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Highlights

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.

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Recommendations

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

Agency Affected Recommendation Status
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.
Open
In March 2021, Interior updated GAO on 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. Established by federal regulations, TTPCC is the entity comprised of 24 tribal representatives that provides input and makes recommendations to the BIA and FHWA. According to Interior, the coordinated action of these groups resulted in the identification of approximately 24 data elements within the NTTFI that could be eliminated from the core inventory system because the data no longer served an identified purpose. Further, BIA staff told GAO that efforts are underway to transition the NTTFI from its existing platform to a GIS-enabled application that provides greater functionality. BIA expects that the GIS-enabled application will be operational in 2022 and will support the optimized version of the NTTFI. GAO will continue to monitor actions 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 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.
Open
In March 2021, Interior updated GAO on efforts being led by a group of tribal users organized by BIA and FHWA to review the NTTFI and the coding guide. This group had previously made recommendations to the 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. BIA told GAO that updates to the coding guide that would provide guidance on steps needed to ensure the consistent reporting of data were tied to the planned transition of the NTTFI from its existing platform to a GIS-enabled application that provides greater functionality. BIA expects that the transitioning of the NTTFI platform and related updating of the coding guide will be completed in 2022. GAO will continue to monitor 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.
Open
In March 2021, Interior told GAO that BIA had established an approach over the previous two years to incorporate into its in-person training provided to tribes a dedicated time period to be used to correct erroneous NTTFI data entries. According to BIA, this approach allows for an interactive process under which BIA staff can directly observe and provide real-time consultation to tribal members who are entering data into NTTFI. BIA told GAO that this approach is timelier and involves less paperwork than if the tribes were to submit a request to BIA to correct a record in NTTFI. While the COVID-19 pandemic has resulted in BIA conducting fewer in-person training sessions, BIA told GAO that it intends to continue holding in-person sessions in the future which will allow it to monitor data 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.
Open
In March 2021, Interior clarified its plans for developing a means to document when the level of service for each road section was last evaluated. According to the BIA staff who are responsible for the Deferred Maintenance Reporting (DMR) system, all data associated with the time and date of a road segment's assessment exists in the system. While these data are captured in the DMR database, BIA staff told GAO that their plans to update the DMR system will require them to work with database administrators to develop reports to communicate this information. BIA staff said that they expect to have the capability to generate these reports by the end of the year. 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 and maintain documentation supporting the unit costs of maintenance used to estimate maintenance needs.
Open
Previously, Interior reported that BIA had surveyed tribes to determine their capabilities for managing data related to road maintenance costs. According to BIA, the survey identified that the majority of tribes had the capability to track maintenance costs for different road types. In March 2021, BIA told GAO that it was working with tribes to leverage this capability for tracking maintenance costs through implementation of a pilot project to determine unit maintenance costs and develop BIA-wide estimates of road maintenance needs. GAO will continue to monitor 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.
Open
In March 2021, Interior told GAO that BIA's pilot project with tribes to determine unit maintenance costs and estimate maintenance needs of BIA roads is expected to also allow for a more complete and accurate reporting of funds expended for performed 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. As such, BIA told GAO that it will continue to coordinate with tribes on developing a process to enable more complete and accurate reporting on funds expended for performed maintenance. GAO will continue to monitor 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.
Closed - Implemented
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.
Open
In March 2021, Interior told GAO that it intended to conduct listening sessions with tribes later in the year to gauge current interest in revising the funding formula. Interior further told GAO that, pending the outcome of these listening sessions, it may choose to proceed with the negotiated rulemaking that would be needed to adjust the formula to better reflect transportation costs for schools. Because Interior cannot presuppose that a negotiated final rule will comport with GAO's recommendation, it continues to not concur with the recommendation. However, Interior told GAO that if a potential final rule does comport with the recommendation, then it will change its position to concur with the recommendation and request that it be closed. GAO will continue to monitor actions to address this recommendation.

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