide the design and implementation of integrated trust refonn efforts.’ As this plan develops new versions will be published. I The term fiduciary trust refers to the trust created by virtue ofthe United States holding title or control over assets belonging to an American Indian individual or tribe. This is to be distin- guished from the general trust responsibility of the United States for Indians, in particular, dealing with appropriated program funds. ’ This plan is intended to be a DO1 working document. It is not intended to, and does not, cre- ate any legal right or benefit, substantive or procedural, enforceable by a party against the United States, its agencies, or instrumentalities, 11s officers or employees, or any other person. iii Comprehensive Trust h4anagement Plan Version 1 .O 3/28/03 tions and to adapt to changing environments. hensive Trust Management Plnn. DO1 Proprietary Information The Department of the Intenor (DOI) is committed to fulfilling its trust responsi- bilities to Arnencan Indians and Alaska Natives effectively and efficiently. It also is committed to providing excellent service to the beneficiaries of that trust. To fulfill its trust responsibilities effectively and efficiently, Interior must have an overall strategic plan to guide the design and implementation of the trust reform efforts. This strategic plan3 defines and describes the vision, goals, and objectives of trust reform and operating the trust program. Achieving the goals that are at the heart of the strategic plan will enhance ( I ) beneficiary services, (2) ownership information, ( 3 ) land and natural resources assets, (4) trust fund assets, ( 5 ) Indian self-governance and self-determination, and (6) administrative services. The objectives set forth in the strategic plan will define the broad ways in which these goals will be achieved. The strategic plan also considers the trends that influence trust management, the role of relevant stakeholders, and the interaction of Interior agencies. Through examination of the “big picture” of trust management, Interior creates a coordinated and integrated system in which all pieces function as a coherent whole. Strategic plans are dynamic. Thus, DO1 will regularly evaluate and update this plan to ensure its responsiveness to the ongoing needs of Interior’s trust opera- ’ This plan I i a been previously referred to as the Inclinn Trust Business Plan. See. for exam- ple, Eeventh Report, November 1, 2002, at 37-38. More recently it is referred to as the Compre- v Comprehensive Trust Management Plan Version 1 .O 3/28/03 . . DO1 Proprietary information 6 ........................................................... ............................... Contents Chapter 1 Introduction .......................................................................................... 1-1 THEPLAN ................................................................................................................... INTRODUCTION ............................... 1.1 1.2 ~IISTORY ..................................................................................................................... Chapter 2 Strategic Direction ............................................................................... 2-1 2.1 2.2 2.3 2.4 2.5 FRAMEWORK ............................................................................... ........................... 2-4 2.5.1 Beneficiaries ....................................................................................................... 2-5 2.5.2 Business Processes ............................................................................................. 2-5 2.5.3 Organization ...................... 2.5.4 Technoiogy and Data ............................................................ 2.6 3.1 3.2 BUStNEsS OBJECTIVES ................................. 3.2.1 Framework Area: Beneficiaries ........... 3.2.2 Framework Area: Business Processes ............................................ 3.2.3 Framework Area: Organization ......................................................................... 3-7 3.2.4 Framework Area: Technology and Data ................................. 3.3 BUSINESS ENVIRONMENT ........................................................................................ 3-12 3.4 BUSlNESS LINES ....................................................................................................... 3.4.1 Supporting Products and Services ................................................................... 3-21 3.5 3.5.1 Reneficiaries ..................................................................................................... 3-25 1-1 1-5 MISSION .............. .................................................................................................. 2-1 PRINCPLES ................................................................................................................. 2-2 VISION ........................................................................................................................ 2-3 ............................................................................. 2-5 ^I .- ............ 1-0 .......... 2-6 ............................. 3-2 ............................. 3-5 3-18 STRATEGIC GOALS ................ 2.7 TRANSITION TO C:HAPTEH 3 ....................................................................................... 2-7 Chapter 3 Business Objectives and Business Profile .......................................... 3-1 INTRODUCTION ........................................................................................................... 3-1 Fwnm SERVICE DELIVERY MODEL ...................................................................... 3-22 . . 3.5.2 Office of the Special Trustee for American Indians ....................................... 3-25 3/2ato3 vii Comprehensive Trust Management Plan Version 1 . 0 L.-. . . -.,- . . . . . . . ... .. ..... ..- .......... .-.- .-. . . DO/ Proprietary I n formation 3.5.3 Bureau of Indian Affairs .......................................................................... 3-26 FIDUCIARY OBLIGATIONS AND REQUIREMENTS ..................................................... 3-27 ................................................................................ 3-27 3.6.1 Fiduciary Obligations . 3.6 3.7 3.6.2 Fiduciary Trust Management Requirements ................................................... 3-28 m N S I T 1 O N TO CHAPTER 4 ..................................................................................... 3-31 Chapter 4 Organizational Realignment ................................................................ 4-1 INTRODUCTION ........................................................................................................... 4-1 ................................. ............................... 4-2 4.1 4.2 BACKGROUND . 4.3 TRIBAL CONSULTATION ............................................................................................ 4-3 4.4 NEW ORGANIZATION ................................................................................................. 4~ 4.5 SERVICE DELIVERY ASSESSMENT ............................................................................. 4-5 4.5.1 Central Office ..................................................................................................... 4-6 4.5.2 Regions ............... 4.7 4.5.3 Agency ....... 4.6 ROLES AND RESPONSIBILITIES ..................................................... SUhfMARY ................................................................................................................ 4-13 5.3 5.4 KiSK MANAGEMENT ..... Chapter 6 Tnist Reengineering ............................................................................. 6-1 6.1 INTRODUC~‘ION ............... 6.2 TtiE As-Is MODEL ............. Chapter 5 Transformation Activities .................................................................... 5-1 5.1 INTRODUCTION .......................................... 5.2 PROJECT AcTtvrrrEs REQUIRED FOR A COWREHENSIW ‘I~ANSFORMATION ........................................................................................... 5-2 EFFORT ................... 5.2.1 Project Planning and Management .................................................................... 5-7 5.2.2 ChangeIRisk Management ................................................................................. 5-7 5.2.3 Create Vision and Strategic Plan ....................................................................... 5-8 Organizational Development and Realignment ................................................ 5-8 5.2.4 5.2.5 Trust Reengineering ........................................................................................... 5-9 Establish Performance Management Program ................................................ 5-10 5.2.6 PROJECT SCHEDULE ...... ................................. 5-13 .......................... .................. 6-1 ............................. 6-3 THE TO-BE MODE^ ..................................................................................................... 6-4 6.3 viii Cornprehensive Trust Management Plan Version I . 0 3/28/03 Con tents DOI Proprietary Information .. ............. /...._.. ....... . ~ . - . -c.. . . . . . . . - - ~ -_x ,..~ ......... --. .............. .--. . _^.__. .... 6.3.1 Creating Management Structures and Building Blocks ................................... 6-4 6.3.2 Managing Change ............................................................................................... 6-5 6.3.3 Creating the Trust Program Management Center ............................................. 6-5 6.3.4 Designing and Implementing the To-Be Model ............................................... 6-6 7-1 Chapter 7 Conclusion ............................................................................................ PROPOSED DATE FOR TERMINATION OF THE OFFICE OF THE SPECIAL 7.1 ....................................... 2-7 ................................... 3-15 TRUSTEE ..................................................................................................................... 7-3 Appendix A Background Appendix B Business Trends Appendix C Requirements Appendix D Tnist Management Roles and Responsibilities Appendix E Abbreviations FIGURES Figure 1- 1. Comprehensive Assessment and Planning Methodology Figure 1-2. comprehensive Trust Management Planning Process ..... Figure 2- 1. Comprehensive Assessment and Planning Methodology ...................................... 2- 1 Figure 2-2. Roadmap to and Core Components of Chapter 2 ................................................... 2- 1 ................................................................... 2-5 Figure 2-3. DO1 and Comprehensive Trust Management Mission Statements.. ..................... 2-2 Figure 2-4. Strategic Framework ..... Figure 2-5. Framework Areas and Strategic Goals .......... Figure 3- 1. Comprehensive Assessment and Planning Methodology ...................................... 3- i Figure 3-2. Roadmap to and Core Components of Chapter 3 ..................... Figure 3-3. Business Objectives Aligned to Strategic Direction .............................................. 3-3 Figure 3-4. Alignment of Business Objectives with Framework Areas ................................ 3- 10 Figure 3-5. Business Profile as Foundation of Strategic Framework ..................................... 3- 12 Figure 3-6. Trust Management Business Environment .......... Figure 3-7. Future Service Delivery Model ................... 3/28/03 ................................ 3-23 ix Comprehensive Tntst Management Plan Version I .O DOI Proprietary information .... ... . . . . . . ................. . ... ...... Figure 4- 1 . Comprehensive Assessment and Planning Methodology ...................................... Figure 5- 1 . Comprehensive Assessment and Planning Methodology ......................... TABLES Table 3- I . Stakeholders’ Future Relationship to Trust Management ..................................... 3-17 Table 3-2 . Sumniary of Requirements ..................................................................................... 3-29 Table 5- I . Risk Assessment ...................................................................................................... 5-13 3/28/03 x Comprehensive Trust Management Plan Version 1 . 0 DOI Proprietary In formation Chapter 1 1.1 THE PLAN DM2.5C. The Department of the Interior (DOI) initiated a comprehensive assessment and planning effort to identify and incorporate project components and actions re- quired to fulfill its trust responsibilities to American Indians and Alaska Natives with respect to Indian trust assets that DO1 holds or controls as trustee delegate of the United state^.^ DO1 i s committed to implementing the actions described in this Comprehensive Trust Management Plan. This plan details the DO1 approach for improving performance and accountability in Indian trust management. While progress has been made in many areas, the current state of trust management reform is the product of a series of related proj- ects, initiated by a variety of influences and not yet incorporated into a h l l y inte- grated effort. Based on preliminary information from a major process documentation effort al- ready underway, DO1 realizes that it will require a comprehensive and filly inte- grated modernization effort to reform Indian trust management. As a result, DO1 initiated an overarching assessment and project planning effort focused on (1) identifying the project components required to improve trust management and (2) expanding the current trust modernization project plan to incorporate these new prqject components and supporting activities. The result is an integrated descrip- tion of comprehensive trust management and the plan for achieving it. In undertaking this assessment, DO1 recognized the need to step back and analyze the current position, direction, and business profile of trust management activities and redefine them as needed to provide a solid foundation for real modernization. As a result, DO1 designed a methodology to support analysis and planning fol- lowed by execution and measurement to achieve comprehensive trust nianage- rnent and provide effective and efficient services to the beneficiaries. (Figure 1-1). ' Defined in the Depnrtment Manuaf, 303-Principtes for Managing Indian Trust Assets, 1 - I Comprehensive Trust Management Plan Version I .O j.- . ./- . . ._ Chapter 3 Business Objectives and Business Profile Chapter 4: Organizational Realignment This chapter presents the organizational redesign needed t o support the new sew- ice delivery model. Chapler 4 Organizational Realignment Chapter 5: Transformation Activities Chapter 5 describes the major implementation activities required for an integrated and comprehensive transformation effort. These activities will govern the expan- sion and scheduling of current and future transformation initiatives. ‘I’he breadth and scope ofthe activities and initiatives requires detailed, continuous implemen- tation planning as the transition unfolds. Chapter 5 Transformation Activities Chapter 6: Trust Reengineering Chapter 6 reflects one of the transformation activities described in Chapter 5- Trust Reengineering The “As-Is” modeling efforts are summarized and the major components of the “To -Be” modeling effort are firrther described. ................. Introduction 3/28/03 ~ . . . . . .... . . . . . . . . . . . . . . . . Environment ........................ ........................... .............................................. .................................. ...-..........._I ............................................................................................................................... ....................................... ,.. ..................... t~ ..................... ............................................................ ROIS a Business Objectives ............. Responstbilile ........ DOI Proprietary in formation ........., ...................... ........... .... Organirationat ............................ Model .............................................. 1-3 Comprehensive Trust Management Plan Version I .O Chapter 6 Trust Reengineering Figure 1-2 illustrates the specific planning process arid structure of this plan ..... ..... Figure 1-2. Comprehensive Trust Management Planning Procc.s-s Chapter 1 Introduction Chapter 2 Strategic Direction Chapter 3 Business Objectives and Business Profile Chapter 4 Organirationai Realignment Chapter 5 Transformation Activities Chapter 6 Trust Reengineering ......................................................................... ...................................... V ................................... . . . . . . . . ............................. ................................. ... .................................. Organizational ........................ ................ ...................................... ............. ................ ... ............... . Responsibilile ..... - i~ g-.;: , Trust i .. : ..e,engineeringi i; L.> 3/28/03 ....................... . . . ) . : I 4 Comprehensive Trust Management Plan Version I .O __-. .-__ introduction DOI Proprietary Information .I I --, ~ - - ,_-- .._”.. ~. 1.2 HISTORY 2000. ’ IJIectronic Data Systems, DO! Trust Reform, Find Report and Randmop, January 24,2002. ._ The history of the trust relationship is the foundation for the political, social, le- gal, and cultural factors that continue to influence current challenges. IJnder the General Allotment Act of 1887, the federal government began to parcel out or allot tribal lands to individual members of Indian tribes. This policy, which did not support the traditional role of the tribes, continued into the twentieth cen- tury until it was repealed by the Indian Reorganization Act of 1934. The act re- stored remaining surplus lands to tribal ownership, thus shi Fting the policy focus away from individual Indians and back to their tribes. The trust period for allot- ments in existence was “extended and continued until otherwise directed by Con- gress.” The Indian Self-Determination and Education Assistance Act of 1975, Public Law 93-638, frirther refined this policy, directing the government to ensure “maximum Indian participation in the direction, planning, conduct, and administration of educational as well as other federal programs and services to Indian communities so as to render such programs and services more responsive to the needs and de- sires of those communities ” The Indian Tribe Self-Governance Amendments of 1994 gave tribes even greater autonomy in the management of federal finds spent on their behalf and their own trust assets. Because of these shifts of national policy, the operation of the Indian ti-Ust 011 be- half of individual Indian beneficiaries became increasingly complex. The number of heirs to the original allotments ballooned and the size of the individual shares correspondingly shrank, resulting in hundreds of individuals owning those origi- nal allotments. To help solve this management problem and others, Congress en- acted, among other laws, the American Indian Trust Fund Management Reform Act of 1994 (Refonn Act) and the Indian Land Consolidation Act Amendments of Congress specifically directed the trustee-delegate, the Secretary of the Interior, to establish, within DOI, the Office of the Special Trustee for American Indians to “oversee and coordinate reforms within the Department.” In 1997, the Special Trustee submitted the first comprehensive strategic plan to guide reforms. Al- though not fully accepted for implementation by then-Secretary Bruce Babbitt, it formed the basis for two subsequent documents: the High Level Implementation Plan and High Level implementation Plan 2000. Having received conflicting information on the state of trust reform, DO1 commissioned an independent report by the management-consulting firni Electronic Data Systems (Ens), which concluded that previous reform results were not satisfactory. This report provided opinions why results were riot effective and recommended impr~vernents.~ Litigation in IJ.S. District Court has 1-5 Comprehensive Trust Management Plan Version I .O 3/28/03 “____I_ ~. --.. ~.~ ..._ .. ..l ,.._.. - . . ” ..,... _. . . ..., - . , . .,_, ~. ,_,.__,.. ., _ _ ~ also impacted the Department’s administration of Indian trust issues. After review of the EDS report, DO1 initiated a planning effort for a more comprehensive approach to trust management beginning in January 2002. In addition, Secretary Norton created two offices, the Office of Indian Tnist Transition (OITT) and Office of Historical Trust Accounting (OHTA), to perfomi two specific tasks: reform and historical accounting. Each is the focal point for attention and resources within its assigned area. Among the actions underway are (1) the reorganization of Interior trust offices to improve delivery of services, effectiveness, and accountability of trust operations, and (2) the reengineering of Interior’s business processes supporting the govern- ment’s fiduciary Indian trust. The documentation of current processes, or “As-Is” model, is the first step in reengineering thern. The next effort will be creating a “To-Be” model, which, when in place, will enable DO1 to standardize, integrate and improve beneficiary-focused processes across a majority of components in- volved with the Indian trust. DO1 has engaged in a wide range of improvement initiatives over many years with varying results. DO1 continues to face many challenges to trust reform (Appendix A). Recognizing the need for a more comprehensive approach to trust improvement, DO1 moved from the previous Ifigh Level Implementation Plan to a more integrated and logical progression toward unified trust management. This transition began in 2002 with a strategic planning effort that incorporated work already being done to improve trust management. The resulting strategic plan is documented in the following chapters. DO1 Proprietary /nformntion 1-6 Comprehensive Trust Management Plan Version 1 .O 3/28/03 2.1 INTRODTJCTTON DOI Proprietary Information Comprehensive trust management must be based on a strategic direction that ac- curately describes the desired hture state. As depicted in Figure 2-1, the strategic direction is the first step in the assessment of trust management. It has been for- mulated through senior-level focus groups to ensure a cohesive, balanced ap- proach. This chapter articulates the direction in a simple framework to ease communication, Subsequent chapters in this plan translate this direction into ac- tion. Figure 2-1. Comprehensive Assessment and Planning Methodology Figure 2-2 shows the roadniap to and core components of this chapter. Chapter 1 Introduction - Execution 8 Measurement tntraductian Figure 2-2. Kondmap to and Core Components rfChaptcr 2 j-1 F] ~ ...... ~. .