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    Subject Term: "Native American education"

    5 publications with a total of 23 open recommendations including 4 priority recommendations
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    6 open recommendations
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop and take corrective actions, in consultation with Interior's Designated Agency Safety and Health Official, to address BIA safety program weaknesses identified in prior Interior evaluations.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. The agency stated that the Designated Agency Safety and Health Official (DASHO) is working with the Indian Affairs' safety office and BIA regional leadership to discuss the current state of BIA's safety program and develop a corrective action plan to address identified safety program weaknesses.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to assign responsibility to a specific office or official to develop and implement a plan to assess employees' safety training needs and monitor employees' compliance with Indian Affairs' safety training requirements.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. Interior indicated that Indian Affairs is developing a safety training plan, which will establish program responsibilities and compliance requirements for safety training across BIA, among other areas. Interior also noted that line offices will track the implementation of the training plan and individuals' compliance with training requirements.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to ensure that BIA's employee performance standards on inspections are consistently incorporated into the appraisal plans of all BIA personnel with safety program responsibilities.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. Interior commented that the appraisal plans of BIA regional directors had been updated to include BIA's new performance standards on inspections, which we noted in our report. The agency also stated that Indian Affairs' work in addressing this recommendation was primarily completed. However, Interior did not provide evidence that the appraisal plans of all BIA staff with safety program responsibilities included all of the bureau's new performance standards on safety inspections. We continue to believe that it is important that BIA's employee performance standards on inspections are consistently incorporated in all BIA employee appraisal plans.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a performance standard on inspection report quality and establish a process to routinely monitor the quality of inspection reports. Monitoring could include, but not be limited to, the following areas: accuracy of risk levels and abatement timeframes assigned to deficiencies and clarity of language to describe safety hazards and recommended corrections.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. The agency noted that Indian Affairs is developing written policies and procedures for safety inspections at BIE schools, which it says will address issues with report clarity and accuracy, among other areas. However, Interior did not provide us with information about whether it will establish a performance standard for report quality and a process for monitoring inspection quality, which are the two key actions we recommended. We maintain that these steps are needed to ensure that BIE schools receive thorough and accurate safety inspection reports.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to require safety inspectors to document when inspection reports are sent to schools and establish a process to routinely monitor the timeliness of reports against Indian Affairs' required 30-day timeframe.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. Interior stated that Indian Affairs will require inspectors to certify and report the dates on which inspectors send reports to schools. The agency also noted that Indian Affairs' safety office will monitor the timeliness of inspection reports sent to schools and report the results of its monitoring to Indian Affairs' senior leadership.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to use information gathered from monitoring the timeliness of school safety inspection reports to assess the performance of employees with safety program responsibilities and hold them accountable.

    Agency: Department of the Interior
    Status: Open

    Comments: Interior agreed with this recommendation. Interior stated that supervisors will ensure that responsible employees are held accountable for complying with its performance standards on safety inspections. We continue to believe it is important that Indian Affairs use information from monitoring inspection report timeliness to assess employee performance.
    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.
    Director: Melissa Emrey-Arras
    Phone: (617) 788-0534

    4 open recommendations
    including 2 priority recommendations
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a comprehensive workforce plan to ensure that BIE has an adequate number of staff with the requisite knowledge and skills to effectively oversee BIE school expenditures.

    Agency: Department of the Interior
    Status: Open

    Comments: In May 2017, the Bureau of Indian Education(BIE) Director reported that an internal working group would draft a comprehensive workforce plan that is aligned with BIE's strategic plan. They did not specify whether such a plan would include a focus on BIE administrative offices responsible for oversight of school expenditures. In late August 2017, BIE officials indicated that they would revisit the strategic workforce planning effort by Indian Affairs. They did not provide further information on what actions BIE will take to address this recommendation. However, the BIE Director noted in May of this year that the agency planned to complete its work on this recommendation no later than the end of 2018. We will continue to monitor Indian Affairs' efforts to implement this recommendation.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a process to share relevant information, such as single audit reports, with all BIE staff responsible for overseeing school expenditures to ensure they have the necessary information to identify schools at risk for misusing funds.

