Tribal Transportation:

Better Data Could Improve Road Management and Inform Indian Student Attendance Strategies

GAO-17-423: Published: May 22, 2017. Publicly Released: May 22, 2017.

Multimedia:

  • GAO: Road Conditions on Tribal Lands and Indian Student AttendanceVIDEO: Road Conditions on Tribal Lands and Indian Student Attendance
    Roads provide a vital connection to essential services such as schools, but the poor conditions of many roads on tribal lands contribute to transportation challenges for students and others. GAO reviewed road conditions and their potential impacts.

Additional Materials:

Contact:

Rebecca Shea
(202) 512-2834
SheaR@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

What GAO Found

The two databases maintained by the Department of the Interior's (Interior) Bureau of Indian Affairs (BIA) include some data fields useful for identifying tribal roads eligible for federal funding, but other fields may be too inaccurate to be useful for performance reporting and oversight. Specifically, the National Tribal Transportation Facility Inventory (NTTFI) provides useful data for identifying the roughly 161,000 miles of roads on tribal lands that are eligible for federal funding. However, the purpose for which these data are used has changed, and GAO found incomplete and inconsistent road-description and condition data, raising questions about the continued value of collecting these data. Similarly, BIA's Deferred Maintenance Reporting (DMR) system provides useful data on roughly 29,000 miles of BIA-owned roads eligible for federal funding, but GAO found inaccuracies in fields related to road-condition and road-maintenance needs. BIA does not document its road-maintenance cost estimates, and some tribes under-report performed maintenance. As a result, budget justification and performance reporting using these fields may not accurately reflect maintenance costs and needs. Federal standards for internal control suggest agencies design information systems and use quality information to achieve objectives.

Funding constraints, overlapping jurisdictions, and adverse weather make improving and maintaining roads on tribal lands challenging. However, intergovernmental partnerships have helped mitigate challenges in some cases. For example, in 2013, federal, state, and tribal agencies partnered on a $35- million project to pave a BIA earth road on the Navajo Nation when the main U.S. highway was closed due to a landslide. By partnering, the agencies completed the project in about 3 months and prior to the start of the school year, eliminating a 45-mile detour.

GAO's literature review and interviews with education officials indicate that road conditions can be a barrier to attendance, and Department of Education data show that Indian students have a higher chronic absence rate than other students (see fig.). At Interior, the Bureau of Indian Education's (BIE) schools generally do not collect data on transportation-related causes for absences, despite broader federal guidance that recommends doing so. BIE's attendance system lists causes, but transportation-related causes are currently not among them. Thus, BIE cannot quantify the effect of road conditions and target appropriate interventions. Rough road conditions in some areas also contribute to greater wear on school vehicles and associated higher maintenance costs.

School Bus on the Navajo Nation (Utah) and the National Rate of Students Chronically Absent, School Year 2013–14

U:\Work in Process\VCA_Graphics\FY 17\PI\Malika\100516 (Tribal Roads)\Tif\Fig0_5-100516_highlight_mr.tif

Why GAO Did This Study

Roads on tribal lands are of particular importance for connecting people to essential services, such as schools, because of the remote location of some tribes. These roads are often unpaved and may not be well maintained. The federal government funds two programs to improve and maintain roads on tribal lands. BIA maintains the NTTFI and DMR databases to support these programs.

GAO was asked to review condition and school-access issues related to roads on tribal lands. This report examines: (1) the extent to which the NTTFI and DMR systems provide useful data on these roads; (2) any challenges to improving and maintaining these roads; and (3) what is known about the connection between road condition and school attendance as well as other aspects of school transportation. GAO reviewed documents and relevant literature; analyzed road-inventory and student- attendance data; and interviewed federal, state, local, and tribal transportation and education officials. GAO visited three selected tribes, based on road mileage and presence of BIE schools, among other factors.

What GAO Recommends

GAO is making eight recommendations including that BIA, in coordination with stakeholders, reexamine the need for NTTFI data and improve the quality of DMR data, and that BIE provide guidance to collect transportation-related absence data. Interior agreed with five of the recommendations, did not take a position on two, and disagreed with one. GAO continues to believe its recommendations are valid, as discussed further in this report.

