Considering potential cumulative effects of proposed actions is fundamental to environmental impact analysis. However, cumulative effects analyses historically are not robust, especially for site-specific decisions. We sought to identify opportunities to strengthen cumulative effects analysis in a large United States public land management agency, the Bureau of Land Management (BLM). We asked 1) how cumulative effects analyses were legally challenged, 2) how site-specific cumulative effects analyses aligned with policy and compared to the broader-scale analyses to which they tiered, and 3) whether characteristics of cumulative effects analyses varied with category of proposed action, type of resource, or agency office. We used thematic analysis to assess litigation and appeals case documents finalized from 2010 to 2020 and a set of document analysis questions to assess National Environmental Policy Act (NEPA) analyses for BLM decisions completed prior to 2020 in Alaska and Colorado. We found that legal challenges related to cumulative effects focused on absence of cumulative effects analysis. In NEPA analyses, cumulative effects were frequently considered, but elements recommended in policy, such as citations, methods, and scope, were rarely included. These elements were present more often in the broader analyses to which site-specific analyses tiered. Many elements of cumulative effects analyses varied by proposed action and BLM office, and analyses of potential cumulative effects on air quality were consistently more detailed than for other resources. Our results suggest that many problems that historically plagued cumulative effects analysis persist. Advances in methods, training, and guidance could strengthen the defensibility of NEPA analyses.