~. ..................... ~..~~.. ............._.........._.................... ~ .......................... 2.2 MISSION The mission statement defines the core purpose of an organization-why i t exists. it captures the contribution and value of the organization. It is the foundation upon which the organization develops its strategic direction. 2-1 Comprehensive Trust Management Plan Version I .O 3/28/03 DO/ Proprietary In formation - - . . ---I---___ ..__. . - ,“.” - _.-- . . - . .,-- ,-- - ~ . ~ Figure 2-3 shows that the comprehensive trust management mission flows from the rK3I proposed new mission statemerit. Figure 2-3. DO1 und Comprehensive Trust hfmugcmenl hfissioti Statements Department of the interior To protect and manage the Nation’s natural resources and cultural heritage; to provide scientific and other information about those resources; and to honor its special responsibilities to American Indians, Alaska Natives and affiliated Island Communities. I I Indian Trust Management To perfom our fiduciary trust responsibilities to American Indian tribes, individual Indians, and Alaska Natives by incorporating a beneficiary focus and beneftciary participation while Drovidinq effective, competent stewardship and manaclement of trust assets. 2.3 PRINCIPLES Principles reflect underlying values. They firther define an organization’s operat- ing environment and shape its culture. Just as the mission statement leads an or- ganization toward the intended state, the principles an organization espouses influence decisions made by or on its behalf, and establish norms of behzvior for employees at all levels. The Secretary of the Interior established the following principles as guidance for discharging DOI’s trust responsibility: A. Protect and preserve Indian trust assets from loss, damage, un- InwfUl alienation, waste, and depletion; B. Assure that any management of Indian trust assets that the Sec- retary has an obligation to undertake promotes the interest of the beneficiary and supports, to the extent it is consistent with the Secretary’s trust responsibility, the beneficiary’s intended use of the assets; C. Enforce the terms o f all leases or other agreements that provide for the use of trust assets, and take appropriate steps to remedy trespass on trust or restricted lands; D. Promote tribal control and self-determination over tribal lands and resources; E. Select and oversee persons who manage Indian trust assets; Principles are documented in the Deynrtrnenml Manual, 303 DM2. 2-2 Comprehensive Tnist Management Plan Version 1 ,O 3/28/03 F. Confirm that tribes that manage Indian trust assets pursuant to contracts and compacts authorized by the Indian Self- Determination and Education Assistance Act, 25 ‘CJ.S.C 450, et seq., protect and prudently manage Indian trust assets; G. Provide oversight and review of the perfo~mance of the Secre- tary’s trust responsibility, including Indian trust asset and in- vestment management programs, operational systems, and information systems; €1. Account for and timely identify, collect, deposit, invest, and distribute income due or held on behalf of beneficiaries; I. Maintain a verifiable system of records that is capable, at a minimum, of identifying: ( 1 j the location, the beneficiary, any legal encumbrances (ix., leases, permits, etc.), the user of the resource, the rents and monies paid, if any, and the value of trust or restricted lands and resources; (2 j dates of collections, deposits, transfers, disbursements, third-party obligations (i.e., court ordered child support, judgments, etc), amount of earn- ings, investment instruments, and closing of all trust fund ac- counts; ( 3 ) documents pertaining to actions taken to prevent o r compensate for any diminishment of the Indian trust assets; and (4) documents that evidence the Department’s actions re- garding the management and disposition of Indian trust assets; J. Establish and maintain a system of records that permits benefi- ciaries to obtain infonation regarding their Indian trust assets in a timely manner and protect the privacy of such information in accordance with applicable statutes; K. Invest tribal and individual Indian trust funds to make the trust account reasonably productive for the beneficial owner consis- tent with market conditions existing at the time the investment is made; L. Communicate with beneficiaries regarding the management and administration of Indian trust assets; and hl. Protect treaty-based fishing, hunting, gathering, and similar rights of access and resource use on traditional lands. 2.4 VISION The mission and principles provide trust management leadership with a founda- tion for executing its responsibilities. The next step is to establish the vision for 2-3 Comprehensive Trust Management Plan Version 1 .O 3/28/03 trust management. The vision defines the future state for comprehensive trust management when all the modernization activities are complete. Comprehensive Trust Management Vision Statement 2.5 FRAMEWORK To fulfill the comprehensive trust management mission and vision, DO1 wilf fo- cus its strategic planning on four areas, which constitute a framework for its ef- forts: + Beneficiaries + Business processes + Organization + Technology and data. Figure 2-4 illustrates these four framework areas, which wilf be used to integrate the strategic direction with the other major elements of the pian. 3/28/03 2-4 Comprehensive Trust Management Plan Version I .O Strategic Direction . .._..__.-____.._l__ .~ _-_, . - . - . . .._._ __.. ~ ,...-___ ..... .,*. ... . . ~ - ~ .. -_ ~. ,__. . .-..- . . ~ . . - 2.5.1 Beneficiaries 2.5.2 Business Processes 2.5.3 Organization DO1 Proprietary Information . Figitre 2-4. Strategic Framework DO1 is committed to taking a more beneficiary-focused approach to its fiduciary responsibilities. DO1 must develop a better communication process with benefici- aries regarding the management of their trust assets. The business processes used to accomplisli work greatly influence the manner in which it is performed. Improving work performance requires improving proc- esses. While data availability, staffing limitations, the legal environment, and other factors prescribe and constrain the many interrelated trust management functions and processes, considerable improvement can be achieved. DO1 will continue current efforts to improve DO1 trust management business processes, DO1 will establish an organization that empowers and enables people to manage trust activities effectively. The ultimate effectiveness of an organization depends upon the professionalism and credibility of the employees and the manner in which they are organized, motivated, and held accountable. DO1 must analyze the workforce to understand how requirements evolve as new technology emerges and processes change. Workloads will change in quantity and nature, and the workforce planning process must anticipate these changes. 2-5 Comprehensive Trust Management Plan Version I .O 3/28/03 2.5.4 Technology and Data DO1 plans to apply technology to the delivery of trust management services. The lack of adequate technological tools severely limits effective performance of DOI's mission. Comprehensive trust management must learn from the past and, in concert with business process reengineering efforts, apply technology to improve processes and beneficiary-focused service delivery systems. This application of technology will require the investment of time arid fiscal resources to build a flexible architecture that can accommodate the inevitable evolution of hardware and software. 2.6 STRATEGIC GOALS \ After considerable input from internal and external sources, DO1 has established six strategic goals, one or more of which supports each framework area: 1 . Beneficiary services that are trusted, accurate, and responsive 2. Tribal self-governance and self-determination that increase participation in managing assets7 3. Ownership information that is accurate, timely, and reliable 4. Land and natural resources management that maximizes return while meeting beneficiary desires.8 5. Tnist h n d assets management that meets fiduciary standards 6. Administrative services that A. enable and enipower the organization and woryorce to be an effective jiduciary trustee, and .__ The level of participation may be constrained by 'I'ribaI preferences. The return on investment may be constrained by beneficiary preferences, or other factors (e.g. fractionation, Indian policy, etc.). B. provide modern, appropriate systems and tools to manage thefiduci- ary trust. Figure 2-5 displays the relationship between the framework areas and strategic goals. 2-6 Comprehensive Trust Management Plan Version I .O 312 8/0 3 ~ -1” - I r Strategic .+. __ Direction . _ Figure 2-5 Framework Arms and Strategic (;oak the beneficiaries with improved trust services. 2.7 TRANSITION TO CHAPTER 3 This figure graphically shows the strategic direction for comprehensive trust man- agement. As the processes become more efficient and effective, they will provide With the strategic direction snapped out and communicated through the strategic goals, more detailed information is required to guide the modernization effort. Chapter 3 describes business objectives that build on the strategic goals and pro- vide the detail needed to define the organization, measure performance, and plan the implementation. ‘The business objectives are accompanied by a business pro- file showing the service delivery model and business lines. 2-7 Comprehensive Trust Management Plan Version I .O -. 3/28/03 DOI PropricFtnry Informof ion ~ . . I Chapter 3 Business Obiectives and Business Profile 3.1 INTRODUCTION Chapter 2 describes the strategic direction but does not provide the specifics nec- essary to complete a detailed assessment or expand project planning. As depicted in Figure 3- 1, this chapter identifies business objectives to achieve the strategic goals. It then summarizes the business profile, identifies the business lines, and lays the foundation for the new mode of operations as defined by the business en- vironment model and the service delivery model. Figure 3-2 shows how this chap- ter is organized. Strategic Direction Figure 3-1. Coniprehensive Assessnient and Planning Methodology Chapter 2 Chapter 4 Chapter 6 Chapler 3 Tnisl Keengineenng Chapter 5. Activities Business Obpclrves Organizational Translormalrcm and Busrngss, P~ofile Realgnment -. / 5 = Execution & Measurement c; -==&- Chapter 2 Strategic Oirection Chapter 3 Business Objectives and Business Profile Figiirc 3-2. Roadmap to and Core Components of CXaptc--r- 3 Chapter 1 Introduction L J LIJ 3- I Comprehensive Trust Management Plan Version 1 .O 3/28/03 3.2 BUSINESS OBJECTIVES The trust management business objectives, when successfully reached, achieve comprehensive trust management’s strategic goals as defined in Chapter 2 and fulfill fiduciary obligations. This alignment of the strategic goals and business ob- jectives articulates DOI’s overall fiduciary trust business plan for managing and reforming its trust operations. Figure 3-3 displays the alignment of the strategic goals and business objectives within the four framework areas. 3/28/03 3-2 Comprehensive Trust Management Plan Version 1 .0 mil BLI 'L In/orrn lI:io11 . . JL Comprehensive Trust Mnnageiiient Pl,iii Version I 3 Rusii . 1LS.L Objec 3/28/01 3 3 Business Objectives and Business Projle ~ DO/ Proprietary Information - - . . --._.-~------ . l.._" - - -I BUSINESS OBJECIIVE 1.2: BENEFICIARY SERVICES MANAGEMENT ASSET SERVICES service regardless of ownership region or area. BUSINESS OBJECTIVE 1.5: TECHNICAL, ASSISTANCE - .-_ . - 3.2.1 Framework Area: Beneficiaries 3/28/03 ..".. The business objectives are defined in the following subsections. They are categorized according to the corresponding strategic goals within each of the four framework areas: beneficiaries, business processes, organization, and technology and data as introduced in Chapter 2. A few of the objectives are furthered defined by subobjectives. STRATEGIC GOAL 1 : BENEFICIARY SERVICFS THAT ARE TKUSTED, ACCURATE, AND RESPONSIVE BUS~NESS OBJECTIVE 1. I : BENEFICIARY STATEMENTS Routinely provide timely, accurate, understandable, and comprehensive state- ments to beneficiaries. Provide beneficiaries with convenient access to trust account services and infor- mation. BUSINESS OBJECTIVE I .3: BENEFICIARY COMMUNICATIONS Develop and maintain effective communications with beneficiaries to facilitate their involvement in improving trust management, acquisition and disposal, and conveyances of trust assets, consistent with DOI's fiduciary duties. BUSINESS OBJECTIVE 1.4: POINT OF CONTACT FOR ALL TRUST Develop an accessible point of contact who can provide any individual Indian or tribal representative with any requested trust management asset information or Provide Indian tribes with technical assistance to develop, implement, and man- age Indian trust fund investment plans, in accordance with the Reform Act. BUSINESS OBJECTIVE 1.6: CooaEMrivE AUDIT AGREEMENTS Increase the number of tribes that participate in cooperative audit agreement pro- grams for mineral leases9 The level of paiticipalivn may be constrained by Tribal preferences. 3-5 Comprehensive Trust Management Plan Version 1 .O STKATEGIC GOAL 2- TRIBAL SELF-GOVERNANCE AND SELF-DL rERMINATION THAT INCREASE PARTICIPATION IN MANAGING ASSE i'S BUSINESS OBJECTIVE 2.1 : EXPAND SELF-GOVERNANCE COMPACTS AND SELF-DETERMINATION CONTRACTS Foster expansion of sel f-governance compacts and self-determination contracts in a manner consistent with DOI's fiduciary responsibilities. 3.2.2 Framework Area: Business Processes STRATEGIC GOAL 3: OWNERSHIP INFORMATION THAT Is ACCURATE, TIMELY, Establish acctirate and current surveys to ensure correct boundaries for trust indi- vidual and tribal lands and any resulting revenue distribution. AND &U4EILE BUSINESS OBJECTIVE 3.1 : SURVEYS BUSINESS OBJECTIVE 3.2: PROBATE AND ESTATE AL)MINIS?'RATION Consistently prioritize and quickly resolve probate and estate administration cases effectively to meet asset management and beneficiary service requirements. BUSINESS OBJECTIVE 3.3: TITLE, REALTY, AND ADMINISTRATIVE INFOKMATION Develop, maintain, and make readily available accurate and current asset owner- ship and administrative infonnation that is managed to professional fiduciary standards. STRATEGIC GOAL 4: LAND AND NATURAL RESOURCES MANAGEMENT THAT MAXlMIZES RETURN WHILE MEETING BENEFlCLARY DESIKES BUSINESS OBJECTIVE 4.1 : LAND AND NATURAL &SOURCE ASSET PLANS AND STEWARDSIIIP STRATEGIES Develop land and natural resource asset plans and stewardship strategies. BUSINESS OBJECTIVE 4.2: PRESERVA'IION AND PROTECTION OF LAND AND NATURAL RESOURCE ASSETS Preserve and protect the long-term viability of land and natural resource assets consistent with fiduciary duties and with the beneficiaries' intended use of the as- sets. 3-6 Comprehensive Trust Management Plan Version I .O 3/28/03 Business Objectives and Biisincw Profile DO/ Proprietnry In formation BLJSNESS MANAGEWNT BUSINESS C)BJECTIVE 4.4: APPRAISALS standards. BUSNESS OBJECTIVE 4.5: FRACHONATION STRATEGY BUSMESS OBJECTIVE 5.1 : FIDUCIARY FUND ASSET MANAGEMENT BUSINESS OBJECTIVE 5.2: COLLECTION, DISBURSEMENT, AND ACCOUNTING OF FUNDS - - - STRATEGIC GOAL 5: TRUST FUND ASSETS MANAGEMENT THAT MEETS FIDUCMRY STANDARDS 3.2.3 Framework Area: Organization STRATEGIC GOAL 6A: ADMINISTRATIVE SERVK'ES THAT ENABLE AND EMPOWER THE ORGANI2ATIC)N AND WORKFORCE TO BE AN EFFECTIVE FIDUCIAKY TRUSTEE BUSINESS OBJECTIVE GA. 1 : ACCOUNTING fective and efficient trust management. . - . BLJStNESS C)BJECI'IVE 4-31 1,ANU AND NATURAL RESOURCE ASSET Manage land and natural resource assets effectively and proactively to obtain fair market value for beneficiaries and to incorporate beneficiary requirements. Obtain appraisal information, as needed, on tnist and restricted lands for tribal and individual Indian owners, using methods and techniques that meet professional Develop and implement a resolution that reduces or eliminates the exponential increase in the number of ownership interests in land. Manage and invest fund assets to provide prudent rates of return in accordance with appropriate statutes, while considering the best interests of individual benefi- ciaries and tribes. Collect, disburse, and account f a furids associated with Indian trust assets quickly and accurately. Develop and maintain accounting activities that are user friendly and integrated, provide necessary hnctionality, and contain appropriate interfaces to support ef- 3-7 Comprehensive Trust Management Plan Version 1 .O 312 810 3 DOI Proprietary Information ~ ~- - .._. - 3-8 Comprehensive Trust Management Plan Version 1 .O . . .... ... .. . . ~ - . . - . .. .---- ._. . _.I .,_ . ” .- _-_~_ BUSrNfiS OBJECTIVE 6A.2: I’OLICIES AND PROCEDURES Coordinate policy and procedure development and management relating to all In- dian trust asset reform and management activities to ensure fiduciary and legal requirements are fulfilled. BrJSrNESS OBJECIIVE 6A.3: BUSINESS PRACTICES Develop and maintain business processes and practices that are complete, consis- tent, reliable, and based on appropriate fiduciary standards. BUSMESS OBJECTIVE 6A.4: RISK MANAGEMENT Develop, implement, and maintain a comprehensive risk management program, including extensive internal and external management controls, to monitor and evaluate the effectiveness of DOI’s trust operations. Rusw~ss OBJECTIVE GA.5: RECORDS MANAGEMENT Create, manage, and preserve trust records with adcquate arid proper documenta- tion so that the information necessary to fulfill DOI’s fiduciary responsibilities is protected, available, and accessible to beneficiaries. BUSMESS OBJECTIVE 6A.6: DO1 TRUST ORGANIZATION Create a DOL trust organization with the structure, policies, anci processes that ful- fill fiduciary and legal requirements, all with a beneficiary focus. Sub-Objective 6A.6.1: Fiduciary Duty Focus and Strategy Develop a fiduciary duty focus and strategy for trust management. Sub-Objective 6A.6.2: Consolidation and Accountability Consolidate DO1 Indian trust asset responsibilities into an organization ac- countable for executing, maintaining, and managing fiduciary trust activities. Sub-Objective 6A.6.3: Trust Processes Benchmark and improve DO1 trust processes and apply appropriate standards. Sub-Objective 6A.6.4: Activity-Based Costing Develop an activity-based costing model for implementing trust enterprise business plan objectives. 3/28/03 DOI Prop vie t a ry Inform at ion Business Objectives and Business Profile . . ~ ,- .,.---_-.. ~ . I . . ,. , _ i ".. ~ , . .. . . . _ I . ~. - . ~. .~-. ~. - .". -. - . -.. .." . , 3-9 Comprehensive Trust Management Plan Version 1 .O . . BUSINESS OBJECTWE 6A.7: kfUMAN RESOURCES Manage the DO1 trust workforce so positions are filled quickly with well-trained employees who are held accountable for effective performance. Sub-Objective 611.7.1 : Workforce Planning Prepare organizational workforce plans that are focused on staffing, recruit- ment, retention, and retirement forecasting, and develop associated infrastruc- ture. Sub-objective 6A.7.2: Workforce 'Training Develop a comprehensive and coordinated DO1 trust asset management train- ing program. BUSINESS OBJECTIVE 6A.8: PERFORMANCE MEASURES Develop, maintain, and use clear performance measures to manage indian tnist asset operations and to assess performance. 3.2.4 Framework Area: Technology and Data STRATEGIC GOAL 6R: ADMWISTRATWE SERVICES THAT PROVIDE MODERN, APPROPFUATE SYSTEMS AND TOOLS TO MANAGE THE FIDUCMRY TRUST BUSINESS OBJECTIVE 6B. I : h'FORM.4TION TECHNOLOGY Develop, operate, and maintain a trust enterprise architecture with the appropriate computer systems to facilitate successful tmst operations. Sub-objective 6B. 1.1 : Trust Enterprise Architecture Develop a comprehensive trust enterprise architecture. Sub-Objective 6B. 1.2: A- 130 Compliance Fully comply with applicable requirements in the Office of Management and Budget (OMB) Circular No. A-130. Sub-Objective 6B. 1.3: Data and Systems Security Develop and implement data and systems security procedures. The realization of these business objectives leads to the achievement of the strate- gic goals. Figure 3-4 illustrates the alignment of the business objectives within the framework areas. 3/28/03 $018 Z/E DOI Proprietary Information ~ ,-__ r C _-_- _-. zation effort. - - . . _ _ _. _.._ Figure 3-5 Business Profile as Foundation of Strategic Framework 3.3 BUSINESS ENVIRONMENT Now that the business objectives have been identified (Figure 3-3), the next step is to identify who is involved in achieving these objectives. DO1 identified key stakeholders involved in providing trust management services. An active, produc- tive, and cooperative partnership with the beneficiaries and the identified key stakeholders is an underlying element of the design and execution of the inoderni- 3-1 2 Comprehensive Trust Management Plan Version 1.0 3/28/03 I - . Business Objectives _- - and I - - Business ~ Profile __ - -" -.-_ 1---- - 1 - _ .__- . DOI . __ Proprietary .-_I.I - _.. Information "_ -_. . Figure 3-6 shows thesc key stakeholders and identifies how they interact to fulfill DOI's tnist management responsibilities. Success depends upon their continued involvement as DO1 transitions toward the vision and achieves the strategic goals defined in Chapter 2. Each box in Figure 3-5 represents a key stakeholder, and each arrow defines continued consultation between and among stakeholders through exchange of ideas, infonnation, arid services as necessary for successful Indian trust management. 3-1 3 Comprehensive Trust Management Plan Version 1 .O 3/28/03 3/28/03 3 - 1 5 Coinprchwsive Trust Mannge~nenl Plan Version I .O Business Objectives and Business Profile __“__I ~ . . - P A ) Minerals Management Service (MMS) Bureau of Land Management :BLM) 3ffice of Yearings and %peals (OHA) Table 3-1 further defines the future relationship of each stakeholder to trust management as identified on the business environment chart (Figure 3-6). Table 3-I. Srakeholders ’ Future Relationship to Trust Management Stakeholder Trustee: Congress Trustee Designate: Office of the Secretary Beneficiaries Custodians Department of the Treasury Lessees Office of the Solicitor Office of the OST provides financial management and disbursement, beneficiary Special Trustee trust services, and representation for individual Indians and Indian for American tribes. OST oversees DO1 performance of trust management. Indians (OST) Bureau of Indian Affairs Role as identified in the business environment model Congress enacts statutes and provides funding. Through the 1994 Reform Act, i t established standards for trust management. I t receives periodic reports on the implementation of trust nianagement pro- grams. -__I The Secretary provides overall trust direction and principles. The Sec- retary receives status updates on reform efforts and reports on im plementation of programs. Beneficiaries request fiduciary trust services and receive fiduciary trust representation, advice and counsel, information, and payments. They provide lease approvals and information, such as address changes, ownership changes, and family updates. - -- Custodians are financial institutions that settle trades, collect income, and hold securities. Treasury provides financial services. Lease revenues are submitted to Treasury through various DO1 agencies, including MMS, BIA, OST, and tribes under compact and contract. _____ - - Lessees lease Indian lands. BIA executes and manages the leases. OST accounts for, invests, and disburses income frorrt leases. Ftinds are held in Treasurv. Office of the Solicitor provides legal counsel to DO1 agencies and par- ticioates in DrObate for members of the Five Civilized Tribes. ~ ~~ BIA provides stewardship and management of land and natural re- sources for individual Indians and Indian tribes. BIA handles small, noncomplex probate cases internally. BIA also maintains land title ownership information. MMS collects and verifies mineral lease revenue and performs min- eral compliance audits. It deposits revenue with the Federal Reserve Bank and posts the data with Treasury, notifies OST for investment purposes, and provides lease-level data to BIA to convert to individual andlor tribal ownership information and ultimate disbursement to beneficiaries. BLM conducts and submits mineral appraisals, leasing compliance, and contracts for cadastral surveys to BIA as required by law. Complex probate cases go to OHA for an order determining heirs and 3istribution. When a decision is final, estate distribution involving swnershiD information is forwarded to BIA. 3-1 7 Comprehensive Trust Management Plan Version I .O . DO/ - - Proprietary . Infornration 3/28/03 ~~. .. .- ~ , .--- ~ - -..-.- - - Stakeholder Office of Surface Mining I PSM) State Counties Cities TaxDavers tribal Indian and interest groups 3.4 BUSINESS LINES Distinct business lines, which provide the basis for developing the organizational structure, can be derived from the service delivery model. The three distinct busi- ness lines are as follows: I . BeneJiciary trust rcpresentation. Representing the beneficiaries in all mat- ters related to the trust, which requires independent representation on be- half of the beneficiaries. 2. Trustfinancial management. Managing the receipt, investment, and dis- bursement of funds generated by Indian assets, as well as record keeping and reporting on fiduciary trust management activities and accounts. 3 . Stewardship and management of land and natural resources. Managing the land and natural resource assets of the trust. Each business line represents a distinct group of products or services for compre- hensive trust management and encompasses related processes, products, and serv- ices within its scope. Each business line consists of common business processes focused on a particular activity. Defining comprehensive trust management in terms of business lines is criticat for several reasons: + Determining the major segments of the business provides the framework for designing the new organizational structure. + Managing the expectations of both beneficiaries and staff begins with clearly defining the business of Comprehensive trust management. Table 3-1. Stakeholders’ Future Relationship to Iirrst Management (Continued) OSM directly regulates all coal mining and reclamation operations on Indian lands under the Indian Land Program Regulations. As the regulatory authority, OSM reviews and approves mining permits and conducts inspection and enforcement activities on Indian lands. State, counties, and cities review and comment on trust land acquisi- tion. Trust land within their jurisdictions in-ipacts them through changes to the tax base and law enforcement jurisdiction. quirements, needs, and expectations. DO1 maintains public relations tion with the beneficiaries. . _ - . -.. ..“I__ .._ ” ~ Role as identified in the business environment model 3-1 8 Comprehensive Trust Management Plan Version 1 .O 3/28103 DOI Proprietary Information . - . ” Business Objectives and . Businvss . . , Profile _ _ DO/ Proprietary .. - . - ~. Information - - tion with the business model. - _- + Defining business lines provides a baseline for developing standard busi- ness processes and systems, as well as effectively aligning the organiza- This subsection describes the major products and services that comprise each business line. These are critical because they influence the design of business pro- cesses, information systems, and organizational structure. This definition of offer- ings, along with the business line descriptions, helps to define comprehensive trust management in the eyes of beneficiaries and other stakeholders, and to shape their expectations for service delivery. Expectations of beneficiaries often exceed what DO1 can accomplish within legis- lative boundaries. Products and services not listed because they fall outside these boundaries cannot be provided by comprehensive trust management. Beneficiary trust representation involves proactively communicating, providing trust management services, and representing the best interests of the beneficiaries in all trust matters. This business line establishes primary accountability for trust representation with OST. However, beneficiary representation is the primary responsibility of both BIA and OST. OST’s objectives, for instance, are to provide beneficiaries with timely and accurate information on trust accounts. However, this business line is not the exclusive business line of OST or BIA Beneficiary trust representation only can be performed successfully through coordinated efforts among involved o r affected DO1 agencies. The primary beneficiary trust representation products and services within this business line are as follows: Advise beneficiaries and other DOI personnel on trust management proc- esses and issues. Represent beneficiaries in fiduciary trust interests concerning trust assets and provide oversight of land and natural resource management. Provide beneficiaries with timely and complete fiduciary trust information and reports, and conduct consultation with tribal and individual trust bene- ficiaries regarding management of fiduciary trust assets. Facilitate beneficiary involvement in developing trust management plans, acquisition and disposal, and conveyances of trust assets. Provide Indian tribes with technical assistance to develop, implement, and manage their tribal tiust fund investment plans. 3- 19 Comprehensive Tnist Management Plan Version 1 .O -. -- . BUSINESS LINE 1 : BENEFICIARY TRUST REPRESENTATION 3 /28/03 DOI Proprictary Information , - - --, __ - _ l _ _ - -- ~ . ~ The stewardship products and services are as follows: Business Objectives a i d Businen Profile + RIA k Provide stewardship and management of land and natural resource assets in the best interests of the beneficiaries, while fulfilling fiduciary and legal responsibilities. BLM provides approval of operations for mineral leases. F Obtain cadastral surveys from BLM to establish accurate surveys and ensure correct boundaries for individual and tribal lands. F Provide title, realty, and administrative information. This entails de- veloping, maintaining, and making readily available accurate and cur- rent land asset ownership and administrative information, including acquisition, conveyance, right of way and easements, mortgages and assignments, and disposal functions. > Encourage and support compact and contract opportunities associated with trust management to promote Indian self-governance a i d self- determination. > Ensure probates are performed when appropriate. Many other important activities are involved in comprehensive trust management, but they play a supporting or oversight role and are not part of the main business lines. These will be accounted for as product or service requirements are identi- fied as the organizational model is developed. 3.4.1 Supporting Products and Services A number of products or services enable comprehensive trust management to de- liver services to beneficiaries or support senior management in the execution of their duties. DO1 must account for these items because they must be incorporated in the process design, systems design, and staffing requirements analysis. They are as follows: + OIIA: Estate adjudication + MMS: Collection and verification of mineral lease revenues and mineral compliance audits -.-___ - _ . - __"_" ~- desirable, this business line also involves promoting Indian self-governance and self-determination through advice and counsel on asset management. This business line reports through the management chain to the Assistant Secretary- Indian Affairs who oversees perfomiance. 3-2 1 Comprehensive Trust Management Plan Version 1 .O 3/28/01 + BLM: * Mineral appraisals * Cadastral surveys * Mineral lease operations, approvat, and compliance + Technical assistance and advice on proposed BIA mineral actions + OSM: > Mining pennits * Inspections + OST: + Comprchensivc trust management modernization plan + Appraisals * Status updates on reform efforts + BIA: * Status updates on reform efforts > Periodic statements of performance and audits > Annual report on implenientation of prograins and assessment of budget as requested by Congress > Periodic reports as requested by the court 3.5 FUTURE SERVICE DELIVERY MODEL The new tnist rnanagemcnt service delivery model identifies the new mode of comprehensive trust management business operations (Figure 3-7). It identifies who provides products and services and the flow of products arid services. It de- picts OST and BIA working together as a cohesive team. 3-22 Comprehensive Trust Management Plan Version I .O 3/28/03 I - ' I J 4 I _ 11OI Proprietary In formation - -_ --. -.- c Business ... - - Objectives - and Business . Profile - - - -_- ordinating efforts with these key stakeholders. 3.5.1 Beneficiaries - -_ ~ 3.5.2 Office of the Special Trustee for American Indians tions. 1 , Fiduciary trust beneficiary service delivery 2. Direct support 3 . Indirect support 4. Leadership. 3.5.2.1 FIDUCIARY TRUST BENEFICIARY SERVTCE DELIVERY ." The model begins on the left with beneficiaries requesting and recciving services through various service channels. The primary contact for beneficiary fiduciary trust services will be OST andlor RIA. The service delivery staff directly supports the beneficiaries. Indirect and direct support staffs further enhance these benefici- ary support functions, and leadership directs and guides operations. Along the lower section of the diagram are the other key stakeholders involved. The service delivery model details those within OST and BIA responsible for co- The following subsections define the relationship and role of the three key players in trust management services: beneficiaries, OST, and BIA. The service delivery model begins with the individual Indian and tribal beneficiaries requiring trust services, such as receiving trust account information, routine trust account statements, advice, and guidance. The intent is to maintain BIA service delivery representatives and to provide beneficiaries with an additional point of contact for all trust service requests and ownership information updates across all areas. Therefore, beneficiaries will continue to have access to the BIA in addition to an assigned trust officer within OST. Eventually, DO1 anticipates that ownership infomiation will be accessible to beneficiaries through various communication channels/contact methods-for example, walk-in, direct phone line, the Internet, a call center, or postal mail-to provide improved access. OST is responsible for beneficiary fiduciary tiust representation and trust finan- cial management. Four main busincss groups are needed to perform these func- Trust officers will provide fiduciary trust asset services and oversee trust asset management. First, trust officers will maintain information and provide a point of contact for all trust asset management information and services. Second, trust of- ficers will establish and maintain close working relations with BIA agency super- intcndents as they provide oversight of beneficiary asset management. Trust 3-25 Comprehensive Trust Management Plan Version 1 .O 3/28/03 DOI Proprietary Information , _ - _ - later date. 3.5.2.2 DIRECT SUPPORT 3.5.2.3 INDIRECT SUPPORT 3.5.2.4 OST LEADERSHIP 3.5.3 Bureau of Indian Affairs 1. Service delivery 2. Direct support 3 . Indirect support 4. Leadership _. officers monitor at-risk decisions and transactions and collaboratively work with BIA to reach a consen~u~ on final actions. Risk identifiers will be defined at a For trust officers to fulfill their role, they need direct support. The direct support team captures, maintains, and tracks fund asset information. Direct support is re- sponsible for records managetnent, accounting of hnds, investments, and dis- bursement of payments. To ensure effective and efficient operations, OST requires indirect support to de- velop policies and procedures, provide training, and reengineer business proc- esses-as applicable-to ensure standardized, best-practice operations. Indirect support also is required to provide the infrastructure for well-trained trust officers, direct support staff, and OST leadership. OST leadership is responsible for the following: implementing the business plan on the basis of DO1 strategic guidance; measuring implementation results; updat- ing the business plan accordingly; and informing the Secretary on trust refomi efforts. The leadership also provides guidance and direction for service delivery, direct support, and indirect support. OST leadership ensures that efforts within OST and between OST and BIA are coordinated. Although a separate trust management division is proposed in Chap- ter 4, DO1 will attempt to avoid stovepiped operations by establishing policies and procedures to foster communications and strong working relations among OST, BIA, BLM, MMS, and other key agencies.” BIA is responsible for stewardship and management of land and natural resources, and beneficiary communication. Four main business groups are needed to perform these fimctions: lo Stovepiping-singling out of a specific operation without regard for integration efforts. 3-26 Comprehensive Trust Management Plan Version 1 .O 3/28/03 _ . - I DOI , Proprieiary - information - " - _,- . Business Objectives and Busincsy Profile 3.5.3.1 SERVICE DELIVERY The BIA service delivery staff manages land and natural resource assets, supports self-governance and self-determination, updates and verifies ownership informa- tion, and ensures collection of non-mineral lease revenues. They conduct assess- ments and develop distribution plans for beneficiaries, including conducting due process to place appropriate accounts in supervised status. The service delivery staff also develops and maintains close working relations with OST service deliv- ery staff in order to provide services to beneficiaries and communicate with them. 3.5.3.2 DIRECT SUPPORT To do its job, the service delivery staff needs a direct support staff to capture, maintain, and track asset ownership information. The direct support staff also provides real estate services, such as resolving probate cases, and natural resource management services. 3.5.3.3 INDIRECT SUPPORT To ensure effective and efficient operations, BIA requires indirect support to de- velop policies and procedures, provide training, and reengineer business processes as applicable. These indirect support efforts are coordinated with OST and ensure standardized, best-practice operations. 3.5.3.4 RIA LEAUEKSHIP BlA leadership is responsible for implementing the business plan on the basis of DO1 strategic guidance, measuring implementation results, and updating the busi- ness plan accordingly. The leadership also provides guidance and direction for service delivery, direct support, and indirect support. Additionally, it ensures co- ordinated efforts within BIA and maintains close working relations with OST. Leadership reports to the DO1 Secretary on trust performance. 3.6 FIDUCIARY OBLIGATIONS AND mQUIREMENTS 3.6.1 Fiduciary Obligations Interior has examined the requirements applicable to administration of the Indi- vidual Indian Monies (IIM) accounts. The primary accounting requirements that Interior must meet is set by the 1994 Act. The Act specifically describes the ac- counting duties owed by DO1 to tribes and individual Indians. The act requires DO1 to: + provide adequate systems for accounting for and reporting trust fund bal- ances; + provide adequate continls over receipts and disbursements; 3-27 Comprehensive Trust Management Plan Version I .O 3/28/03 ~ .- Business .. ...-.._ ., ., Objectives . ~~. ._. and . .,,. Business . - .. Profile .. .~-~.--.-.~.- -...,_- -- . ~ ,- ..,,._ ,. -~ 101-56 L X X X X _I X X X , __. DO[ _. Propriclnry , ..... . .... ~... Information .. ~ X - X X X ___. X - X X - X Table 3-2. Exnrnples of Statutory nnd Regulatory Requirements - Computer Crime Act of 1984 Computer Fraud and Abuse Act of 1986, Public Law 99-474, 18 United States Code (U.S.C.) 1030 American Indian Trust Fund Management Reform Act of 1994 Appraisal handbook Computer Security Act of 1987, Public Law 100-235,40 U.S.C. 759 DO1 Departmental Manuals .- - ~ - ~. _. .~ 303-Principles for Managing Indian Trust Assets 375-Information Technology Security Program 376-Chapter 19, Information Technology Security Program. April 15. 2002 38O--Records Management Program and Res-pnsibilities __ 384-Records Disposition 44 I-Personnel Suitability and Security Requirements, Chapter 1-6 ~ ~ . _ ~ 444-Physical Security and Building Security, Chapter 1 486-Vital Records DO1 Information Technology Security Plan (ITSP), Version 2.0, April 15, 2002 DO1 Information Technology Security Reference Handbook, Sep- tember 2001 DO1 Risk Assessment Guideline, April 23,2002 DO1 Contingency Planning Guideline. April 22. 2002 DO1 System Security Plan (General Support System [GSSJ) Guide and Template, May 31, 2002 X . -_______ __ - -- DO1 System Security Plan (major applicalion [MA]) Guide and Template, May 31, 2002 Electronic Communications Privacy Act of 1986, PI. 99-508 Federal Oil and Gas Royalty Management Act of 1982 X X X X I X X 3-29 Comprehensive Trust Management Plan Version 1 .O 3/28/03 .” ._ - - -.r -.--- -- - .- -~ _ - - I ” ,. -..-.-.- t a #F! - -~ __ X X X - - X - X X X X - X X X DOi Proprietary Information X X 7bble 3-2. Examples ofSratutory nnd Regulatory Requirements (Continued) Federal Records Act of 1950 __ X Federal Information Processing Standard (FIPS) PUB 102, Guideline for Computer Security Certification and Accreditation, September 1983 FlPS PUB 31, Guidelines for Automated Data Processing Physical Security and Risk Management, June 1974 FIPS PUB 73, Guidelines for Security of Computer Applications, June 1980 Freedom of Information Act, 5 U.S.C. 552 Generally accepted government auditing standards (GASGAG AS)-. “Yellow Book” Generally accepted accounting principles applicable to Indian trust (Federal Accounting Standard Board (FASB). American lnstiute of Certified Public Accountants (AICPA), Governmental Accounting Standard Board (GASB). etc.) Government Information Security Reform Act (GISRA), Title X. Pub- lic Law 106-398 -^ .