    Agency: Department of the Interior
    Status: Open

    Comments: In late August 2017, agency officials reported that it had developed and implemented a SharePoint-based system for sharing single audit reports to ensure that all key staff have access to this system. The agency is exploring other technological options for providing staff with access to single audit reports. The BIE Director noted in May of this year that the agency planned to complete its work on this recommendation no later than the end of 2018. While this is a step in the right direction, as we have communicated to BIE officials, the SharePoint system includes audit reports on fewer than half of all tribally-operated schools. Such reports are a vital source of information for monitoring how schools use federal funds. Without relevant BIE staff having access to audit reports for the majority of tribally-operated schools, it is unclear to us how such a system can support effective oversight of spending at these schools. We will continue to monitor Indian Affairs' efforts to implement this recommendation.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop written procedures for BIE to oversee expenditures for major programs, including Interior's Indian School Equalization Program. These procedures should include requirements for staff to consistently document their monitoring activities and actions they have taken to resolve financial weaknesses identified at schools.

    Agency: Department of the Interior
    Status: Open
    Priority recommendation

    Comments: In response to our report, Interior stated that BIE already had written procedures in place related to the Indian School Equalization Program (ISEP). However, we found the procedures did not relate to overseeing schools' ISEP expenditures. In late August 2017, agency officials reported taking several steps to address this recommendation. In particular, officials reported that the agency had drafted written procedures for overseeing BIE school spending. However, these officials noted that further review and revision to the procedures are necessary before they can be finalized and implemented. Officials did not provide us with a draft of the procedures to review. The BIE Director noted in May of this year that the agency planned to complete its work on this recommendation by the middle of 2019. We will continue to monitor Indian Affairs' efforts to implement this recommendation.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a risk-based approach to oversee BIE school expenditures to focus BIE's monitoring activities on schools that auditors have found to be at the greatest risk of misusing federal funds.

    Agency: Department of the Interior
    Status: Open
    Priority recommendation

    Comments: In late August 2017, agency officials reported that they had begun drafting a risk assessment policy and procedures for monitoring BIE school expenditures. However, they noted that further review and revision to the policy is necessary before it can be finalized and implemented. Officials did not provide us with a draft of these documents to review. The BIE Director noted in May of this year that the agency planned to complete its work on this recommendation by the middle of 2019. We will continue to monitor Indian Affairs' efforts to implement this recommendation.
    Director: Scott, George A
    Phone: (202) 512-7215

    3 open recommendations
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop and implement decision-making procedures for BIE that specify who should be involved in the decision-making process for key decisions that affect BIE and its schools to ensure that BIE has effective management controls, is accountable for the use of federal funds, and comports with federal laws and regulations. Such procedures should be clearly documented in management directives, administrative policies, or operating manuals.

    Agency: Department of the Interior
    Status: Open

    Comments: In August 2017, Bureau of Indian Education (BIE) officials stated that they have developed decision-making procedures for BIE in consultation with staff from across the bureau. They indicated that the procedures will be implemented in the coming weeks, pending final approval from the Office of Regulatory Affairs and Collaborative Action and the Office of the Assistant Secretary-Indian Affairs. We reviewed Indian Affairs' draft procedures, which they plan to incorporate into Indian Affairs' policy manual. The procedures identify, by position, BIE leaders whose involvement in the decision-making process is necessary and define roles and responsibilities of such individuals, among other areas. We will consider whether Indian Affairs' actions fully address this recommendation once the agency provides us with its finalized procedures.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a strategic plan that includes detailed goals and strategies for BIE and for those offices that support BIE's mission, including the Bureau of Indian Affairs, to help Indian Affairs effectively implement its realignment. Development of the strategic plan should incorporate feedback from BIE officials and other key stakeholders. To gather stakeholder input, we recommend that the plan include a comprehensive communications strategy to improve communication within Indian Affairs and between Indian Affairs and BIE staff.

    Agency: Department of the Interior
    Status: Open

    Comments: In August 2017, Indian Affairs officials stated that the draft strategic plan for BIE developed by the agency several years ago did not address our recommendation. Officials also told us they began holding strategic planning sessions in March 2017, which they said would continue through late September 2017. Indian Affairs drafted several key elements of its new strategic plan for BIE. The draft includes information on its mission, vision, values and goals. According to agency officials, they are currently developing additional elements to include milestones, measures, and specific action plans. Officials also noted that BIE has reached out to external subject matter expert organizations, such as the Council of Chief State School Officers, in developing its strategic plan. Officials reported they expect to implement the new plan no later than the end of calendar year 2017. We will continue to monitor Indian Affairs' efforts to implement this recommendation.
    Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to revise its strategic workforce plan to ensure that employees providing administrative support to BIE have the requisite knowledge and skills to help BIE achieve its mission and are placed in the appropriate offices to ensure that regions with a large number of BIE schools have sufficient support.

    Agency: Department of the Interior
    Status: Open

    Comments: Although BIE completed a strategic workforce planning effort in 2016, the agency has not fully addressed this recommendation. We will monitor the agency's efforts to finish implementing this recommendation.