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    Subject Term: "Educational facility construction"

    2 publications with a total of 10 open recommendations including 2 priority recommendations
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    6 open recommendations
    Recommendation: To ensure accountability for BIE school facility funds, the Secretary of the Interior should direct the Assistant Secretary--Indian Affairs to develop a comprehensive long-term capital asset plan to inform its allocation of school facility funds. Such a plan should include a prioritized list of school repair and maintenance projects with the greatest need for funding.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. Interior stated that Indian Affairs is engaged with the Office of Management and Budget to develop a more robust and prioritized capital asset management plan for school infrastructure needs, which they expect to complete before the end of fiscal year 2017.
    Recommendation: To ensure accountability for BIE school facility funds, the Secretary of the Interior should direct the Assistant Secretary--Indian Affairs to provide more details in Indian Affairs' annual congressional budget justifications on specific needs at BIE schools, including information on proposed capital expenditures, and updates on previous school construction projects.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. In May 2017, Interior stated that Indian Affairs is currently engaged in an effort to comprehensively review the budget justification process with the objective of improving the quality, format, and presentation of the President's annual budget submission to Congress and that it will work to provide more detailed information on proposed capital expenditures and updates on previous construction projects. In addition, the agency reported that Indian Affairs will ensure improvements to the budgeting process are made permanent through formal policy and procedure in order to ensure that the needs of BIE schools are accurately and regularly reported in its congressional budget justification.
    Recommendation: To ensure accountability for BIE school facility funds, the Secretary of the Interior should direct the Assistant Secretary--Indian Affairs to develop and implement guidance for its project managers and contracting officers regarding effective use of accountability measures.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. Interior indicated that the Acquisition office and the Division of Facilities Management and Construction are working together to create and implement guidance and were preparing and planning improvements for future construction contracts. In addition, the agency stated that Indian Affairs will develop a financial accountability workgroup with members from the Office of the Chief Financial Officer, BIA, BIE, and the Office of the Assistant Secretary--Indian Affairs to develop guidance and standards to ensure the effective use of accountability measures.
    Recommendation: To ensure accountability for BIE school facility funds, the Secretary of the Interior should direct the Assistant Secretary--Indian Affairs to clarify Indian Affairs' design handbook requirements to explain when and how school designs can deviate from specific requirements--such as heating and cooling systems with complex features--when the life cycle cost analysis demonstrates the requirements are not cost-effective or practical given such factors as the technical capacity of school facility staff.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior disagreed with this recommendation, noting that it had revised its design handbook in 2017 and that the revised handbook includes a process to consider deviations that do not violate requisite codes, standards, or laws. Interior also stated that the handbook is not intended to describe every scenario where a deviation may be requested and that it is more efficient to allow designers, schools and other users to request deviations and exceptions as and when needs arise. However, we believe the revised handbook is still in draft and is being reviewed internally and has neither been finalized nor distributed: an updated design handbook that includes a process for deviations is critical. We agree with the agency that the handbook does not need to describe every scenario where a deviation may be requested. The draft 2017 handbook indicates that when conflicts or questions arise the designer is to formally notify the Interior project manager in writing to request a waiver. However, it does not provide an explanation of the process or how life cycle cost analysis might inform that process. We continue to believe that, in addition to a process, providing guidelines and an explanation about how life-cycle cost analysis should inform such decisions in the handbook before it is finalized would be useful and help to ensure that the choices designers make with regard to design are both cost-effective and practical.
    Recommendation: To ensure accountability for BIE school facility funds, the Secretary of the Interior should direct the Assistant Secretary--Indian Affairs to improve oversight and technical assistance to tribal organizations to enhance tribal capacity to manage major construction projects.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. Interior stated that its Division of Facilities Management and Construction will develop a "high-risk" project tracking and monitoring process. The Division will work with BIA and BIE facilities managers to develop an engagement plan to better inform tribes of the extensive requirements involving the management of capital projects replacing schools or facilities. For tribes that manage projects themselves, Indian Affairs will offer to provide them with technical assistance, particularly during key program phases.
    Recommendation: To ensure accountability for BIE school facility funds, the Secretary of the Interior should direct the Assistant Secretary--Indian Affairs to develop and implement guidance for maintaining complete contract and grant files for all BIE school construction projects.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. Interior stated that Indian Affairs will develop, as part of its Financial Accountability Workgroup, guidance for maintaining all types of construction contract and grant files.
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    4 open recommendations
    including 2 priority recommendations
    Recommendation: To support the collection of complete and accurate safety and health information on the condition of BIE school facilities nationally, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to ensure that all BIE schools are annually inspected for safety and health, as required by its policy, and that inspection information is complete and accurate. This could include: (1) Analyzing the key challenges to ensuring that all BIE schools are inspected, as well as implementing a plan to mitigate those challenges. (2) In the interim, prioritizing inspections at schools where facility conditions may pose a greater risk to students--such as schools with dormitories or those that have not been recently inspected.

