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TUESDAY, NOVEMBER 13, 2001

The following are 13 recommendations EDS Corporation submitted to the Department of Interior on October 30, 2001.

1. Immediately Appoint a Single, Accountable, Trust Reform Sponsor.
As reported last week, Secretary Gale Norton has been urged to appoint a receiver ("Norton told to appoint trust fund receiver") for the trust fund, which could prevent a federal court from doing so. "The Trust Reform sub-projects and breach efforts need to be directed by a single, Executive Sponsor. The emphasis of this recommendation is on aligning responsibility with line authority," writes EDS.

2. Adopt an overall business and computer systems architecture.
The Interior has been criticized by a court monitor for not having an adequate, high-level design of its computer systems, leading to misleading progress reports given to a federal judge.

3. Integrate the TAAMS and BIA Data Cleanup sub-projects.
Likewise, the efforts on a $40 million software system have largely failed, said monitor Joseph S. Kieffer III in two reports. "TAAMS objectives cannot be fully achieved until complete . . . information is available," writes EDS." Likewise, the quality of that information will continue to degrade until" recommendation 2 is implemented.

4. Develop an overarching Trust Operations Business Model.
"The Business Model . . . must also comply with treaty statutes and case law," writes EDS.

5. Adopt a consistent Information Systems Acquisitions Strategy.
In the summer of 1999, the government told a federal judge that TAAMS could be developed within a short time frame because it was based on an off-the-shelf software product. But the Interior quickly found out otherwise, which has resulted in numerous delays. EDS recommends the government develop a strategy to avoid similar problems in the future.

6. Immediately assess the nature and magnitude of the BIA Data Cleanup Issue.
As noted by Kieffer, the government kept data cleanup in a state of disarray ("Norton hit on trust fund progress"), which has hampered TAAMS. "The DOI needs to move immediately to conduct a statistically valid assessment of the nature of the BIA data integrity issues," writes EDS.

7. Integrate the TAAMS Title and BIA Data Cleanup implementation plans.
According to senior Interior officials, the BIA and the software company creating TAAMS have continued to modify the system without assurances the data which it will use is stable. During a software test this past summer, the problem became more apparent ("Latest trust fund system a 'failure'"). "It shook their confidence," said one official of the test.

8. Implement consistent technology frameworks, methods and tools.
BIA regional offices often have their own ways of carrying out trust duties. EDS recommends the Interior develop a way to support a department-wide solution.

9. Establish required computing and communications capabilities.
EDS criticizes the Interior for not knowing if its computer network can handle the tribal and individual trusts. EDS recommends the Interior test "levels of network capacity" and fix any problems.

10. Immediately appoint one individual accountable for TAAMS and BIA Data Cleanup.
One manager is in charge of the TAAMS sub-project, of which Data Cleanup is a part. EDS recommends the Interior "invest the authority and responsibility" for the projects in one person who will report to the Executive Sponsor.

11. Establish a Trust Program Management Center.
EDS envisions the TPMC as a one-stop "dashboard" for seeing how trust reform is going. This would allow the government to report progress to a federal judge "with confidence," says EDS.

12. Improve stakeholder involvement in TAAMS and BIA Data Cleanup.
EDS recommends the Interior consult with tribes, Indian beneficiaries and work with its offices to come up with a plan that will adhere to "federal and local statues, treaties and tribal needs."

13. Execute comprehensive staffing plans for all participating organizations.
The BIA and the Office of the Special Trustee employ about 11,000 individuals. Many of them are not solely dedicated to trust reform because they have other duties to Indian Country.

"Regional offices are already understaffed in key areas," writes EDS. But unless the government comes up with a staffing plan, EDS says simply dedicating existing people to trust reform "will jeopardize the Department's ability to comply with ongoing Trust responsibilities."

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Interior mum on trust fund report (11/13)