~ Government Performance and Results Act (GPRA) of 1993. Public Law 10362, 107 Stat., 5 U.S.C. Section 306,31 U.S.C. 7 105.1 11 5- 11 19,3515,9703-9704 Information Technology Managemgni Reform Act of 1996 (Clinger- Cohen Act), Division E of Public Law 104-106, 40 U.S.C. 1401 National Archives and Records Administration (NARA) in 36 Code of Federal Regulations (C.F.R.) and 44 U.S.C. National Security Act, as amended. Public Law 102-485 SPEC PUB 800-12-An Introduction to Computer Security: The NlSf Handbook, October 1995 SPEC PUB 800-1 4-Generally Accepted Principles and Prac- tices for Securing Information Technology Systems, June 1996 SPEC PUB 800-1 8 4 u i d e for Developing Security Plans for In- formation Technology Systems, December 1998 X X .. __ -_ SPEC PUB 800-26, Security Self-Assessment Guide for Informa- tion Technology Systems, November 2001 SPEC PUB 800-30, Risk Assessment Guide for Information Technology Syjtems, January 2002 SPEC PUB 800-34, Contingency Planning Guide for Information Technology Systems. June 2002 SPEC PUB 800-47. Security Guide forlnterconnecting Informa- tion Technology Systems, September 2002 -I--___ X _ _ X ..-_____-- 3/28/03 3-30 Comprehensive Trust Management Plan Version 1 .O _, _ _ . - Business _-- -_. - __ Objectives . ~ and Business Profile - _ Table 3 -2. Exampies ofstatutory and Regulutory Requirements (Continued) -- i A-1 1, "Preparing, Submitting, and Executing the Budget," June 22,2002 A-50, "Audit follow-up Inspector General (1G)iGeneral Accounting c ____-__ Office (GAO)" A-123, "Management, Accountability, and Control" A-127, "Financial Management Systems," July 23. 1993 ~. ~~ __ I_____. A-1 30, "Management of Federal Information Resources," Febru- ary8.1996 OST Investment Policy Paperwork Reduction Act of 1978, as amended, Public Law 103-13, 109 Stat 163,44 U.S.C. Ch 35 .___ Privacy Act of 1974, Public Law 93-579. 5 U.S.C. 552a (1974) Prudent man rule subject to limitations under 25 U.S.C. 16z(a) Sections applicable to Indian Tnrst of the Uniformed Principal and Income Act Statement of Auditing Standards 70 review related to trust fund ac- counting system The Chief Financial Officers Act of 1990, Public Law 101-576, 31 U.S.C. 901, et. seq., as amended The Federal Financial Management Improvement Act of 1996 The Federal Managers' Financial Integrity Act of 1982, Public Law 97-255,31 U S C 1352 __________ Title 25 of the United States Code and applicable regulations for land use and leasing ~- -.-I___ Universal Standards of Professional Appraisal Practices ---I___ For hrther information on which functions within each business line are affected by these requirements, refer to Appendix C. -I 3.7 TRANSITION TO CHAPTER 4 Chapter 4 defines the new organization. It also describes the roles and responsibilities needed to support the new service delivery model, achieve the business objectives, and meet the fiduciary obligations. 3 12 8/03 3-3 1 Comprehensive Trust Management Plan Version 1 .O DOI Proprietary Information - ,. -- ,.. --. - - - 3/28/03 3-32 Comprehensive Trust Management Plan Version 1 .O DOI Proprietary lnformation Chapter 4 *-wqc-> Organizational Realignment -7 4.1 INTRODUCTION The updated strategic direction and business profile provide the fiindamental in- formation needed to reform and revitalize an organization. How the organization is structured to support the business lines is equally critical to success. The rea- lignment is a major componcnt of the overall modernization effort. As portrayed in Figure 4- 1, realigning the organization is the next important step toward realiz- ing comprehensive trust management. Figure 4-2 shows the roadmap to and core components of this chapter. Figure 4-1. Comprehensive Assessment and Planning Methodology -- Execution 8 Measurement 4-f Comprehensive Trust Management Ptan Version I .O 3/28/03 Chapter 1 Introduction Chapter 2 Strategic Direction Business Chapter 3 Business Objedives and Business Protile Chapter 4 Organizational Realignment 4.2 BACKGROUND DO1 has undertaken many trust reform initiatives over the years, with modest success and unanticipated failure. Most interested parties know that continued in- dividual initiatives will not generate the breadth 01- depth of improvement re- quired. Accordingly, DO1 has set in motion a complete modernization of Indian trust management, addressing all aspects of service delivery, including organiza- tional design. Reorganization is vital to this multifaceted approach to trust reform. Past attempts to change the organization have met with resistance and mixed results. The Joint DOUTribal Leaders Task Force discussions dearly linked organizational structure with the ability to provide quality services to trust beneficiaries. This chapter contains the plan for reorganizing DOI's Indian trust operations to improve the effectiveness and accountability of trust management. The implemen- tation of this organizational design will enhance benefits to trust beneficiaries in the following ways: + Dedicating personnel to provide consolidated beneficiary services + Increasing the emphasis on tribal contracting and compacting + Maintaining staff and conserving monetary resources within BIA and OST . . . ~~ 4-2 Comprehensive Trust Management Plan Version 1 .O 3/28/03 I, - - " ^ I .-. . . . I ~ ~ ............ ~~ ... ~ Organizational Dot Proprietary In formalion ! t Guidance including . ... ... ~ .... ~ Rdes & Re spponsibdrles Modei DO I Proprietary Info rmn fion - I . -. ___--.- - ,. , _ _ -. .” ’- -~~ - . - Organizational Realignment 4.3 TRIBAL CONSULTATION - - *--”. . -_ + Improving organizational accountability + Elevating the profile of Indian economic developrnent + Grouping organizational functions more efficiently. DO1 held sessions with the Joint DOl/Tribal Leaders Task Force to discuss col- laboratively the organizational issues related to trust reform. The task force evalu- ated numerous proposals for trust reform that had been submitted to the Secretary of the Interior. In addition, it assisted DO1 in reviewing current practices. The task force provided proposals to the Secretary on organizational alternatives for the management of trust services within DOI. The task force represented a broad cross-section of tribal interests. It consisted of two leaders from each of the twelve BIA regions, with a third acting as an alter- nate. Members of the federal team were senior Department officials. The task force held joint multiday meetings in Shephcrdstown, WV, Phoenix, AZ, San Di- ego, CA, Minneapolis, MN, Bismarck, ND, Portland, OR, Anchorage, AK, AIex- andria, VA, and Washington, DC. The task force ultimately agreed to recommend that Congress establish the posi- tion of Undersecretary for Indian Affairs, appointed by the President, confirmed by the Senate, and reporting directly to the Secretary. The Undersecretary would have direct-line authority over ail aspects of Indian affairs within DOI. This authority would include coordination of trust reform efforts across the relevant agencies and programs within DO1 to ensure these functions are performed in a manner consistent with its trust responsibility. The Office of the Special Trustee for American Indians would be phased out. The task force also agreed that the Office of Self-Governance and Self- Determination should report directly to the new Undersecretary for Indian Affairs. This arrangement would enhance the ability of tribes interested in moving toward more compacting and contracting to directly provide the services due to Indian beneficiaries. Similarly, the task force agreed that any authorizing legislation would also include the creation of a Director of Trust Accountability, reporting directly to the Undersecretary, who would have day-to-day responsibility for overseeing the trust programs of DOI. Members of the task force also recommended a restructuring of BIA. DO1 and the tribal representatives agreed that the status quo was unacceptable and that DOI’s long-standing approach to trust management needed to change. Moreover, this change must be reflected in a system that is accountable at every level, with people trained in the principles of trust management. 4-3 Comprehensive Trust Management Plan Version I .O 3/28/03 DOI Proprietary Information . - - - I.".. . . I ~ _.._--- .~ - _ 4.4 NEW ORGANIZATION + Align responsibility, function, and authority + Provide effective management controls + Support accurate and timely reporting + Support performance measurement + Support personal and organizational accountability + Clearly assign and integrate fiduciary obligations. - . - - After nearly a year oftask force meetings and organizational consultations, the process closed with a final consultation session in Washington, DC, in December 2002. Although the task force consultation process did not reach consensus on draft legislation supporting a trust organization structure, it did reveal the desires of the tribes regarding the kind of reorganization that would both strengthen tnist functions and meet the beneficiaries' needs. The new organizational structure, approved by the appropriate Congressional committees in December 2002, better supports achievement of the modernization goals and objectives. The future comprehensive trust management organization must fully align with the new strategic direction and business profile, and its roles, responsibilities, and resources must effectively support the new service delivery model. DO1 analyzed the service delivery model to document elements with a common purpose and function. To design an organization that effectively executes service delivery, DO1 placed directly related activities under a responsible manager to ensure clear direction, management, and responsibility. DO1 aligned subordinate layers under the responsible managers until all functions were fully accounted for in the organizational model. Properly aligning these elements with the service delivery model ensures efficient workflow. Finally, DO1 evaluated the new design for compliance with selected organizational objectives used to guide the initial analysis. These organizational objectives are as follows: + Support a strong, beneficiary-focused service delivery + Align duties and responsibilities such that different functional activities are not duplicated in another part of DO1 The new organizational structure aligns with the service delivery model (Figure 3-7) and supports the overarching principles of performance and account- ability. This model, described in the following sections, represents the intended 4-4 Comprehensive Trust Management Plan Version 1 .O 3 J28IO3 ~ ~ ~ , ” ” - _ _ ,..,-,. ~. . - .--,. .... ... -. ..~.. - ~ . - ” _ .-,.,.,.-- _ _ Organizational Rea Iignment and desired-but not yet implemented-structure. The new structure will require revising the DOI Depurtmental Manual, which addresses operations. 4.5 SERVICE DELIVERY ASSESSMENT The service delivery hnctions (as shown in the service delivery model in Chapter 3) are key to developing the organizational structure. l h e y assist in identifying the specific organizational elements responsible for delivery of products and serv- ices, and for providing cntical support to the direct delivery functions. The service delivery model indicates that four primary offices within DO1 are critical to re- forming comprehensive trust management: The Oflice of the Assistant Secretary-Indian Affairs oversees BIA, which has stewardship and management of trust lands and natural re- sources in addition to other responsibilities and services outside of trust program activities . The Office of the Assistant Secretary-Land and Minerals Management continues to provide support services to BIA for trust land and mineral matters through BLM, MMS, and OSM. The Office of the Assistant Secretary-Policy, Management and Budget continues to provide support services to BIA (through OHA) in the deter- mination of disputed legal ownership and certain probate issues. Office of the Special Trustee for American Indians (OST) provides the fi- duciary trust management activities and oversight. Within the four primary offices many organizational components-located in the central office, regions, and agencies-support comprehensive tnist management (Figure 4-3). (Figure 4-3 displays only the organizational elements involved in comprehensive trust management. j DOI Proprietary l n formation 4-5 Comprehensive Trust Management Plan Version 1 .O 3/28/03 I " , - - r . - ~ . _ L ..-_ -_..-. .__ - .---.-._ - DOI Proprietary Information -_-. r _ _ -_ _._. Figrtre 4-3 Summary Overview- Comprehensive Trust Managemenl Structure 4.5.1 Central Office (only key ?fleers with significant trust duties are shown) ~~~~~...~_____ . ~ ~ ~ ~ . ~ ~ . . Note: The shaded boxes and dotted lines between them indicate a workiOg relationship and the need to coordi- nate and communicate trust management issues. This coordination provides the connectivity needed to avoid stovepiping of bust management hctions in the different organizations. The following sections describe the locations---central office, regions, and agen- cies--and their structures. Figure 4-4 shows the overall comprehensive trust management structure in the central office related to Fiduciary trust asset management. 4-6 Comprehensive Trust Management Plan Version 1 .O 3/28/03 - _ - I I. Organizational Realignmen f - -.__ _ I . _-- . . 4.5.1. I BUREAU OF INDIAN AFFAIRS BIA has primary responsibility for the stewardship of Indian and tribal natural resources and land management. The BIA structure in the central office provides leadership and guidance through statutes, regulations, policies, and procedures for servicing trust land management. The principal element is the Office of the Dep- uty Director-Field Operations. The Deputy Director-Field Operations provides the direct line authority to the regions. The Deputy Director-Trust Services provides policies, procedures, and guidance for natural resources management in the field through the following di- visions: + Division of Natural Resources > Water resoiirces > Irrigation and safety of dams > AgriculturdRange management > Fish, wildlife, and parks + Division of Real Estate * Land acquisition and disposal k Land title records office DOI Proprietary In formation .1 -.-- ._- ,". . _ _ I - ."___.._____ __ k'igure 4-4. Central Office-Corrpehensi ve Trust Management Structure Notes: The shaded box and dolted line from the Deputy Director for Field Operations to the OST side of the s t m - ture indiate a working relationship. The Deputy Special Trustee for Field Operations will be located in Washing- ton. DC. or Albuquerque, NM 4-7 Comprehensive Trust Management Plan Version 1 .O 3/28/03 ~ . - . r . ” - _.-_.._I. .- N Probate k Rights-of-way k Lease/permit + Division of Forestry k Forestry and Fire . . + Division of Energy and Minerals Resources k Energy and Minerals Management. 4.5.1.3 OFFICEOF I&AREG AND APPEALS tary-Policy, Management and Budget. DO1 Proprietary Information .. -_ -- -.-. --~ “ ---_ The Office of the Assistant Secretary-Indian Affairs shares responsibility with OST for information technology policy, planning, architecture, configuration management, engineering, security, privacy, project management, development, and operation of trust systems and their integration with the DO1 and federal ar- chi tecture. 4.5. I .2 MMERALS MANAGEMENT SERVICE, BUREAU OF LAND MANAGEMENT, AND OFFICE OF SURFACE MmmG The MMS supports mineral lease revenue coilection, disbursement activities, and audit compliance for the trust programs. BLM provides mineral appraisals, min- eral operations approval and compliance, and cadastral surveys of beneficiaries’ trust land. OSM regulates all coal mining and reclamation operations on Indian lands under the Indian Lands Program Regulations. The line of authority for MMS, BLM. and OSM goes to the Assistant Secretary-Land and Minerals Man- agement. OHA issues probate orders determining heirs to trust land through the complex probate estate administration, and the line of authority is to the Assistant Secre- 4.5. I .4 OFFICE OF THE SPECIAL TRUSTEE FOR AMERICAN WDIANS OST provides fiduciary guidance, management, and leadership for both tribal trust accounts and IIM accounts. OST oversees and coordinates DO1 efforts to ensure establishment of consistent policies, procedures, systems, and practices throughout DOI. OST consists o f the following organizational units, which per- form oversight activities and operations for OST personnel: + Chief Information Officer provides and maintains the information tech- nology where beneficiary records information resides. + Trust Review and Audit analyzes reports and production data for accuracy and manages contractors performing independent audits. 4-8 Comprehensive Trust Management Plan Version 1 .O 3/28/03 + Deputy Special Trustee for Trust Accountability coordinates policy, de- velopment of regulations, and establishment of procedures for comprehen- sive trust management. + Deputy Special Trustee for Trust Services provides beneficiary trust rec- ords maintenance, trust hnd management, and investment services. + Deputy Special Trustee for Field Operations manages the interface with beneficiaries, overseeing and providing technical assistance to the trust of- ficers. 4.5.2' Regions The regional structure provides the trust elements needed for delivery of trust management services and support to the field. Figure 4-5 shows the regional structure, which addresses the BIA and OST trust management functions in the regions. Figure 4-5. Region-Coniprehensive Trust Management Structure 4.5.2.1 BIA REGIONAL DIRECTOR The Regional Director's office, which includes trust operations, provides steward- ship of natural resource and land management technical assistance to agency su- perintendents. A deputy director provides line authority for the Division of Natural Resources and Division of Real Estate, which provide polky and decision support to the agencies. 3/28/03 4-9 Compreherisive Trust Management Plan Version 1 .O DOI Proprietary Information ~ ~ ,._.____..F__.. -, . ..... _..-., __"__..__,. ~ ..._ ~ _. tee--Field Operations. 4.5.3 Agency to the agencies. .__ ~.,. .~ The Deputy Regional Director for Trust Services provides information and assis- tance to the OST regional trust administrators. The working relationship is similar to that between the Deputy Director-Field Operations and Deputy Special Trus- 4.5.2.2 OST REGIONAL FIDUCIARY TRUST ADMINISTRATORS The regional fiduciary trust administrators provide the direct line authority connection to the agency trust officers. They closely monitor the field activities while providing policy and guidance. The regional trust administrators provide some of the direct support functions to the agency-level trust officers and resolve issues escalated by the trust officers. 4.5.2.3 OST OTFM AND REPORTING AND RECONCILIATION The Office of Trust Funds Management (OTFM) and the Office of Reporting and Reconciliation are located in Albuquerque, NM. They directly support the agency trust officers. OTFM records, invests, and disburses beneficiary trust fund assets. The Office of Reporting and Reconciliation is responsible for internal and exter- nal reconciliation and reporting. The interaction between the beneficiaries and comprehensive trust management elements takes place in the agencies. The likely contacts for beneficiaries are the Deputy Agency Superintendents-Trust Services in BIA and the Trust Officers in OST. Figure 3-6 shows the relationship and direct-line authority fi-om the regions 4-1 0 Comprehensive Trust Management Plan Version i .O 3/28/03 DOI Proprietary injormation ~ _I . . ~ . , .,..-. ~ . ~ . . ~ ..... , . . _, . . -. ..... , ... __ ... - - , - .. . - .~ ~ /-A= -Waler Resources -Forestry and Fire -Irrigation and Safety of Dams -Agriculture -Fish. Wildlife. and Parks 4.5.3.1 BIA DEPUTY AGENCY SUPERINTENDENTSTRUST SERVICES The Agency Superintendent is the responsible official for managing all BIA ac- tivities at an agency office. The following activities, however, may be performed by a Deputy Agency Superintendent for Trust (DAST), when one is available: DAST will work with tribes and individuals on developing trust resource management plans. DAST will develop and implement trust fund expendihire plans for super- vised and encumbered accounts. DAST will develop natural resource protection, maintenance, use and en- hancement plans, and ensure that cultural and environmental concerns are considered and addressed. + DAST will ensure that regulatory and procedural requirements for man- agement of day-to-day natural resource business processes are made avail- able. to tribes and followed. DAST is the appropriate liaison to contract and compacted tribes regard- ing the tribes management of their natural resources. Organ izationul Realignment . ..... Division of Naturai Resources Figure 4-6. AgencpComprehensivc Trust Management Structure ~ ~~. . ~ . ~ ~ ...... ~ ~..~..~ ..... ~. ~ ~ . . . . ~ .... ~ ~...~ .... .. . ................. ~. .. . ..... .~ 1. Region I ......... ~~. . .... . . ~ . ~ ~ ~.~ .......... .......... - Trust Services Regional Trust Administrator Trust Officers Social Worker Supenntendenl and - Trust Services Superintendent Land Acquisition and Disposal -Land T i t k Records Office -Probale Rights of-Way -Leasepermit 3/28/03 1 .~ . ~ .. . ~ . . ~ ~ ~ . ~ ~ . . . ~ ................... . ..... 