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Nonprofit Quarterly has uncovered public documents pertinent to the announcement by Dan Snyder, the owner of Washington DC’s NFL franchise, of the creation of the “Washington Redskins Original Americans Foundation” and the appointment of one Gary L. Edwards as its CEO. As reported by NPQ, Edwards, a 28-year veteran of the U.S. Secret Service, is the former chief executive officer of the National Native American Law Enforcement Association, organized as a 501(c)(6) business league with its physical headquarters at the Ronald Reagan Building in Washington, DC, though GuideStar lists its physical address as Jonesborough, TN.
The NNALEA, long directed by Edwards, has received 24 contracts from federal government agencies between 2006 and 2010, 15 from the Department of Homeland Security and nine from the Department of the Interior, according to the USASpending.gov database. The total value of these transactions was $1,327,425, most of them small contracts related to NNALEA roles in providing law enforcement training, typically at NNALEA annual conferences.
By far the largest, however, was a one-year $1 million contract through the Bureau of Indian Affairs of the Department of the Interior in 2009 to help the BIA recruit and hire law enforcement officers (police, corrections, and criminal investigator positions) to work in Indian Country. In eight months, the NNALEA received and spent $967,100 of the $1 million. According to the Interior Department’s Inspector General, “OIG found that [the BIA Office of Justice Services] received no beneﬁt when it awarded the recruitment services contract to NNALEA, thus wasting almost $1 million.” Although the IG clearly identifies the inadequate contract development and management by the BIA, it points out the poorly written contract was developed in conjunction with the NNALEA, and “NNALEA took advantage of OJS and the contract defects to produce unusable contract deliverables.”
Notwithstanding the clear examples of BIA mismanagement of the contract relationship with NNALEA, the specifics contained in the Inspector General’s May 2012 report about NNALEA’s performance are damning:
- The original contract scope of work called for NNALEA to deliver 500 qualified applicants for federal law enforcement positions in Indian Country, which were particularly needed because of the documented shortage of qualified law enforcement personnel at BIA detention facilities. NNALEA’s proposal explained how it would determine and verify that the applicants were qualified. However, after the contract award, the BIA and the NNALEA jointly revised the contract. The most significant modification to the statement of work eliminated the requirement that NNALEA deliver qualified applicants, but simply that they be “pre-screened.” According to the IG report, “this modification removed the requirement that an applicant be qualified for the position and be of Native American heritage to be counted as a contract deliverable applicant.” It added, “Under the revised contract terms, NNALEA only needed to review the application materials submitted by every applicant.”
- “NNALEA provided OJS with 748 applications, none of which were of use to OJS,” according to the IG report. “Upon delivery, OJS officials reviewed the first batch of applications, finding them to be generally unacceptable because they were incomplete and/or applicants exceeded age requirements, did not have Indian preference, and/or had criminal records.” Among the “pre-screened” applicants that NNALEA delivered for its million-dollar contract was one person who was 80 years old (the upper age limit for qualified applicants was 37). Out of 540 applicants reviewed by the IG, 104 were too young or too old to qualify. Lastly, and amazingly, only four percent of the applicants expressed a preference for a federal law enforcement position in Indian Country. All of this from a contractor that was selected in part because of its knowledge of the requirements for federal law enforcement officers and because of its ability to recruit Native Americans who wanted to work in Indian Country.
- The IG found billings from NNALEA that looked to be for expenses that were never incurred—for example, for on-site recruiting that never seemed to happen at a Crow Fair Celebration and for recruiting advertisements that were never placed in the Aberdeen News of South Dakota.
- Although the CEO of NNALEA—Edwards—apparently was initially interviewed by the IG’s staff, he declined to sit for a second interview with the IG on the advice of counsel, and three directors of the NNALEA, all federal law enforcement officers, also declined to be interviewed.
While the BIA’s management of the contract was clearly disastrous, the NNALEA appears to have delivered nothing of value for the nearly $1 million of federal money it spent—virtually no one who the BIA could have recruited, or who wanted to be recruited, for a federal law enforcement position in Indian Country.
According to details of this contract on the USASpending site, NNALEA claims to have had 27 employees, but its Form 990s on GuideStar show no employees. Apparently, it conducts its work through subcontractors who are not identified in the 990s. Overall, the NNALEA financials look as follows, with the last available 990 from 2011: