Weaknesses in the Office of the Special Trustee for American Indian’s Death Record Process Threaten Fiduciary Responsibilities

We inspected the Office of the Special Trustee for American Indians’ (OST’s) process for collecting death data to determine whether beneficiary deaths are accurately recorded to ensure that payments made after the death of a beneficiary are distributed correctly. The DOI has responsibility for more than $5 billion held in trust by the Federal Government on behalf of American Indians and Indian Tribes. The OST manages the Indian fiduciary trust for the DOI, which includes approximately 3,500 trust accounts for 250 Indian Tribes and nearly 404,000 Individual Indian Money (IIM) accounts. We found weaknesses in the OST’s process for collecting death data. Specifically, we found the OST does not have a system that interfaces with the Bureau of Indian Affairs’ (BIA’s) probate tracking system, which may lead to inconsistent death data between DOI’s agencies; does not reconcile or confirm the status of beneficiaries with the BIA or other sources to monitor accuracy of its death data; and does not educate Indian communities about providing death notifications to ensure timely and complete death data. Without consistent, accurate, timely, and complete death data, the OST risks distributing payments to deceased beneficiary accounts and delaying the initiation of the probate process, which threatens the proper distribution of trust payments. We made three recommendations that, if implemented, will improve the consistency, accuracy, and completeness of the OST’s beneficiary data.