4-1 1 Comprehensive lrust Management Plan Version 1 .O . . . I - _--. ~ -.. ' , + DAST is the appropriate liaison to state, local, and other federal agencies to promote contracting and compacting for protection of trust natural re- sources, resolving boundary disputes, conservation enforcement, coopera- tive agreements for fire suppression and habitat development, etc. + DAST will at times have full access to trust officers employed by Interior and work in a collaborative style to ensure a seamless presentation of trust management processes to all trust beneficiaries.' ' I t DOI Proprietary Information 4-1 2 Comprehensive Trust Management Plan Version I .O 4.5.3.2 C)ST FIDUCIARY TRCJST OFFICERS The OST fiduciary trust officers interact with beneficiaries for trust needs. The trust officers work closely with the Deputy Agency Superintendents and their staff to work on beneficiary issues and ensure the beneficiaries are receiving de- livery of products and services. Some of their specific duties include the follow- ing: + One or more trust officers are to be located in local BIA agencies, where appropriate, or within reasonable proximity if necessary. Trust officers are to be the primary contact for trust beneficiaries regarding information re- lated to their tnist assets. + Trust officers' role is to be a key contact for trust beneficiaries and to work cooperatively with Superintendents by being the trust liaison for trust matters involving information about beneficiary's trust assets, status of account, obtaining required information for trust accounts, gathering in- formation for use by the Agcncy in manazing a beneficiary's natural re- sources, etc. + Trust officers will work with the Agency to assist, as requested, in the de- velopment of fiduciary trust management plans, and will review and con- cur with the plans, when appropriate, to ensure fiduciary trust obligations are met within the plan. + Trust officers will establish, implement, and maintain controls over trust cash assets. It is anticipated that these procedures and controls will be con- sistent from agency to agency and will be established in consultation with the DAST and Superintendent. + Trust officers will serve as the local collections office for all trust funds, encoding transactions, monitoring the accounts receivables, and providing technical assistance on trust matters. + Trust officers will receive reports from the Trust Program Management Center on performance mcasures. They will work with the DAST to Some regional offices provide these services typically provided by agencies. 3/28/03 D 01 Proprietary Info rm n tion - ...- - - - ~- CoordmaIe Hlth BIA lo pwk3e a influence poduas and m e s on issues mnrrmng the CTM fundwn Orgunizntiona f Retrlignmerit " _... - - __ . - _ " _- - _-_ ~ . . ^ improve any weaknesses reported and revise business processes a s appropna tu. + Trust officers will be primarily responsible for the appropriate creation, storage, and disposition of trust records and will work together with the DAST and Superintendent to ensure that policies, procedures and training are followed and made available to agency staff as necessary. + Trust officers will ensure that appropriate documentation of all fiduciary trust transactions and internal controls are in place and followed. + Trust officers will review and audit fiduciary trust asset management deci- sions and transactions that meet high-risk criteria. Trust officers will work collaboratively with the DAST in a contemporaneous manner to reach concurrence on such decisions and transactions. 4.6 ROLES AND RESPONSIBILITIES Table D-1 in Appendix D identifies the roles and responsibilities for the core roles of the comprehensive tnist management organizational design. Table D-I. Roles and Rcsponsibilitics Mfice Or the Special Trustee tor Amwicsn Indians R d C es Mwior lhe external ennroomenl fa Executes bus: management rok a d focuses outside OST Specid Tnrsfee 4.7 SUMMARY orgaruzabon lhal W e s me Seuetaryd hlm. BIA dtreclas. mbal task forces. an&, The organizational structure design provides the necessary elements for effec- tively accomplishing the comprehensive tnist management mission, strategic di- rection, business plan, and service delivery model-with a focus on delivery of services to beneficiaries. The organizational structure presented in this chapter is a natural extension of the strategic direction of Chapter 2 and the business profile of Chapter 3 . It clearly delineates the organizational units that have the roles and responsibilities required to meet DOI's fiduciary trust obligations. 4-1 3 Comprehensive Trust Management Plan Version 1 .O 3/28/03 LjOI Proprietary In formation Chapter 5 Transformation Activities ,L'&T T,?F% 5.1 INTRODUCTION Chapters 2 , 3 , and 4 describe DOI's strategic direction, business objectives, serv- ice delivery model, organization realignment, and roles and responsibilities re- quired to achieve a new level of performance and accountability in Indian trust management. This chapter describes the transformation activities required to achieve comprehensive trust management as defined in the previous chapters. This chapter is a shift from design to implementation of comprehensive trust management and represents the final step in this plan, as shown in Figure 5-1. Figure 5-2 shows the roadrnap to and core components of this chapter. Figure 5- I . Comprehensive Assessment and Planning hiethodology 5-1 Comprehensive Trust Management Plan Version 1 .O 3/28/03 ~. _. i : Beginning in January 2002, DO1 set essential goals, assessed improvement prog- ress, analyzed commercial best practices, continued initiatives to solve problems or implement improvements, and reconirnended a comprehensive assessment of trust management modernization. Section 5.2 describes the project components identified for inclusion in the ongoing comprehensive transformation effort. 5.2 PROJECT ACTIVITIES REQUIRED FOR A COMPREHENSIVE TRANSFORMATION EFFORT This section addresses the overall activities, such as project management, organizational realignment, and change management, required for successhl transformation. The individual implementation tasks fall under six major project components: + Project planning and management + Changeirisk management Figure 5-2. Roadmup to and Core Conrponents of Chapter 5 Chapter 1 Inlroduction Chapier2 Strategic Direction Business O b p d i v t l Chapter 3 Business Objectives and Business Profile chapter 4 Organizational Realignment Chapter S Transformation AcIivilies 5-2 Coniprehensive Trust Management Plan Version 1 .0 3/28/03 ~ r - l - -----.. DOi - Proprietary - . In formation -. *_- Trans-irmation ~” .”_ ., Aciivilies ~. “.-. ---- _._, .- . . + Create vision and strategic plan + Organizational development and rearignment + Trust reengineenng + Establish perfomancc management program. See Figure 5-3 for an illustration of these six transformation activities. 5-3 Comprehensive Trust Management Plan Version 1 .O 3 12 810 3 -j_ .-_..-.I._____._ - Trmsfurmuiion Acrivilies Project Planning & Management /Trust Mgmc. project team p t e e r l n g committee . &elailed integrated p r o w k r e s o u r c e s end bud& requirements J tracking systems ior refom? efforts I success Create Vision & Strategic Plan burlnesa objecllv - Present vision and Sollcil leeback fro 3/28/03 ~ . .. , .. __. _. ,. . , ~ - . " .. . . Fipirrf 5-3 Tion~furmarion Aclivi!ies Organizational Development 8 Realignment Vision -7 * s-5 .. , .. . . .... . . - ^. , , .- _I,-_ ". ..__I_." . . . . ... , . . ___. . D 0 I Prupri ew ry InJu rmo r ioir I Comprehensive Trusi Managemeiil PIm Version I .O D 0 I Proprie fa ry Info rm a t io ?i Transformation Activities ,r ". - - . ~ - - - ~ + Monitor performance/success. -_ __- ---I - - The following subsections describe the major components. Project planning and management activities include the following: + Complete and maintain a detailed integrated project plan + Institute status reporting and tracking systems for reform efforts + Engage commitment and ownership of new vision + Conduct detailed change and risk assessments + Develop, execute, and track communication plan. - .-- - Project planning and management is an ongoing process. Significant resources will be required over several fiscal years to succeed, especially in light of the en- visioned organization, process, and information systems modernization. As with all such efforts, total requirements can easily exceed available resources. This group of activities involves establishing a more formal process and structure for identifying, requesting, and allocating resources across the project. Additionally, all trust transfomiation efforts need to be coordinated. The Office of Indian Trust Transition manages and provides oversight to transformation activities and plan- ning. + Continue engagement of Comprehensive Trust Management (CTM) proj- ect team and DO1 trust executive steering committee + Identify and manage transformation resources and budget requirements Transformation requires a sweeping culhire change within DO1 trust management functions to align the workforce with the new strategic direction and business pro- file. New processes and systems will fall short if the organization's culture does not support them. A top priority is to initiate a change management project that transitions organizational norms, beliefs, and values to hlly support service deliv- ery, performance, and accountability. Part of any transformation effort is to estab- lish a sense of urgency because trans fonnation requires the proactive cooperation of many stakeholders. This requires mitigating risk, actively fostering change, and tracking and managing a significant amount of communications. These change management tasks will improve the alignment of the human ele- ment with the business practices to complete the modernization: + Develop and implement strategies to foster change and mitigate risks 5-7 Comprehensive Trust Management Plan Version 1 .O - - . 5.2.1 Project Planning and Management 5.2.2 ChangeRisk Management 3/28/03 DOI Proprietary Information ~ ~ , . ~ ---_Y _--,-- . . ,. . ” . ...- . ~- ___ . . .. ._ . . ,. ~. ... . , . + Realign Organization . . ~ . ,. ~.__ As previously mentioned, to fulfill its trust responsibilities effectively and effi- ciently, interior must have an overall strategic plan to guide design and implementation of trust reform efforts. This strategic plan describes the vision, goals, and objectives of trust reform and operation of the trust program. It will be regularly evaluated and updated to ensure its responsiveness to the needs of Interior’s trust operations. It will be a dynamic strategic plan will be adapted to changing environments. This involves clearly defining detailed CTM roles and responsibilities, identifying clear lines of responsibility, performance, and accountability, mapping the interactions required among stakeholders, and supporting the process of realigning the organization. The steps involved in organizational development and realignment are the follow- ing: + Define Comprehensive Trust Management roles b Develop a detailed organizational description * Define roles and responsibilities, including new performance measures for new organization * Conduct workforce planning for implementation * Develop a detailed staffing plan * Determine gaps between current funds and requirements + Determine current policies and constraints + Assess for policy impact and make appropriate changes * Implement new organization + Design and deliver required training. This organizational development will expand upon current efforts. Upon recommendation of OST and BIA based on Joint DOI/fribal Leaders Task Force input on December 4,2002, the Secretary of the interior approved a new organizational structure within current statutory constraints to provide trust services to the beneficiaries in a more accountable and efficient manner. The 5-8 Comprehensive Trust Management Plan Version 1.0 ____ 5.2.3 Create Vision and Strategic Plan 5.2.4 Organizational Development and Realignment 3/28/03 Transformation Activities - - “ - T , , - - - - - - _. _- -. 5.2.5 Trust Reengineering Probate Tltle Services Appraisal .. ~ -_ , ~ 5.2.5.1 ‘‘ASIS” TRLJST PROCESS MODELING Beneficiary Services Surface Asset Management Subsurface Asset Management Accounting Management Cadastral Survey. tions. D 0 I Proprietary Info rma ti o n .- -- .. ..-..--- ”. - appropriate Congressional committees approved reprogramming funds to support the new organizational structure on December 18,2002. This activity requires an assessment of how DO1 intends to perform its role as trustee and manage the three business Iines of beneficiary service, financial accountability, and natural resource management. DO1 then must develop efficient and standard business processes and supporting systems across all three trust business lines, incorporating best practices when possible. At the core of the reengineering efforts is beneficiary relationship management. Beneficiary relationship management is the process of establishing positive relationships with all beneficiaries, understanding comprehensive trust management servicing requirements, achieving effective communication between beneficiaries and the DO1 government workforce, and quickly and efficiently tracking and resolving service delivery issues. These tasks will be integrated into the process and system reengineering efforts. The fiIst phase of the reengineering project was the “As-is” Model effort that commenced in February 2002 and finished in February 2003. The “As-Is” Model establishes a comprehensive understanding of how trust operations are conducted currently. The final “As-Is ” Trust Business Model Report will be issued during the first quarter of calendar year 2003. The report provides detailed documenta- tion of the Indian trust’s eight core processes: The report examines related industry standards and performance measures, docu- ments the “As-Is” trust business model, and provides findings and recommenda- 5-9 Comprehensive Tnist Management Plan Version I .O 3/28/03 5.2.5.2 “TO-RE” TRUST PROCESS MODELING During the “To-Be” phase, DO1 will take a fresh look at how the Indian trust should be designed and operated. DO1 will go beyond incrementally revising the existing eight core trust processes and redefine the core processes and activities required to successfully perform trust management in the future. These activities will build on the high-level service delivery model presented in Chapter 3, and will integrate the specific functions of trust management into an effective, per- formance-based, detailed service delivery model. The service delivery model is a roadmap that displays the relationship between all the elements of comprehensive trust management service delivery. New process flows and interactions will then be designed with improved information technologies and best practices. l h e change effort will be a DOI-wide transformation encompassing most aspects of the trust. The intent is to design and implement necessary changes to ensure that new strategic goals and business objectives are made possible. 5.2.5.3 hLNFOKMATION SYSTEMS MODERNIZATION DO1 has identified the “As-Is” business, data, application, technology, and secu- rity architecture. A high-level blueprint has been developed to map trust business systems processes from existing procedures and information technology systems. The recommendations from the blueprint are currently being scheduled for review and action. The enterprise architecture and management systems will enable the new business processes to function, to ensure data accuracy and storage capability, and to effect the necessary reporting and auditing. DO1 will upgrade current systems and add new ones to meet the future needs of CTM. Modem and appropriate records and information systems are required to support the core business processes. From the business process reengineering and standardization, existing systems can be ex- panded and new systems introduced that enable faster and more accurate process- ing, provide data and reports simultaneously to multiple users across the nation, and make accurate record keeping an attainable goal. The trust reengineering activity is further described in Chapter 6. 5.2.6 Establish Performance Management Program Improved performance can only be achieved through the design, implementation, and continued use of a performance management program. These activities in- clude setting performance standards, measuring performance, and improving pro- cesses when standards are not met. 5-1 0 Comprehensive Trust Management Plan Version I .O 3/28/03 5.3 PROJECT SCHEDULE The project schedule appearing in Figure 5-4 incorporates the components re- quired for successful transformation. This sample project schedule illustrates ma- jor milestones and will expand as the project unfolds in greater detail and specific initiatives are developed. It is an active management tool that will be routinely updated, tracked, and reported. The schedule is part of a dynamic plan that wilI evolve and change in the future, and is constructed to support the complex nature of the CTM project. 5-1 1 Comprehensive Trust Management Plan Version 1 .O 3/28/03 1 2 -- 3 __._. 4 5 . ___ 6 7 - -~ 8 Change Organizational Culture - . -- --- ___ Create Vision and Strategic Plan ___ -- ____ 9 10 71 12 13 14 15 16- 17 , - - 18 . 19 Organizational Development ._ 20 .- 21 ._ ___ 22 23 -~ 24 25 __ 26 27 -.- - 28 - ~- ~ Dot Proprietary Irformaiion ~ _ _ - Slatus In-process Completed Completed In-process Completed In- proces s In process In-process Complefed In-progress Figrrrc 5-4 C'clmnprehensrve Trust Managenrent Project Schedule . - - ~-~ _ _ _ _ _ . - . ..__I_-________-_ ID ' IaskName - .-j.--- ___- __ Expand Priject Planning and Management -- Establish Comprehensive Trust Management projpct team lnsblute a DO1 Steerlng Committee . Idenify and manage Iransformatm resources and budget requirements lnslrtute status remltina . - and trackinq systems for reform efforts Complete arid niainlain detailed mtegrated prqect plan Monitor performance /success Engage commitment and ownenhQ of new w o n Condud detailed change and risk assessments Develop and implement strategies lo fosler change and mittgate nsks Develoo. execute track communication plan Develol, strategtc direction Determine business objectives and assess buvness environment Develop future service delivery model Devebp organiratwl redeslgn to supPo13 new semce delivery model Identify strategic performance measures to monitor achievement of strategic goals Define Comprehensive Trust Management roles Devdop a detailed organizahonal desuption Define rdes and responsrbtitles including new performance measures for new organlzation Conduct workforce planrung for implementation Oevelop a delailed staffii plan Realign 0rgGnuati-m Determine gaps between current funds and requirements Determine current poriaes and constraints Assess for policy impact and make appropriate changes Implement new organizabon Deslgn and deliver required traming Assess and document "As Is' processes Define To Be' processes Desrgn Mure delailed sewlce ddivery model Present m n and soliat feedback from stakehokiers Design and reengin&r processes and idenbfy workforce. Irainig, polKV, and s ~ s l e m i requirements - - ModernizeAmplement information systems Consolidate nformabon;ystems requnements Develop an enierpme informatton systems aictuterture ldentrfy ail applcations needed to fully supporl the new business model Integrate Glerpnse archlteclure design wth applicatm requirements . . - - Identify processes lo measure Identify the mebics Establish metncs standards Alqn measures wth service delwery standards lnstltute measurement and reporting pocesses - _ - - . 29 30 -- . 31 Trust Reengineering 33 _- - - 32 34 35 36 37 __ - 36 39 40 __- . - 41 __ -- ._ 42 Implement new architecture and applicatms 43 Establish Performance Management Program 44 45 -- -- 46 47 48 5-1 2 Comprehensive Trust Management Plan Version 1 .O 3/28/03 ~ . I - 5.4 RISK MANAGEMENT Risks are always present in a modernization effort of this scale and significance. Because risk management has been an integral part of the overall effort from the beginning, DO1 identified major risks, assessed the potential impact, and devet- oped initial mitigation strategies for the expansion activities of phase two. identifying risks in an integrated manner can be a complex process. The approach used at this point is to assess the strategic framework for potential risks and sever- ity of impact. In this plan, DO1 rated each risk-high, medium, or low-for its potential impact and the likelihood that it will occur. Although initial mitigation strategies are proposed, this high-level assessment of risk cannot replace detailed risk management. The project plan contains procedures for establishing an ongo- ing risk manageinent program. Eight major risks are associated with the C'I'M modernization project. Each in- volves a critical part of the project, and not mitigating these risks could prevent project success. Table 5-1 displays the results of the risk assessment. The se- quence number shows the order in which these risks are likely to occur. Risk The strategic and business directions for CTM lack sufficient definition and clarity to create the understanding and acceptance d the modernization project. Beneficiaries do not accept the 001 modernization plan. Various major stakeholders disagree on the CTM mission and implied boundaries. Project acbon Estabksh a dedicated pqect planning and management team for the entire rnodemuatron effort (several transihon elements in place already) Secure support for the CTM plan and begin developing and managtng the desired lag-term Rartnership Initiate a proactive BRM program for the entire effort to develop support, accentuate the positive changes. and mitigate risk. Table 5-1. Risk Assessment Likelihood Potential impact Medium Modernization efforts can continue. but progress will be more difficult and real change will be limited High. Will severely limit the ability to transition to a performance-based, accountable partnership. High. If the major stakehokleffi cannot LOW -- High Medium agree on what CTM is and what it isn't, then service aod performance expectatis will ahvays be misaligned and dissatisfaction always prevalent. Mitigation strategy Provide as much information and detail as possible in the initial modeniization plan and Ihm devebp a means for updating, expanding, and cornrnunica ting information as the project unfolds. ___________ Organize a consultation effort to give beneficiaries voice and make them a partner in the modernization effort. Develop a ctnnplete libracy of mission- defining information and then. through the proper venue, initiate a process for sharing all information and reaching agreement on the CTM mission. 5-1 3 Comprehensive Trust Management Plan Version 1.0 3/28/03 Risk Sequence delivery can be improved. accuracy needed. Table 5 - I . Risk Assessment (Continued) Sufficient resources are not available lo complete the modernization effort. Organizational revisions do not effectively align with the service delivery model or support achievement of the business objectives, limiting the degree to which s m k e Reengineering efforts do not generate the degree of improvement IXX integration needed. Information systems do not support &e process improvements or be data and r e a d Desired 51.4 cultural shift does not occur, hampering efforts to Likelihooc Potenlial impacl High High Without sufficient resources, implementation actions wll not be completed and progress wll be imited Medium SeMce delivery can be improved. even if the organization is not Low effectrvely aligned. but the degree of unprovement wdl be limited Medium Medium. Ability to improve service wi0 be limited by the degree of innovation and standardization incwpwated in the reengineering. Medium High. Improvement in data and recotd accuracy is a core requirement for the modernization of CTM. Less effective systems will have major negative impacts on performance. accountability. and efficiency. High. If owporate culture does not realign with the new strategic direction. then service will Medium continue to be delivered as it is today, under the guise of new processes and systems. Miligation strategy Ensure that Congress is fully aware of 001's needs and prioritize funding requests based on the highest needs. Directly link the service delivery model and the new organization and validate through me of clearly understood organizational principles Derive dear wncepts and principles from the modernization plan that guide the reengineering effort and create traceable linkages to the service delivery model L.ink processes to measures and assess the capability of the processes to meet planned efficiency Conduct a detailed functional requirements and integration analysis. on the basis of reengineered processes. to ensure optimum support for the "To-Be" environment. Develop performance and accuracy standards to apply to new system procurernent. Initiate a change management program to define the need for change, develop a comprehensive change management plan, and effectively execute the plan. 4 5 6 7 8 complete the modernization. 3/28/03 5-14 Comprehensive Trust Management Plan Version 1 .O Project action Develop a resource requirements and allocation plan for the entire effort and integrate into the Department's overall budget proccss as early as possible. Begin organizational realgnment with the development of an organizational description that clearly defines roles responsibililies. stafl requirements, and workflow Begin to align existing or new organizational elements with the service delivery model as soon as practical. Using the SeMm dehveiy model, conduct detailed business process mprovement icutiabves for all applicable business processes Based on the results of the business process improvement efforts. complete information systems modernizalin that effectively aligns information systems with the business processes and meet performance and accuracy requirements. Initiate a formal change management program lo expand and continue the cultural shift to an integrated. performancebased. and accountable business culture. ~ ~ __._-. _l_l_l ~, -.,. __I._ - /-_--.- . ... ., .....-I_...- Transformation Activities impacts can either be averted or minimized. D 0 I Prop rie f ary In formation _.-____.._ *.__,._ -.. The project actions shown in Table 5-1 are incorporated in the project schedule and influence sequencing and timing. By doing so, potential setbacks or negative 5-1 5 Comprehensive Trust Management Plan Version 1 .O 3\28/03 Chapter 6 6.1 INTRODUCTION Figure 6- I . Cuniprehensive Assessment and Planning Methodology Execution .3 Measurement Chapter 5 described the six major components of trust transformation. One of those six components was Trust Reengineering This chapter further describes that activity, as shown in Figure 6-1. Figure 4-2 shows the roadmap to and core component of this chapter. DO1 Proprie fury information i': ion 6-1 Comprehensive Trust Management Plan Version 1 .O 3/28/03 Business i i i H ~ ~ Hpqi ! ; : i Business Profile ................................ Chapter 4 Organizational Realignment Chapter 5 Transformation Activities tions, and roles. Figure lnhodudion Chapter t J 6-2. Raudmup to and 1 Core Introduction Components I 1 Hstw of Chapter 6 Chapler 2 Strategic Direction ................................................. Envirment Business Obpctives ...................................................... , ........................... , ..................... 8 ~ .f ............................ Chapter 3 Business .Objectives and FutureSeMce i Oelivery Model i~~ .................................................... .......................... The strategic direction and business objectives described in Chapters 1 and 2 and the reorganization plan for the Indian Trust become major inputs to the reeng- neering effort's second phase-the To-Re Model. Broadly, the reengineering project has been organized into two major phases: The As-Is Model-documents the current processes, obligations (laws regulations, trcatics, ctc.), controls, inputs, outputs, mechanisms, organiza- The To-He ModeI-includes creating management structures and building blocks, managing change, developing a project management office, and designing the To-Be model. The model will incorporate the three business lines: beneficiary services, financial accountability, land and natural re- source management. 6-2 Comprehensive Trust Management Plan Version 1.0 Trends Prodlnfs ?. services ........................................ ... 3/28/03 j Guidarre L ........................ "_._..~ll .. ..~.-. . . .~.. - , ." . ._ ~ .,..,. Trust Reengineering port 6.2 THE As-Is MODEL dian trust's eight core processes: + Probate + Title Services + Beneficiary Services + Appraisal + Surface Asset Management + Subsurface Asset Management + Accounting Management Cadastral Survey. Once the To-Be Model has been designed, parts of it will be piloted and then a final design will be implemented. The concepts and activities required for this section are described in greater detail in the EDS As-1s Trust Business Model Re- The first phase of the reengineering project was the As-Is model effort that com- menced in February 2002 and finished in February 2003. The .4s-Is model estab- lishes a comprehensive understanding of how trust operations are conducted currently. The As-Is model effort started with the development of a project plan and selection of data collection tools. A week-long workshop that included over 60 DO1 and Tribal representatives was then held to develop a baseline of eight core Trust processes. An As-Is Business Model Team consisting of over 20 EDS consuttants, DO1 process sponsors and Joint DOIRribal Leaders Task Force members was formed. This team held 10 multi-day work sessions at field loca- tions with BIA regions, a session with the compact and contract Tribes, and a ses- sion with the OSTiOffice of Trust Funds Management (OTFM). Through these sessions, more than 1000 subject matter experts from the Land Trust Records Of- fices, Tribes, BIA Agencies, BLM, MMS, OHA, and OST were consulted. For each of the eight core trust processes examined, a baseline model documenting the standard manner in which each process is performed was developed. Regional variations from the standard baseline processes also were documented. As stated in subsection 5.2.5.1, the Final "As-1s Trust Business ModeI" report will be issued in March 2003. The report provides detailed documentation of the In- The report examines related industry standards and performance measures, docu- ments the As-Is trust business model, and provides findings and recommenda- tions. 6-3 Comprehensive Trust Management Plan Version 1 .O __ .-__. 3 /2 8/03 DO1 Proprietary Information _.I__.. _. , .. .._. -... 6.3 THE To-RE MODEL The To-Be model is the new integrated transformational design for trust manage- ment within DOI. The To-Be model will not only encompass reengineering and designing new Trust business processes; it will also include coordinated im- provements and requirements in supporting systems, organizations, training, and personnel requirements, combined with an internal and external communication plan. The To-Be phase allows the Department to take a fresh look at how the Indian trust will be designed and operated. The Department will go beyond incrementally revising the existing eight core trust processes. It will redefine its core processes consistent with the service delivery model shown in Figure 3-7, and then develop new process flows and interactions that will be conducted with (improved) inter- related areas. For example, redefined surface and sub-surface realty business pro- cesses will be combined with new information technologies and tailored training to deliver sigruficantly enhanced services. The remainder of this chapter describes the major components of the To-Be model : + Creating management structures and building blocks + Managing change + Creating the Trust Program Management Center + Designing and implementing the To-Be model. The management structure requirements, change management requirements, and design and implementation support requirements will be inputs to the overall transformation program efforts. 6.3.1 Creating Management Structures and Building BIocks In the planning and early development of the To-Be model, the Department em- phasized and communicated the urgency of change; built a high quality team with the right participants, skills and knowledge; and ensured senior management and tribal involvement. It will be important to establish a solid framework so the teams can operate efficiently and have an appropriate mechanism in place for co- ordinating the To-Be phase with other trust-related initiatives. The activities iilus- trated in Figure 6-3 will begin immediately following the completion of the As-Is phase. 6-4 Comprehensive Trust Management Plan Version 1.0 3/28/03 . .- . .... ". Trust Reengineering . . ..-. - , -- ,.-. ~. . __ Figure 6-3. Getting Started on the "To-Be " hfodt.1 __- . Key findingsfissues from Trust and A s k assessments - Outputs of couii cases . Beneficiary input . 1994 Trusl Reform Act I- Executive sponsors 3 Steenng committee Prolecl director Subprqecl sponsors Team members DO1 Tnbd and IIM representatives Consulting supporl Involving all levels of the organization will help to uncover implementation issues early, as well as minimize resistance 6-5 Comprehensive Trust Management Plan Version 1.0 --- Creating a sense of urgency is critical to the success of any large-scale change effort 6.3.2 Managing Change Many business process reengineering and technology implementation projects fail to achieve their stated goals due to a failure to address the human aspect of organ- izational change. Top performing organizations recognize that change must be comprehensive and integrated, and must focus on the people-related issues asso- ciated with managing the change program, mobilizing leadership, and creating the case for change. 6.3.3 Creating the Tnist Program Management Center Development of the To-Be model wilt be an exciting, yet coniplex undertaking €or the Department. It will require significant coordination, collaboration, and communication among many participants, tribal representatives, process areas, subject matter experts, leaders, and sponsors. Effective project planning and man- agement will be critical to achieve the desired outcomes of this phase. Past organ- izational issues and the decentralized nature of efforts to improve have hindered meaningful, widespread progress. A critical element for managing the complex changes is the Trust Program Man- agement Center, with its associated personnel capabilities and technology tools that can highlight dependencies and linkages among many different initiatives. This office reports to the Deputy Special Trustee for Trust Accountability. 3128103 DO1 Proprietary Information ~ - -_-I-_- __ - ...~. ....,. _ _ _. __ . . - _ - * DO1 strategy . DO1 process expwbse DO1 technology expertise DO1 wganization expertise Faalltatton skills I Project management skills . Change management 8 communication skills * Knowledge of As-Is . To-Be development expenence . Process. people 8 technology analytical skills - Building the right team, with "best and brightest" team members is afso cntical to any largescale change project DOl Proprietary Information 6.3.4 Designing and Implementing the To-Be Model 6.3.4. I TO-BE DEVELOPMENT - . . -., .__-_ .. Designing the To-Be will be the most innovative and creative part of the trans- formation, while implementation may pose some of the greatest challenges. The diagram below illustrates some of the key steps and activities that will be in- volved in the design arid implcmentation process. Figure 6-4. Designing and ImpIernenting the "To-Be " Model Major activities during the development of the To-Be model will include the fot- lowing : + A series of workshop sessions. Facilitated workshop sessions are often the best way to brainstorm solutions and maximixthe diverse knowledge and shlls of participants. Typically, sessions begin with a large group meeting, breaking up into smaller action teams as the session progresses, and end- ing with more large group sessions. During the workshops, strengths, weaknesses, and initial recoinmendations for change will be reviewed, with discussions around the feasibility and effectiveness of the recom- mendations. Alternative and/or additional recommendations also will be developed. The goals of the workshop sessions will include the following: redefinition of core Trust processes consistent with the service delivery 6-6 Comprehensive Trust Management Plan Version 1 .O 3 /2 8/0 3 _-I _.__.I. . DOI Proprietary Information model, at sufficient level of detail to clearly show how business will be conducted; establishment of a high-level trust business process model; and development of high-level performance measures. The results of the work- shop sessions will be recommendations that all agree upon and corre- sponding high-level action plans. + Analysis of improvement initiatives/recom m enda tions. Either during or following the sessions, more-detailed analysis of the recommendations will be necessary. This will involve a much broader audience. The level of analysis required may vary from one recommendation to the next; how- ever, a gap analysis will be conducted for all recommendations to gain an understanding of the magnitude of change necessary for implementation. Also, especially for recommendations requiring larger investments, an analysis of the costs and benefits of the recommendation may be war- ranted. Finally, appropriate consideration will be given to the implementa- Trust Reengineering . . , 3/28/03 tion risks. 4 Prioritization of initiatives. As in any organization undergoing large-scale change, time constraints, funding, resources, and threshold for change will limit the number of initiatives that can be implemented during a fiscal year. It will be important to prioritize the initiatives to ensure that the right initiatives are implemented at the right time. In determining priorities, the Department will want to consider the importance of the initiative, the ex- pected impact of the initiative, the ease of implementation, ihe itnpact iin the Indian trust beneficiaries, and finally, the gap between the current and future state. 4 Clustering of initiatives into work streams. In order to plan the implementation, recommendations will be grouped together into work streams. This simplifies implementation and allows work stream sponsors, managers, and team members to be designated. In order to affect the large change effort, the Trust Policy Management Center has been put into place and together with the Trust Accountability Office will manage and track progress of the work streams, hnding requirements and expenditures, ensure adequate staffing, and communicate work stream activities and success. 4 Development of a Concept of Operations (CONOPS). During the To-Be efforts, a CONOPS will be developed and approved prior to irnplementa- tion planning. The purpose of the CONOPS is to define and discuss at a high level the concepts that will make up the To-Be model. The CONOPS incorporates the Design Criteria, and identifies gaps between the As-Is model and hture goals. In addition, the CONOPS typically details specific initiatives critical to removing process deficiencies and improving existing strengths, such as concepts to improve business processes, speed, produc- tivity, and beneficiary satisfaction. The CONOPS will provide guidance to staff, fiinctional managers, systems administrators, senior management, 6-7 Comprehensive Trust Management Plan Version I .O and tribal representatives t o assist them i n understanding the basis of the To-Be model. + Review of Universal Support Functions. As part o f the To-Be, the univer- sal support functions (risk assessment, automated system requirements, re- cords, internal controlslfiduciary security, policies and procedures, workforce planning, training, and define hture system user technical as- sistance center requirements) will be reviewed to determine the support requirements that will be needed in order to implement the To-Be efforts. 6.3.4.2 DETAILED DESIGN AND TECIINOLOGY INTEGRATION After clustering the change initiatives into work streams and approving the CONOPS, more detailed design activities will take place. This will include development of 4 detailed process maps and diagrams, to include interface requirements; 4 revised or new policies and procedures; 4 revised or new roles and responsibilities; 4 a training plan for new training requirements; and + performance measures for the new processes. The above design activities will facilitate the implementation of a trust manage- ment dashboard, in phases, allowing access to the appropriate performance meas- ures data. Additionally, the data and technology requirements will need to be identified. This will include: + requirements definition and design of any new systems or technologies, + acquisition strategies for new software andlor systems, 4 architecture planning to support the To-Be environment, 4 security requirements, and + system interface requirements. 6.3.4.3 IMPLEMENTATION Implementation of the To-Be model will not be a simple task and will take place over a number of years. Implementation will require multiple efforts and phases, spanning many DO1 organizational entities. Planning for the implementation will begin early, around the time the CONOPS is approved. Before the Detailed 6-8 Comprehensive Trust Management Plan Version I .O 3/28/03 Design and Technology Integration steps above have been completed, an implementation team will be identified and organized. Team members and other involved parties responsible for developing the To-Be model will be part of the implementation team. A project manager will be designated to run the implementation, with many subproject managers responsible for individual work streams. Active and visible participation of the executive sponsors will continue. Dctailed transformation plans also will be developed and communicated prior to the implementation phase. As part of the beginning steps of implementation, i t will be prudent to test the concepts on a small segment of DO1 before beginning a nationwide deployment. Finally, measures will be put into place that will help to monitor the success of implementation. 6-9 Comprehensive Trust Management Plan Version 1 .O 3/28/03 DOI Proprietary InJormaiion Chapter 7 DO1 is committed to hlfilling its trust responsibilities to American Indians and Alaska Natives effectively, efficiently, and with excellent service to beneficiaries. The completed Comprehensive Trust Management Plan encapsulates the results of a detailed analysis and planning effort that not only sets a new strategic direc- tion for trust management, but also provides the critical service delivery and or- ganizational details and implementation activities needed to make it a reality. This analysis and planning is the first step in phase two toward integrated, perform- ance-based, and accountable service delivery. It reflects DOI's commitment to modernization of trust management, as shown in Figure 7- 1. Figure 7-1. Comprehensive Assessment and Plarzning Methodology By examining the entire organization and its service delivery model, DO1 is build- ing the framework for modernization arid initiating a business cul tiire change. While much remains to be done in the long term, this plan is a niajor milestone toward achieving a performance-based, accountable trust rrianagement system be- cause it establishes a strategic framework (Figure 7-2) and strategic direction to guide the design and implementation of tnist reform efforts. 