Tribal Transportation: Better Data Could Improve Road Management and Inform Indian Student Attendance Strategies
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
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.
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.
Recommendations for Executive Action
|Department of the Interior||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.||
The Department of the Interior's Bureau of Indian Affairs (BIA) maintains the National Tribal Transportation Facility Inventory (NTTFI) data system, which includes transportation facilities--such as roads, bridges, bus shelters, and parking lots--on Indian reservations and within tribal communities and all public roads on tribal lands. Transportation facilities contained in the NTTFI are eligible for assistance under the Tribal Transportation Program (TTP) that distributes funding to tribes by formula. GAO conducted electronic testing of NTTFI data for completeness, out-of-range values, and logical inconsistencies to determine the extent to which the NTTFI system provided useful information about road conditions on tribal lands. In 2017, GAO reported that NTTFI inventory data--such as road location, length, and ownership--were reasonably complete and accurate and therefore useful, for identifying roads eligible for TTP funding. In contrast, GAO's electronic testing of NTTFI data on road-description and condition data--such as surface type, surface condition, and daily traffic count--found missing, inaccurate, and out-of-date-entries. Despite these issues, the Federal Highway Administration--the agency responsible for the TTP budget--used the NTTFI road-description and condition data in its annual budget justification and its Conditions and Performance Reports to Congress. While these road-description data were relevant for the budget justification and Report to Congress, it was unclear how useful the data were given the results of GAO's electronic testing. Further, the changes that BIA officials described to GAO in how the data are no longer used to support TTP-funding allocations raised questions about the continued need to collect road-condition and description data. Nevertheless, BIA continued to collect these data fields from tribes and maintain existing data on these fields in the NTTFI. Federal standards for internal control state that agencies should (1) design information systems and related control activities including continuing to evaluate those activities for continued relevance and effectiveness and (2) use quality information. To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, GAO recommended that the BIA coordinate with the FHWA and tribal stakeholders and reexamine the need for road-description and condition data collected in the NTTFI and eliminate fields that do not serve an identified purpose. Shortly after GAO issued its report, BIA and FHWA reported that they had conducted meetings with tribes and a tribal transportation program coordinating committee to review NTTFI data and identify those data that are no longer applicable for TTP implementation. In 2022, GAO confirmed that BIA conducted coordination meetings that resulted in a recommendation to reduce the number of NTTFI data fields from 54 to approximately 30. Further, GAO confirmed that BIA is transitioning the NTTFI data from its existing platform that is nearing the end of its life-cycle to a new geographic information system-enabled application that will provide enhanced functionality in using the NTTFI data. By taking these steps to eliminate data fields that do not serve an identified purpose and transition to a more functional application, BIA is positioning the NTTFI system to provide current, complete, and accurate data for more effective management and oversight of the TTP.
|Department of the Interior||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.||
In April 2023, BIA officials updated GAO on efforts to modernize the NTTFI from its existing platform to a geographic information system-enabled (GIS) application that will provide greater functionality. BIA officials told GAO that they completed the pilot for the GIS application in October 2022 and are proceeding with their phased approach to implement the application. According to BIA officials, as implementation progresses, they will develop guidance on steps needed to ensure the consistent reporting of data into the application. GAO will continue to monitor BIA efforts to address this recommendation.
|Department of the Interior||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.||
In April 2023, BIA officials informed GAO that the in-person training they provide to tribes includes time for tribal members to correct errors identified with their NTTFI data entries. According to these officials, this process allows for BIA staff to directly observe and provide real-time consultation to tribal members who are entering data into NTTFI and involves less uncertainty than if the they were to submit a request to BIA to correct a record in NTTFI. BIA officials said that they plan to increase the frequency of in-person trainings now that suspensions to training resulting from the COVID-19 pandemic have been lifted. Further, according to BIA officials, the trainings will continue to provide time for BIA to monitor tribes' NTTFI data entries to facilitate timely and targeted corrections to erroneous data. GAO will continue to monitor efforts to address this recommendation.
|Department of the Interior||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.||
In April 2023, BIA officials informed GAO that they expect to experience improvements to the DMR system as part of the ongoing transition of the NTTFI from its existing platform to a geographic information system-based (GIS) application. BIA officials told GAO that they completed the pilot for the GIS application in October 2022 and are proceeding with their phased approach to implement the application. According to these officials, when fully implemented, the GIS application will allow for the level of service evaluation data to be recorded along with the geometry information for road segments. Further, according to these officials, the application will provide the functionality to generate Deferred Maintenance Reports that include the time and date stamp of level of service evaluation activities. GAO will continue to monitor BIA's efforts to address this recommendation.
|Department of the Interior||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.||
In April 2023, BIA officials provided GAO with an update on their efforts to work with tribes in managing data related to road maintenance costs. According to these officials, BIA's efforts are aimed at assisting tribes in developing automated systems to track the cost of their maintenance activities. These officials further said that they intend for tribes to use this cost information to develop unit cost tables for their use in estimating maintenance needs and supporting DMR reporting. GAO will continue to monitor BIA's actions to address this recommendation.
|Department of the Interior||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.||
In April 2023, BIA officials informed GAO that they continue to work with tribes in exploring options to facilitate complete and accurate reporting on maintenance activities. Previously, BIA reported that its pilot project with tribes to develop capabilities to track costs for maintenance performed and use this information to develop estimates for future maintenance needs of BIA roads was also expected to move tribes to provide a more complete and accurate reporting of funds expended for maintenance on these roads. BIA acknowledged that some tribes are not required to report information on the funds expended for BIA road maintenance because 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, according to BIA, tribes have generally expressed interest in reporting this information. GAO will continue to monitor BIA's actions to address this recommendation.
|Department of the Interior||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.||
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.
|Department of the Interior||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.||
In April 2023, Department of Interior officials reiterated to GAO that they do not concur with the recommendation and do not plan to take action to implement it. The agency had previously conducted listening sessions with tribes to gauge interest in reviewing and adjusting the funding formula. According to Interior, tribes expressed little interest during these listening sessions to engage in the resource-intensive negotiated rulemaking process that would be needed to change the funding formula because of more pressing priorities. As a result, Interior told GAO that it has no plans to undertake a rulemaking process with tribes to review and adjust the formula. GAO continues to believe that adjusting the formula to better reflect transportation costs would help to best align resource allocation decisions to needs. However, GAO recognizes that despite Interior's attempts to engage on this issue, tribes' other priorities have tempered their interest in undertaking the rulemaking process that would be needed to make modifications to the funding formula. GAO will continue to monitor BIA's actions, if any, to address this recommendation.