    Agency: Department of the Interior
    Status: Open
    Priority recommendation

    Comments: In September 2016, Indian Affairs reported that it had completed annual safety inspections at all BIE school locations for the first time in at least 15 years. In late August 2017, officials reported that Indian Affairs was on course to complete all inspections in 2017 but did not provide documentation on its progress. Further, Indian Affairs stated that it understands the need to ensure that completing school inspections does not detract from inspection quality. However, as of August 2017 we had not received documentation that the agency had taken steps to ensure that its safety personnel collect inspection information that is complete and accurate. We believe the steps Indian Affairs has taken to prioritize the completion of safety inspections at all BIE schools are important ones. However, we believe it is also important that the agency take specific steps to ensure that the inspection information it collects is complete and accurate. Without complete and accurate information, BIE schools may not have the information they need on potential safety hazards, which may endanger students and staff. We will continue to monitor Indian Affairs' efforts to implement this recommendation.
    Recommendation: To support the collection of complete and accurate safety and health information on the condition of BIE school facilities nationally, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to revise its inspection guidance and tools to ensure that they are comprehensive and up-to-date; require that regional safety inspectors use them to ensure all vital areas are covered, such as school fire protection; and monitor safety inspectors' use of procedures and tools across regions to ensure they are consistently adopted.

    Agency: Department of the Interior
    Status: Open

    Comments: In June 2016, Indian Affairs implemented new comprehensive guidelines for safety and health inspections and testing and maintaining fire prevention systems. The guidelines, which we reviewed, detail specific inspection procedures which all relevant safety personnel are required to follow. Indian Affairs provided training in May and June of 2017 to relevant staff on using the guidelines. According to the guidelines, Indian Affairs' safety office is required to monitor safety staff compliance with the new inspection procedures. We believe these are important steps to ensuring that regional inspectors have clear procedures in place for conducting BIE school inspections. However, Indian Affairs has not provided us with documentation, such as a plan, for how its safety office will monitor inspections to ensure procedures are consistently followed by inspectors across regions. For example, such monitoring could help ensure that all inspectors conduct a close out meeting with relevant school staff at the conclusion of an on-site safety inspection. We believe such monitoring is important to ensure that the practices of its safety inspectors consistently align with its procedures and result in inspection information that is complete and accurate. We will continue to monitor Indian Affairs' efforts to implement this recommendation.
    Recommendation: To ensure that all BIE schools are positioned to address safety and health problems with their facilities and provide student environments that are free from hazards, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a plan to build schools' capacity to promptly address safety and health problems with facilities. Such a plan could prioritize assistance to schools to improve the expertise of facility staff to maintain and repair school buildings.

    Agency: Department of the Interior
    Status: Open
    Priority recommendation

    Comments: Interior agreed with this recommendation. As of late August 2017, Indian Affairs had not provided us any documentation that it had taken steps to implement our recommendation. We will continue to monitor Indian Affairs' efforts to implement this recommendation.
    Recommendation: To ensure that all BIE schools are positioned to address safety and health problems with their facilities and provide student environments that are free from hazards, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to consistently monitor whether schools have established required safety committees.

    Agency: Department of the Interior
    Status: Open

    Comments: In July 2017, Indian Affairs officials told us that they are developing a system that would enable them to monitor whether schools have established required safety committees. They also noted that Indian Affairs' new inspection procedures require that inspectors check to see if schools have established safety committees. Finally, the BIE Director reported that he would send a memorandum to all BIE schools reminding them about Indian Affairs' requirement to establish safety committees. We will review and evaluate Indian Affairs' actions when the agency has provided us with supporting documentation.