7-1 Comprehensive Tnist Management Plan Version I .O 3/28/63 3/28/03 DOi Proprietary I n formation - I .~ 1 ” . -~ Figure 7-2. Coniprchensl vc’ Trust Munngement Straiegic Framework i i i i i i i I i I i i i i I 1 i 7-2 Comprehensive Trust Management Plan Version 1 .O Conclusion DOI Proprietary In formaiion ~ ~ ” .- ” --I- - ...__ _ _ - __ -. _-.- I - .- - - c 7.1 PROPOSED DATE FOR TERMINATION OF THE OFFICE OF THE SPECIAL TRUSTEE Title 25 USC Sec. 4043(a)(ZXC) provides that the plan shall include the follow- ing: “a timetable for implementing the refomis identified in the plan, including a date for the proposed termination of the Office.” This plan is a dynamic plan which will not be completed until the trust process reengineering project is completed which is expected to occur in approximately 14 months from the date of the plan. Following the completion of the process reengineering, the reengineered processes will take effect and the applicable tech- nology, policies and procedures, guidelines and handbooks will be developed. At that time it may become reasonable to forecast a date for the termination of the Office of the Special Trustee. The plan will be examined at that time for such purpose and a determination made as to whether a date can be reasonably esti- mated. -. - 7-3 Comprehensive Trust Management PIan Version 1 .O 3/28/03 DOi Proprietary Informution The following information is provided as background so that the plan can be placed in the proper context of what is long history of trust reform and moderniza- tion. TRUST MODERNIZATION CHALLENGES Major challenges to trust modernization must be addressed. Many of these chal- lenges will not disappear for years, if at all, but the Department must make plans at least to mitigate them early in the effort. The following subsections describe seven major challenges the Department faces. Challenge 1 : Fractionation Fractionation is the division of an originaI ownership interest into smaller, more fractionated interests when each interest is further divided as a result of inheri- tance. These smaller interests are growing at an exponential rate. The fractionation of the land ownership results in individuals having accounts with extremely low values and high management costs. For example, about 18,000 individual Indian account holders have almost no income and balances of $ 1 or less. The fractionated ownership of the underlying land or natural resource assets-in which hundreds or thousands of individuals each own less than 2 per- cent of the asset-causes the beneficiaries o f these accounts to receive very small amounts of income. Challenge 2: Stakeholders and Complexity SIGNIFICANT NUMBER OF STAKEHOLDEKS Indian trust management has a significantly higher number of stakeholders than private-sector trust management, which increases its complexity. Indian trust management stakeholders include the following: + Tribes % Self-governance tribes + Direct-service tribes > Treaty tribes A-1 Comprehensive Trust Management Plan Version 1.0 4 ~ .I-.., ..-. ~ .. ..-,, ~~~ - + Individual Indians + Congress + States + Counties + Cities + Taxpayers + Custodians 4 I,essees .._ -.- * Account holders F Non-account holders + Individual Indian associations and interest groups + Tribal Indian associations and interest groups + Department of the Treasury + Department of the Interior F Ofice of the Secretary F Office of the Special Tnistee for Amencan Indians (OST) + Bureau of Indian Affairs (BIA) F Minerals Management Service (MMS) * Bureau of Land Management (BLM) F Office of Hearings and Appeals (OHA). COMPLEXITY OF NDlAN TKUST MANAGEMENT Many factors increase the complexity of Indian trust management: + Many federal agencies are invotved directly and or indirectly in asset management, unlike the private sector, which has a single focal point. A-2 Comprehensive Tnist Management Plan Version 1 .O DUI Proprielary Information I .~ ~-.~.~,.. . ... . ..... . _ . . ~ ._-_ ~ I- - ~ --- _I DO1 Proprietary In - formation - _._ . .-- -- + The Indian trust manages thousands of accounts with very small income and mininial balances; the private sector typically handles much larger ac- counts. + The Indian trust has land and natural resources as the primary asset; the majority of private-sector trusts generally manage financial assets. + Regional, nonstandard business processes make integration of information systems and other processes extraordinarily difficult and render infornia- tion sharing and consistency nearly irnpossibie. + Fractionation, an accumulation of cases pending probate, an array ofun- met expectations, and an intricate, complicated business environment hin- der service delivery. + Lack of a trust agrcemetiu'clocrtment. + Perpetual trust without an effective opportunity for a relationship with the next generation of beneficiaries. + Complicated congressional direction from hundreds of statutes. + Unclear relationship between statutory trust and common law require- ments. + Lack of normat parameters associated with cost benefit paradigm. Challenge 3: Misaligned Expectations Regional focus and long-tenn relationships with beneficiaries have Ied to varia- tions in business processes, service delivery, and employee attitudes. As a result, many participants on both sides of the service delivery model have expectations for Indian trust management that, for various reasons, are challenging, diverse, and in some instances unreacfiable. Interpretations of Indian trust management requirements abound, and opinions diverge on a desirable fiiture direction. Due to its complexity, beneficiaries often have difficulty understanding the specifics of trust management, and their expec- tations for service delivery vary-sometimes exceeding the Indian trust mandate or capability. Congress, the courts, and other stakeholders also have conflicting concepts of the responsibilities and operations of trust management. For example, Congress wants a state-of-the-art trust system but is not always willing to h n d such an expansive effort. Others suggest that a commercial entity could manage DO1 Indian trust assets, yet no commercial trust entity has been identified that would be willing to manage thousands of accounts that maintain less than a dollar. Buckground _ - . 3/28/03 . . -_- ". A-3 Cornprehensitre Trust Management Plan Version 1 .O . , - .- -. . . .- .- -_. __.. .^. - . , . . ~ - . ...,. ... .^._.-.-.-__.II.. -.- _I __ , .... _ _ -..,.., ., .-~., Challenge 6: Resources . .- ~~ Challenge 4: Distributed Management In the 18OOs, the management of Indian trust assets began with frontier represen- tatives and has since been characterized by regional independence and manage- ment. This distributed management structure has major drawbacks in today's environment. DO1 is required to deliver equitabfe service for all customers na- tionwide and to manage and account for assets, revenues, investment, and dis- bursements. Variations in regional management and the processes- -including outdated, paper-driven methods- thwart these expectations and pose challenges to tnodemization efforts. Challenge 5: Organizational Alignment The current trust management structure mixes roles and responsibilities among individual organizational elements. The &cure organization must realign to im- plement a new service delivery model. Specifically, BIA and OS'I' must have clear roles as to trust responsibilities so responsible parties can be held account- able. Private-sector trusts generate the h n d s to pay for the cost o f their management. The s o w t h of such private-sector trusts depends on how well the trust is man- aged. Many of the individual trusts under the Indian trust marlagenlent umbrella cost much more to manage than they generate in revenue. Congress provides DO1 with the money for trust management, and the beneficiaries receive all the reve- nue earned, regardless of the cost of management. Therefore, unlike a typical pri- vate-sector trust, several other factors influence resource allocation, including other national priorities and requirements. Management effectiveness is directly tied to the funding received through the congressional budget process. DO1 must manage these funds efficiently, but must also accurately portray reqfiirements and potential consequences when hnding needs cannot be met. Challenge 7: Organizational Cuiture Although new processes, systems, and organization can improve many aspects of trust management, the DO1 organizational culture must also change. After the new service delivery model, products, and services are clearly defined, DO1 has to embrace the need for effective service and necessary changes. Every employee needs to understand the importance and unique aspects of comprehensive trust management, and management should use a performance-based, accountable ap- proach to ensure that employees meet their responsibilities. Dot Proprietary fnformntion A 4 Comprehensive Trust Management Plan Version 1 .O 3/28/03 FUTURE ENVIRONMENT Two principles are key to comprehensive modernization plans-performance and accountability: + Performance. Organization, business processes, infonnation systems, and special actions influence performance and must change during the transi- tion to a perfonnance-based operation. Measuring the performance of these elements in the service delivery model will indicate progress toward improvement. Likewise, perfomlance metrics will reveal elements that limit performance. 4 Accountability. DO1 is committed to modernizing trust management. AIf entities influencing performance must be accountable for their effect on service delivery, the beneficiaries, and other major stakeholders. DO1 must continue clearly to define trust managers' roles and responsibilities in fiduciary trust management and then aggressively develop the processes, systems, people, and business culture needed to fulfill them. The Department must align the service delivery model with stakeholders' expectations and establish clear per- formance measures for all operational aspects. Using these performance meas- ures, DO1 can track progress and performance and assess stakeholders' support of the transition to the new business environment. A-5 Comprehensive Trust Management Plan Version 1 .O 3/28/03 DOi Proprietury Information Appendix B Business Trends -#sw DO1 analyzed the business environment defined in Chapter 3 to help identify some of the business trends as they relate to various stakeholders. In most cases, the stakeholders shape these trends. For example, increased dissatisfaction with trust services-on the part of Individual Indians, tribes, and Congress-is a well- documented trend. External forces shape other trends, such as fractionation, a function of generational succession over time, and the standardization of processes and modernization of systems, the result of work process changes and technological progress in the national and global economies. The trends most affecting DO1 trust management are as follows: + Continued dissatisfaction with services + Continued fractionation + Standardization of processes and modernization of systems + Increased beneficiary focus + Increasing self-governance and self-determination. SUMMARY OF TRENDS Continued Dissatisfaction with Services Individual Indians, tribes, and Congress have for some time expressed dissatisfac- tion with the trust management services provided by DOI. This dissatisfaction has led to increased interest in Indian affairs by all parties, which in turn has resulted in greater oversight, litigation, and DO1 reform efforts. Continued Fractionation Fractionation is the division of an original allotment ownership interest into smaller more fractionated interests as each interest is further divided as a result of inheritance. These smaller interests are growing at an exponential rate. As this process repeated itself, sheer numbers excessively complicated the existing man- ual and automated processes of tracking, paying, and auditing these accounts. B- 1 Comprehensive Trust Management Plan Version 1 .O 3/28/03 ~ . ,.. . . . . - , . . ~ .__ ,. Increased Beneficiary Services Congress Custodians Department of Lessees Secretary ... . ~ . . _. DO1 - ,_.-. Proprietary Information ._^_ _.___ ...__ ‘Transition fiom Autonomous Processes to Standardized Processes and Modernization of Systems Over the history of DO1 tnlst management, local and regional locations have autonomously developed processes and systems. To increase efficiency and effec- tiveness, DOE is standardizing processes and modernizing systems to meet ac- counting, customer, and operational requirements. In today’s business environment, the overarching business trend is a paradigm shift from managing Indian trust accounts to providing trustee services and repre- sentation for individual Indians and Indian tribes. Increasing Self-Determination and Self-Governance DO1 has promoted and supported self-determination and self-governance to en- able tribes to manage their lands, natural resoiirces located on their reservations, and trust funds. This has resulted in a large number of tribes engaged in managing their own trust asscts. BUSTNESS TRENDS AND STAKEHOLDERS For each core stakeholder in the business environment model, DO1 identified as- sociated business trends that need to be considered and addressed within the com- prehensive trust nianagement plan (Fable B-I). -. Tahle B- I . Birsiness Trends by Stakehoiders .~-_____I I I beneficiaries Beneficiary tribes Individual Stakeholders - _- ~______~~_____ and trust asset beneficiary tinued Increased increased delivery activities. interest dissatisfaction fractionation; self-sufficiency tribes of owners. Adoption trustee and with individuals. fncreased services. exponentially of and services. self-sufficiency Business self-determination beneficiary ___- Conflict trend increasing and of expectations interest self-governance. numbers in management - between of in individual quality the Con- of t Increased interest in management of Indian trust activities. Increased use of custodians. Increased involvement. -___ ~- increased frustration in finalizing lease agreements. Increased emphasis and involvement of DO1 bureaus and offices to fulfill fiduciary obligations. Transition toward beneficiary-focused and business-oriented operations. __.~_ _I B-2 Comprehensive Trust Management Plan Version 1 .O 3/28/03 - Rusinesr Trends Office of the Solicitor BIA MMS BLM OST Table R- 1. flusirless l'rrnds by Sfakehotders (Continued) Stakeholders Business trend ~~ ~~ Increased expectation of responsiveness, involvement, and fiduciary trust expertise. Separation of fiduciary trust asset management functions from other bureau services Increased focus on improving beneficiary services Transition toward beneficiary-focused and business-oriented opera- tions Federal government agencies operating more like commercial businesses when applicable. __ Continued involvement in Indian affairs Indian affairs activities remain a small part of operations. Continued involvement in Indian affairs. Indian affairs remain a small portion of operations. Forecasted increase in survey and mineral ap- praisal workload. Increased reliance on advanced IT systems in management of ac- counting functions, customer relations, and operations. Increased fo- cus on improving beneficiary services and satisfaction. Federal government trend toward privatization to take advantage of commer- cial-sector expertise in specified areas (such as trust management). Federal government agencies operating more like commercial busi- nesses when applicable. Transition toward beneficiary-focused and business-oriented operalions. Increased oversight capabilities and trust operations. Increased probate workload. Uneven workload. Continued involvement in regulating coal mining and reclamation op- erations on Indian lands under the Indian Land Program Regulations. Continued review and comment on trust land acquisition. ~~ Increased publicity by interest groups on their views of Indian trust management activities. increased public relations efforts by DO1 with associations, interest groups, and lobbyists to foster improved corn wuncation among DOI, the beneficiaries, and other interested parties. OHA OSM State Counties Cities TaxDavers individual and tribal Indian associations and interest clroups 3/28/03 - -, . I_ DOI Yroprietury Information ~ ~~ .___ ~ _ _ R-3 Comprehensive Trust Management Plan Version 1.0 DO/ Proprietary information Appendix C Requirements Appendix C categorizes the examples of statutory and regulatory requirements of Table 3-2 in Chapter 3. These requirements, that may contain provisions affect- ing trust management, are categorized according to the business line and hnction within that business line they may impact. Some requirements apply to more than one business line or function and thus niay be listed multiple times. BUSTNESS Lrm I : BENEFICIARY TRUST REPRESENTATION Statements of Trust Accounts + Federal Oil and Gas Royalty Management Act of I982 + BIAIOST interagency handbook 4 American Indian Trust Fund Management Reform Act of 1994. BLJSINESS LINE 2: TRUST FTNANCIAL MANAGEMENT Accounting + The Chief Financial Officers Act of 1990, Public Law 101-576, 31 U.S.C. 90 1, et. seq., as amended + Statement of Federal Financial Accounting Standards Number 7- Accounting for Revenue and Other Financing Sources Interpretation of Federal Financial Accounting Standards, Interpre- tation 1 ---Reporting on lndian Trust Funds + Sections applicable to Indian Trust of the Unifomi Principal and Income Act (for example, trcatrnent of capital gains) + Federal Oil and Gas Royalty Management Act of 1982 + Generally accepted accounting principles applicable to Indian Trust (FASB, AICPA, GASB, etc.) + BIAIOST Interagency Handbook. C- 1 Coniprehensive Trust Management Plan Version I .O AUDITING INVESTMENTS RECORDS Business Line 3: Stewardship of Land and Natural Resources 3/28/03 + Generally accepted government auditing standards (GASGAGAS)- ”Yellow Book” + The Federal Managers’ Financial Integrity Act of 1982, P.L. Y7-255,3 1 U.S.C. 1352 + The Federal Financial Management Improvement Act of 1996 + Office of Management and Budget Circulars: A-50, “Audit Follow-up IG/G A S” . + DO1 Departmental Manual 303--PrincipJes for Managing Indian Trust Assets. + OST investment policy + Prudent man rule subject to limitations under 25 U.S.C. 162 (a). + Federal Records Act of I950 + Departmental Manuals * Chapter 1, Part 380, DM ]-Records Management Program and Re- sporisi bil ities * Chapter 1, Part 384, DM 1-Records Disposition * Chapter 6, Part 380, DM &Vital Records * 486-Vital Records + National Archives and Records Administration (NARA) in 36 C.F.R. and 44 U.S.C. + Universal Standards of Professional Appraisal Practices + Appraisal Handbook C-2 Comprehensive Trust Management Plan Version 1 .O SUKVEYS, LEASES, I’RESERVATIONS, OWNEKSHIP, AND AUDIT + Title 25 of the United States Code and applicable regulations for land use and leasing + Federal Oil and Gas Royalty Management Act of 1982 + DO1 Departmental Manual 303-Principles for Managing Indian Tnist Assets. All Business Lines AUTOMATED SYSTEMS + Statement of Auditing Standards 70 review related to trust hnd account- ing system + Office of Management and Budget Circular: A-127, “Financial Manage- ment Systems,” July23, 1993 + Computer Fraud and Abuse Act of 1986, Public Law 99-474, 18 U.S.C. 1030 + Computer Security Act of 1987, Public Law 100-235,40 U.S.C. 759 + National Institute of Standards and Technology WET) Special Publica- tions * SPEC PUB 800-12-Introduction to Computer Security: The NET Handbook. October 1995 % SPEC PUB 800-14--Generally Accepted Principles and Practices for Securing Information Technoloby Systems, June 1996 * SPEC PUB 800- 1 8-Guide for Developing Security Plans for Infor- mation Technology Systems, December 1995 * SPEC PUB 800-26, Security Self-Assessment Guide for Information Technology Systems, November 2001 F SPEC PUB 800-30, Risk Assessment Guide for Information Technol- ogy Systems, January 2002 P SPEC PUB 800-34, Contingency Planning Guide for Information Technology Systems, June 2002 > SPEC PUB 800-47, Security Guide for Interconnecting Information Technology Systems, September 2002 3/28/03 C-3 Comprehensive Trust Management Plan Version 1 .O + Computer C t h e Act of I984 + Computer Matching and Privacy Protection Act of 1986, P.L. 10 I-56 + DO1 Departmental Manual 376-Chapter 19 Information Technology Se- curity Program, April 15,2002 (New) + DO1 Information Technology Security Plan (ITSP), Version 2.0, April 15, 2002 (New) + DO1 Information Technology Security Reference Handbook, September 200 1 + Electronic Communications Privacy Act of 1986, PI, 99-508 + FIBPS PUB 102, Guideline for Computer Security Certification and Ac- creditation, September 1983 4 FIBPS PUB 3 1 ~ Guidelines for Automated Data Processing Physical Secu- rity and Risk blanagcment, June 1974 + FIBPS PUB 73, Guidelines for Security of Computer Applications, June 1980 4 Information Technology Management Reform Act of 1996 (Clinger- Cohen Act), Division E of Public Law 104-106,40 U.S.C. 1401 + Paperwork Reduction Act of 1978, as amended, PL 103-13, 109 Stat 163, 44 U.S.C. Ch 35. INTERN A L CONTROLS ~FID~JCLARY SECURITY + Office of Management and Budget Circulars * A- 123, “Management, Accountability and Control” * A-130, “Management of Federal Infomation Resources”, February 8, 1996 + Computer Security Act of 1987, Public Law 100-235,40 U.S.C. 759 + Government Information Security Reform Act (GISRA), Title X, P.L. 106-398 + National Institute of Standards and ‘Technology (NIST) Special Publica- tions + SPEC PlJB 800-12--Introduction to Computer Security: The NIST EIandbook, October I995 C-4 Comprehensive Trust Managemcnt Plan Version 1 .0 3/28/03 * SPEC PUB 800-14-Generally Acceptcd Principles and Practices for Securing Information Technology Systems, June 1996 * SPEC PUB 800- I %-Guide for Developing Security Plans for Infor- mation Technology Systems, December 1998 + Departmental Manuals % 375, DM 19, Part 19-Information Teciinology Security Program % 4Il-Pcrsonnel Suitability and Security Requirements, Chapter 1-6 * 444-Physical Security and Building Security, Chapter 1 + DO1 System Security Plan (GSS) Guide and Template, May 3 I , 2002 + DO1 System Security Plan (MA) Guide and Template, May 3 1,2002 + Freedom of Information Act, 5 U.S.C. 552 + Privacy Act of 1971, P.L. 93-579,5 U.S.C. 552a (1974) + National Security Act, as amended, P.L. 102-485 RISK ASSESSMENT + Office of Management and Budget Circular, "A-123, Management, Ac- countability and Control" + National Institute of Standards and Technology (NIST) Special Publica- tions + SPEC PUB 800-12-An Introduction to Computer Security: The NIST Handbook, October 1995 F SPEC PUB 800-14-Generally Accepted Principles and Practices for Securing Information Technology Systems, June 1996 + SPEC PUB 800-184uide for Developing Security Plans for Infor- mation Technology Systems, December i 998 + Departmentaf Manuais + 375-Information Technology Security Program * 44 I-Personnel Suitability and Security Requirements, Chapter 1-6 + 44il---Physical Security and Building Security, Chapter 1 3/28/03 C-5 Comprehensive Trust Management Plan Version 1.0 ~ ~ _ ” _ -_.I-I-_ -. . . I _ ” . .-----_ .-_-- _- BUDGET PERFORMANCE - _ + DO1 h s k Assessment Guideline, April 23, 2002 4 DO1 Contingency Planning Guideline, Apnl 22, 2002. + Office of Management and Budget Circulars A- I 1 , “Preparing, Subniit- ting, and Executing the Budget,” June 22,2002. + Government Performarice and Results Act (GPRA) of 1993, P.L. 103-62, 107Stat.,SU.S.C.Section306,31 U.S.C. 1105, 1115-1119,3515,9703- 9704. DOI Proprietary Information C-6 Comprehensive Trust Management Plan Version I .O 3/28/03 Appendix D xww? Trust Management Roles and Responsibilities DO1 Proprietary In formation .>% Y w " * ' ; . ~ ~ , . 13-1 Comprehensive Trust Management Plan Version I .O ,\idy_-L %%S@-Wr >Q% * "- :%? Trw: Mnnugemeni Roles and Responsibilities ... .- . rrust Review and Abdit :hid Information Oflcer 3\28/03 . . , . __-.~._.._....__.-...I._. ___I__,.._. the .-.-..._,.I. stakeholders Role Executes (rust management role and foeuses outside OST organization that includes the Secretary 01 the Interior BIA directors. tribal task lwces and other and Information Officer of OST Manaaes OST internal owration re~resonts Soecial Works directly wilh and reports to the Special Trustee, analyzes repons and production data for accuracy, manages contractors performing independenl audits Provides the mformalion technology infraStrUCtw? maintenance help desk activities software and hardware for OST trust activities. establisnes. updales and maintains OeneRciaw . . . . , record% . . . . - -. on . in . - $1 -. fkmnc . -. . __ Tublr D-I. Rolei und Re,ponsihililit.s-O//ice ofthe S p d u l Trus:ee,/iv Americun lndhnh I 1 ~ I I 1 i I j 1 , I 4 + Provide OVeiall indexing and location of records. including Responslblllty + Inform Ihe Secretarj of the interior of all developments postlive and negative and bow tha function is operating + Coordinate with BIA 10 provide or influence products and services on issues j + Keep Speclai Trbstee updaled on all duties in OST aroups in CTM + Monitor Ihe external environment for perceived or real discontent with the trust operations + Communicate with ail DOi oflices on issues and status of , A 3.- ,, . nCT -_--- functions performed by DO1 + Review and repoa on all aspects of CTM acliyims 4 Monitor and report on corrective actions Manage external audit + provide os7 tmsl management systems support + Coordinate with BIA and olher agencies on selection of all so'lware applications for use in 'rust management + Coordinate and tnlegrate database information exchange with BIA and other 001 agencies coilecling data ard information for lrusI management Coordinate with indian IrUSt programs lo derermine adequate and proper documentalion for Irusl entnes t Complele and impiemenl record retention schedules lor Koy roles ion wilh day.to.day operational j i -. . . .. to and + Ac: unavinlabie in piace of the Special Trustee when Special Trustee is + delivecy Report to of the products Special Trustee SeN!ces an issues beneficiaries or problems thal encumber the + Coordinale with outside contractors 10 assess ail CTM r Perform an annual tiscal year audit cf aJ funds held In trusl by Lha h i l e d Slates lor the benefil of individual Indians (25 U S C 401 l(c)) + Deielop a performance ranking system based or a review process for ai, offices performing [rust activities + Evaluate tribally managed trust programs (compactedicanlracled) + Ensure CTM policies regulalions and procedures are lollorYed by all 6 Pedorm oversight of all groups involved in CTM Supply and maintain hardware and software appl calions laking aavamase of information lecnnology advances for OST Provide inlormalion lechnology suppon to the support an0 operations sla'l Develop life-cycle requnemenls for saltware and hardware Work with olher agencies to establish information Iecrnology security measures Retrieve and retain aii in(ormation that Is necessary to rencer an accurate eccounling of all money In the IlM IruSI (December 1999 order) Provide adequale controls over receipts and disbursemerls in OST (25 U S C 162a(3)(2)) Coordinate Department agencies lnpul to all bereliciar/ recams cancernirg trust assets Work with olher agencies lo set polcy for records managemem a i d storag, oflrurt asset$ in DO1 4 all Work Monilor with other information egencles technoiogv to wtablish advancements electronic record-keeping in records manacemeni stindards 1 that comply with federal government standards Comprehensive Trust Management Plaii Vcrsion I .O OST re~earch for OST + Determine records storage requiremen!$ + Communlcale !rusl.speclfic funclions to 001 information technology personnel responsible tar selectinglusing soltware applications for trust management purposes + Provide oversight and evaluation of DO1 Lrusl compuler system archilecfure planning, development, implementation, and operations D-3 , DOI Proprictrrrv rind Crmfidmtial . .. . , . ., . ._l-_*" . .. ... , .. . _--.,,_. . .I . ~ . . - - ._ ~ -- ---I - imeliness of all report3 and mfcrmat or provided to . . Trust Managemml Roles and Responsibilirirs Offlcslindividual 1$ RCCliCId - - -_- - - k w t v Sneclal Trustee iegional Trust 4drninistrators Trust Officers 3\28/03 ~ . . . . . .. . ., .. . .. .- -- ..-- . . .-, . ._ ...,- -"I1 nay roll). i t Manage centralizcd trust beneficiary call center Manage all held staff of lrlr5t officers 1 + Provide lecnnical arflstance on trust matters to OSTilrlbes 4 Coordinate wilh Office ol Regional Dlrector for Trust Services + Act a8 primary conlacl l o and for trust beneficiaries regarding lhelr trusl aseels + Work cooperatively with DO1 staff and beneficiaries on Lduclary trust matters + Review and approve fiductary trust assel management deClSiGnS and transactions tnat meet high-risk criteria + Serve as local collections once for all Lrust funds encoding transactions monitoring accounls receivables and providln8 + Ac! a3 pnmary co7tacI for the appropriate creation storage technical assislance on trust malters and disposition of crust records Tublr 0-1. Rolci ond Ru.vpon..ibi/itics-O//ic e q f f h r Speci~rl Triufre Joi. Americnn lndiuns (Conrinirrrl) I 1 1 Manages interiaces with beneficiaries stays on the leading edge of the OST organiraoon I -__ Provides firsl-line supervision of trust officers provides 1 + Act a s rlrsl.llne technical CTM assistance with the BIA regional airectors Provides interaction with the trLst benaflciaries 1 1 0-5 Responsibllity + Manage and direct all trust adminislrators and trust officers + Ensure trust ollcffrs are trained and possess the Skills requ red to proilL'e * Set up and manage beneficiary call center. establish and enforce dedicated CTM serwce to beneficiaries perfomlance measures, and train call takers as fcrst-line cuslomer conlacls 1 4 Proiide adequate staffing sccounting (25 U S C 162a(d)(7)) + Ensure trust ofiicers are Iralned and cornpeten1 to deliver first-rate sewce to trusl beneficiaries + Provide technical and funcbona! assistance to lrusl officers as needed t Enuurs tru%t oficers have the tools and means to provide effective deiive of preducts and setvices to beneflclarles + Provide service and lofally to trust accounts within responsibility + Establish. lmpiement and maintain Controls over lrus1 cash assets + Provide constanl coordinallon with agency superlntendenis on CTM issbes + Workwith OOI staff to improve business operations + Ensure proper documentalion for trust transactions + Cosign aclions of the superintendenl above a Oetermined threshold of land and nelural resource management + Coordlnate and secure local collections + Work wilh 001 to ensure that fiduclaiy 1rUSt policies procedu-es and training are followed and made avallable to agency staff as necessary + Ensure thal appropriate documentation of all fduciar) lrust transacttons and Internal controts are In place and followed + Record updated and accurate managemen! files lor tracking a n l reporting on beneficiary accounts . . . . . .. . . . . ~ -. . .. . DO1 Prupriercicy rind Confidcnlitrl . and sqervision hi trust fund managemaw ana I I - Comprehensive Tritst .VClaiingernetit Plan Version I 0 i-a . . . . . . . . . . . . . . . . . . . Provides beneficiary tru9t recards and trust hnd management investment SBNIC~S collec1s, reCOidS and disburses beneficiary trust assets 1 , ' Provides internal anc external reporting and reconciliatior j Role T r u i Manugrmenr Roles and Rrsponsibilifier Offlce/lndlvldual Deputy Specla/ Trustee for Trust ServIces I Otfw Of Trust Funds Maragement I I I _I --.-.. _.1 Office 01 Reporling and Reconciliation 312 8/03 I -i ....... " -. Tublr D-I Role, und Respunrit)ilriirs-Oj/icc o/ ihr Sprcrul Twsrcr /or Amrricrin lndiuns (Coniinrreri) I ...."" 1 I 1 j I I , I I . l n r i h"" 4 Provide accounling data-enlly oualilf assurance Make furd disbursements PrOVlde reCOnCllia~lOn bene,lClarY Bccoun,s tor trust asset management accuracy 1 4 Pvovide reports to DO1 lrusl administrators trust officers beneficiaries and federal ofices on wdcvioual and trlbal trust accsurts 0-9 + Ensure accounting funclion for CTM is accurate. current and includes a complete record of beneficiary trusl aclivities 4 Maintain aelive management of all inveslment aclions wilhtn the j ' 1 3 ' gains and losses j 1 I . . . . Manage Oflice of Trust Funds Management Manage investmenl services Reconcile and report on trust fund act1on5 cenlrallzed accounting SeNICeS Make collections . Accounts receivable Kby roles I j I . . . . . . . . . .- -, .......I ........ _ _ DO! Proprie:ut:v ( i n d Coti/;dcn/io! Responslbllity I + Reconcile and remrl an (rust hnd actions 4 Provide plaintiff3 an accurale accounting of all money 11 Ihe IIM Irusl beta for Ihe benefit ol plaintiffs withoul regard to when the funds were deposited (December 1999 order, 25 U S C 401 l(a)) + Account for dairy and annual balance of all funds held in trust by the Un led States for the benefit of individual Indians (25 U S C 40*1(a)) 4 Determine accurate cash balances (25 U S C 162a(d)(J)) 4 Provide and maintaln all accounting service for beneficiaries Proviae direct coordinalion and interface wilh t h e cuslodian for inbestment 1 lrust 4 of Provide assets periodic statemenl of performance al Ihe en6 of ever( calefldar 1 quarter to each IIM account holder thal identifies . source begtnning type balance and stalus of funds . receipts and disbursements ' * Provide periodic. llmely reconciliation to ensure accwacj of aCcwrts ending balance (25 U S C 401 l(b)) I I i J (25 U S C 1628(d)(3)) + Prepare and supp~y account holders wllh periodic statements of their account performance and balances (25 U 5 C 162a(a!(5)) 4 Provide up-to-date financcal reports to beneficiarles and federal offlces Comprehensive Trust Management Plan Version I .O . . .. . _. - . Trusi Munugemen, Role5 und Rerponribilitirs Assistanl Secretary - Offlcelindlvldual Indian Anairs -- Primary Official charged wilh the responsibility 10 administer federal Indian pol~cy and to fulflll the federal lrusl rasponsibility for American lncian lribes. Alaska natwes and tnbal organizabons Manages trust informallon resources and informatfon technology Maiage Indian Land Consolidallon ProJecl Provides dlreciion lo regional offices agencies and fie12 offices Manages headquarlers activities associaled wilh the management and protection of trust and reslricled lands, and natural resources Provides central office management for aeveloprnent and protection of trust natural rasources ProvMes cenlral office management for the protection, managemenl, utillzallon and probate of trust and reslricled federal lndiakowned lands Oapuly Aaslstant Secretary for lnfonnatlon Resource ManagementlChlof Information Officer l------ Director, Indian Land 1 Conso!idalion Cenler ' Deputy Director - Field Operalions Seroces Resources Real Estate 3/28/03 _.." - ___ , , I ! , + + protection Provide Skengthens policy of Ihe trust guidance govemmenl-lo-gover~me~t resources for BIA s managemenl and relatlOlshlP + Advocales policies thal supPoR lndiar Sell-Determination + Maintains relationship wilh Special Trustee for Amewan I 1 I I i I I ~ I [ 1 field assistance Provide ofices specialized to field onices and programmatic and tribes lechnical i ' DO1 Propri ciur y unrl Con/iilenii:ii ~ ,.. ". . . . . .... . .,.,. .... ... " . . . . , . . . . . . . .. . . Responribillty + Ensure management and prolecllon of Irusi resources IS withon scope of acceplable conprehenslve trust management practices + Maximizes Ihs effeC*lL'enesS of program operat on5 of the BureaJ 0' lrdiar wllh Indian tribes Indians i + I + Eslablish. develop. operate. and maintain information + Primary depanmental confact for the developmenl and rewew of policy proposals and for inierpreOng estaolished polic~es related to trust issues Conducts appropriale consullation with Indian tribes, other bureaus, the Oflice Of the Secretary. the Solicitor, h e Office of Managemenl and Budget. olher governmental a encies. Congress, and the public Supply. maintain. revlew. and?nonilor Information technology for IiM,- taking advantage of IT advance!, Establish wrilten pOIICiBS and procedures for IT architecture necessary tr render an accurate accounting of Ihe IIM trust Supply and mainlain hardware and software applications Laktng resource management and informalion IechnoIQgy (IT) policy planning, architecture. configuralion management, engineering. security, privacy, project management. + !n!egrale the lrusl iT architecture wilh lhe 001 anc federal development. and operations of trust systems ilrchitecUre I advantage of IT advances Provide IT SUDPO~I + Work wilh Other agencies lo eslabllsh IT security measures lo the supoon and operatlong sian + Retrieve and retam all information thal is necessaw lo render an accuraie I + Shires resPQOS biiity for the management 01 tribal and individual Indian trust funds with the Speclal Trustee for American Indians + Eslablsh land conaolidatron policies + Develops tribal and implements cooperawe agreements + Provides national oversight direction rnonllorirg ard program eraluation I of the Indian land conso idallon projecl I . ,-- contractors and BIA project skaff + Monilor and evaluate the performance ot the regional and ' and field offices 1 + Oversight for Attorney Decision Makers, for Ihe adjudlcalion of probates of lndlan trusl estates I 1 I Provldes nallonal d,rection for the dally operations of the regtonal. aGency , + National primary lachnical, managemeni, and monitoring experiise-fG-. - ~ Indian trust nalural resources programs I + Cevelopmenl and prolection of trusl natural resources + Technical and Policy advice for aclivities relaled l o soil. baler. rangeland, fish. and wildlife programs + Provides assislance, advice, policy, oversighl, monitoring and coordinalior + Provides nabonaf oversighl and aireciion for Ihe administratian and maintenance of title documentation for trusl and reslncted federal Indian-owed lands -I for lhe protection, management. consewatton. developmeni of trust and reStricled federal Indian-owned lands. which InCIUdeS acgbirilion,, disposal. Ienure. right-of-way. permits, leasing and Bales D-I I Comprehensive Trust Mandgemcnt Plan Version 1 .O i Division of Forestry Offlcellndlvidusl Provides management related to developmenl and protection of trusi forest resource3 l Social Worker Regional Division of Natural Resources Regiondl Division of Real Estate I Agency Superintendenti Deputy Supenntendent Agency - Trusl Role Delermines whether an individual account 55ould be plamd in restncledtsupew!sov status Regional Director - Trust resources programs and Indian sewces programs l trusl lands Provides regtonal management for development and protection of trusl natural resources forestry and energ, and mineral resources Provides regional rnanagemenl for Ihe prolection managemenl utilization and probale of twst and reStriciec federal lndlanawnea lands 1 1 resources Manage day.lo4ay programs operations of land and natural Manage day-to-day operations of land and ralural resources proIjrams Ensures !he Irust and restricted federaLowned lanos are administered and mainlalned in accordance wlth regulations and pohcies I I 1 + Provides oversqhl .. and guidance to the agencylfield office level for management and protectton of Ihe land and natural resources Droarams ' 1 I I I ~ 1 + Provldes for the coordination planning. management i management oifice , t reslricled Zovides central federal Indian-awned lands for the protect on management uciiization and probate of trust and I 5ervtr.c Agency Division of Natural Resources Agency Dlvlsion of Real Eslate 3/28/03 Exercises program oversighl of natlonal forestry activities lo ensure that regulatory and policy requirements are followed and fhat sound forest hmds 1 I ~ I KDY role to determlre dbiiitY 10 manage activllies with olner governmenial aaencles private and lnbal groups + Regional poinl of conlact &th OST + Provldes lBCh17iCal oversight and assistawe to Agencf and fieid OMce ievel planning. caordinatlon, guidance and assisfance for sound trust natural tesource management and protection Provides regional overstght and direction for (he adminlstrallon and maintenance 01 till0 documentetfon for pWlecOOn and utilizallon of trust and . rmtrirl*T( _ _ - - - Provl&s federal Indlan-owned P r i m a r y s i Q h l lands for the administration and I I + Agency part at contact With OST Trust Officers maintenance agencylfield oflice trust program a encytfield office level D.13 Coordinales vie planning, management and protection of (rust foresi resources ircluding Ihe natlonal woldland fire program I I I + Makes delerminalioo to place an account in reslrlcledisupervlsory staius a w 1 I I I Ensure land and ralural resources are m d n a g e d ~ z i J p e ~ e ~ comprebenstva trlrst management practices Rerponalblllty acceplable comprenenslve trust management prac'ices 4 Ensure h e adminisirallon and Indian-owned lands withln the + Prov,das for (he admintstration of Ine BctIvIIies for Ihe prolec:ion. management. conservatlon and develOpmePt of trust and restrlcred federal- owned land, Including a;quiSilIOn dlsposal lenure. r gh! of way permit3 I Ensure land and natural resources are managed wtfhin stope tit acceptable 1 comprehenslve (rust management praclices Ensure land and natural resources are manageir wlthin stope of acceptable ' Comprehensive Trust Manogcmcnt Plan Vccrion ! .O Appendix E AICPA BLM C.F.R. SIA BRM CONOPS CTM DAST DO1 EDS FASB FiPS GAO GASGAGAS GASH cJrsw GPRA GSS HLIP IG IIM rT ITSP MA MMS NARA NIST OHA 3/28/03 DO1 Proprietary In formation Ofice of Hearings and Appeals - American Institute o f Certified Public Accountants Bureau of Indian Affairs Bureau of Land Management beneficiary relationship management Code of Federal Regulations concept of operations Comprehensive Trust Management Deputy Agency Supenntendent for Trust Department of the Interior Electronic Data Systems Federal Accounting Standard Board Federal Information Processing Standard Government Accounting Office generally accepted government auditing standards Governmental Accounting Standard Board Govenment Information Security Reform Act Government Performance and Results Act General Support System Nigh Level Implementation Plan Inspector General Individual Indian Monies information technology Information Teclmology Security Plan major application Minerals Management Semicc National Archives and Records Administration National Institute of Standards and Technology E- I Comprehensive Trust Management Plan Version I .O OHTA OITf OMB OSM OST OTFM SPEC PUB TPMC U.S.C. 312 8/03 Office of Historical Trust Accot~nting Office of Indian Trust Transition Office of Management and Budget Office of Surface Mining Office of the Special Trustee for American Indians Office of Trust Fund Management special publications Trust Program Management Center United States Code E-2 Comprehensive Trust Management Plan Version 1 .O