For more information, contact Rebecca Shea at (202) 512-2834 or SheaR@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: In June 2019, Interior reported that the Bureau of Indian Affairs' (BIA) and Federal Highway Administration's (FHWA) efforts to coordinate with tribes and the Tribal Transportation Program Coordinating Committee (TTPCC) to address this recommendation were progressing. Established by federal regulations, TTPCC is the committee comprised of 24 tribal representatives that provides input and makes recommendations to the BIA and FHWA. According to Interior, TTPCC has identified data elements--14 of 54 data fields--to be considered for removal from NTTFI, and BIA and FHWA have held discussions with tribes concerning a draft plan to remove these identified data elements from NTTFI. Interior reported that tribal groups have posed no objections to the plan and that they anticipate the plan being implemented later in the year. We will continue to monitor actions to address this recommendation.

    Recommendation: To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to coordinate with the Federal Highway Administration and tribal stakeholders and reexamine the need for road-description and condition data currently collected in the NTTFI and eliminate fields that do not serve an identified purpose.

    Agency Affected: Department of the Interior

  2. Status: Open

    Comments: In June 2019, Interior reported that a group of tribal users organized by the Bureau of Indian Affairs (BIA) and the Federal Highway Administration (FHWA) to review the NTTFI and the coding guide was progressing in its efforts to recommend updates to the coding guide. According to Interior, the group has made recommendations to the Tribal Transportation Program Coordinating Committee (TTPCC) on which data elements to remove from the NTTFI and for clarifying guidance in the coding guide, relevant to the data elements proposed to remain in the NTTFI. Interior anticipates that updates to the coding guide based on the group's recommendations will be completed in 2019. We will continue to monitor actions to address this recommendation.

    Recommendation: To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to for fields determined to have continued relevance for management and program oversight take steps to improve the quality of these data by clarifying guidance in the NTTFI coding guide that tribes use to collect data and by providing additional guidance on steps needed to ensure that data are consistently reported.

    Agency Affected: Department of the Interior

  3. Status: Open

    Comments: Interior told us that, along with the Bureau of Indian Affairs (BIA) and Federal Highway Administration (FHWA), it has held several meetings with tribal users to identify missing or erroneous data in the NTTFI. For example, the meeting participants identified that data which were formerly but are no longer used in formulas to allocate federal funding to tribes are likely outdated and not useful. Further, recognizing that approximately 70 percent of NTTFI data reflects inventory and condition information of roads owned by non-BIA and non-tribal entities, such as state and local governments, the meeting participants determined that opportunities exist to work with these external entities to monitor data obtained from them to ensure that it is current and accurate for use and display in the NTTFI. As of June 2019, Interior said that, in anticipation of changes to the NTTFI format, its main actions to address this recommendation will be to coordinate with these external entities to monitor the data they provide to NTTFI to ensure it conforms to NTTFI's new format. We will continue to monitor actions to address this recommendation.

    Recommendation: To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to establish a process to monitor data to facilitate timely and targeted corrections to missing or erroneous data.

    Agency Affected: Department of the Interior

  4. Status: Open

    Comments: In June 2019 Interior reported that BIA had developed a data reporting process that incorporates use of a "time-stamp" to indicate when the level of service for a road section is evaluated. Interior said that it anticipates providing guidance on this process to BIA staff, tribes, and others that perform level of service road maintenance assessments so that they can implement the process in 2020. We will continue to monitor efforts to implement this recommendation.

    Recommendation: To improve the DMR, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a means to document when the level of service for each road section was last evaluated.

    Agency Affected: Department of the Interior

  5. Status: Open

    Comments: In June 2019 Interior reported that the Bureau of Indian Affairs (BIA) had surveyed tribes to determine their capabilities for managing data related to road maintenance costs. Interior further reported that BIA was investigating the use of computer software for tracking road maintenance costs and developing estimates of maintenance needs. Interior said that it expects to complete actions to implement this recommendation in 2020. We will continue to monitor actions to address this recommendation.

    Recommendation: To improve the DMR, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop and maintain documentation supporting the unit costs of maintenance used to estimate maintenance needs.

    Agency Affected: Department of the Interior

  6. Status: Open

    Comments: In its official comments on our report, Interior said that that it cannot reasonably accomplish this recommendation because, in reference to the tribes which have agreements with the Bureau of Indian Affairs (BIA) to maintain BIA roads in their area, it conflicts with the intent of federal law and the minimum-reporting requirements when a tribal entity takes over the day-to-day actions and tasks of a program. However, following our report's issuance, Interior told us that its actions to address other recommendations will assist the tribes in developing data on Road Maintenance Program (RMP) funds expended for performed maintenance on BIA roads. In addition, Interior said that tribes have expressed interest in gathering this data. Further, in June 2019, Interior reported that the Tribal-Interior Budget Council had approved a plan for a pilot project in the BIA Great Plains Region to gather data relevant to addressing this recommendation. Even though tribal reporting of this data is voluntary, we continue to believe that by coordinating with affected tribes on developing a process for their self-reporting of RMP funds expended for maintenance, and by implementing such a process for tribes that BIA serves directly, Interior could improve the reporting of maintenance performed on BIA roads and be better positioned to provide Congress with more accurate and complete information on RMP funding decisions. We will continue to monitor actions to address this recommendation.

    Recommendation: To improve the DMR, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a process for more complete and accurate reporting occurring under existing authority of Road Maintenance Program funds expended for performed maintenance on BIA roads.

    Agency Affected: Department of the Interior

  7. Status: Closed - Implemented

    Comments: The Bureau of Indian Education (BIE) funds 185 schools serving about 41,000 students living on or near tribal lands. Roads on tribal lands are of particular importance for connecting people to essential services, such as schools, because of the remote location of some tribes. These roads are often unpaved and may not be well maintained, which can create transportation challenges for tribal communities. In 2017, GAO reported that Indian elementary and secondary school students are absent more than non-Indian students, according to GAO's analysis of national data from the Department of Education. Indian students' higher rates of absences are evident at public schools serving mostly Indian students and at BIE schools, which would likely be on or near tribal lands. Given the absence of studies on the effects of road conditions on student attendance in the United States, GAO found studies about developing countries that identified road conditions as one of several factors influencing student attendance. Likewise, road conditions are one of the factors leading to absences for Indian youth on tribal lands, according to officials at all 10 local schools and districts GAO visited serving three tribes. Guidance from the National Forum on Education Statistics and from four departments--Education, Health and Human Services, Housing and Urban Development, and Justice--emphasizes the importance of collecting and using absence data to improve attendance and to understand reasons for absences. Three of the schools and districts GAO visited collected data on the number of student absences related to road and weather conditions. This was despite the fact that BIE had neither provided guidance to its schools regarding capturing reasons for absences related to roads and weather, nor provided instructions or suggestions to the 185 schools it funds to consider including road and weather conditions as reasons for absences in their attendance system. Without such guidance, affected BIE schools as well as the Bureau itself would continue to lack insight into the effect of roads and weather on absences and the ability to target interventions accordingly. Therefore, GAO recommended that BIE provide guidance to its schools to collect data on student absences related to road and weather conditions. In 2019, GAO confirmed that BIE had completed work to implement two new data tracking categories in its Native American Student Information System (NASIS) that allows users to attribute absences to either adverse road conditions or adverse weather conditions. BIE had also increased from two to seven its NASIS staff who are expected to provide training, guidance materials, and technical assistance to its BIE-funded schools on the newly implemented data tracking categories. BIE schools first used the new data tracking categories to collect data on the reasons for student absences during the 2018 - 2019 school year. As these schools continue to collect data, they as well as the Bureau will be able to analyze these data to improve their understanding of the extent that adverse road conditions and adverse weather affect attendance and to target interventions.

    Recommendation: To improve data on reasons for student absences, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to provide guidance to BIE schools to collect data on student absences related to road and weather conditions.

    Agency Affected: Department of the Interior

  8. Status: Open

    Comments: At the time of our report, Interior said that it concurred with this recommendation; however, it subsequently changed its position. Interior noted that its tribal and school partners have not requested changes to this formula and that it was therefore not compelled to undertake the rigorous consultation and negotiated rulemaking actions that would be needed to change the formula. As of June 2019, Interior has not acted to address this recommendation.

    Recommendation: To best align resources allocation decisions to needs, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to review the formula to fund transportation at BIE schools and determine, with BIA and tribal stakeholders, what adjustments, such as distinguishing between gravel and paved roads, are needed to better reflect transportation costs for schools.

    Agency Affected: Department of the Interior

 

Explore the full database of GAO's Open Recommendations »

Aug 10, 2020

Jul 27, 2020

Jul 16, 2020

Jun 23, 2020

Apr 30, 2020

Apr 29, 2020

Apr 23, 2020

Mar 25, 2020

Mar 23, 2020

Looking for more? Browse all our products here