Recommendation: The Director of IHS should implement a targeted, resource-efficient method to identify additional eligible Indian homes that may have existing deficiencies to include in IHS's Home Inventory Tracking System (HITS). (Recommendation 1)
Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open
Comments: In August 2018, IHS's Division of Sanitation Facilities Construction issued a memo to its Area Directors directing them to identify additional eligible Indian homes that may have existing deficiencies to include in HITS. The memo directed Area Offices to use existing staffing resources to leverage their annual efforts to gather sanitation needs data, in collaboration with tribes, to identify any additional homes. In December 2019, IHS officials stated that, as a result of implementing the 2018 memo, Area Directors had increased the number of eligible homes that they identified in 2019. We will continue to monitor the results of IHS's actions.
Recommendation: The Director of IHS should implement a mechanism to indicate in HITS whether each home with a deficiency level of 0 has been assessed. (Recommendation 2)
Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open
Comments: As of December 2019, IHS had developed a mechanism in HITS to indicate whether a home currently classified as deficiency level (DL) 0 had been assessed. IHS stated that it has eliminated the category of DL 0 from HITS; in its place, it created a new category of "Pending Assessment" for those homes that are in HITS but that have not been assessed. IHS also came up with a way to prioritize the homes in the Pending Assessment category based on their eligibility to receive assistance from IHS. Homes currently in HITS that have a DL 0 and received service through the Sanitation Facilities Construction Program from 2015 through today will be reassigned a DL 1 to indicate the deficiencies are only associated with routine operations and maintenance. IHS stated that the changes to HITS have been implemented and shared a proposal of how it will distribute the former DL 0 homes across the new categories. We will evaluate IHS's actions after they are complete.
Recommendation: The Director of IHS should reassess the point distribution across the Sanitation Deficiency System scoring factors as part of its program guidelines update, in light of trade-offs between funding projects that address the most severe sanitation deficiencies and projects that meet other needs. (Recommendation 3)
Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open
Comments: As part of its reassessment of the point distribution across the scoring factors, in 2018 and 2019 IHS consulted with tribes and analyzed various options for changing the point distribution. We have asked IHS to provide additional information about its reassessment efforts. We will evaluate IHS's actions after we receive the additional information.
Recommendation: The Assistant to the Secretary of Agriculture for Rural Development should implement a scoring factor that awards points for proposed Native American program grant projects that address health risks from a lack of access to safe drinking water and wastewater disposal, as it does with the Colonias grant program. (Recommendation 4)
Agency: Department of Agriculture
Status: Open
Comments: As of January 2020, USDA stated it would prefer to use its discretionary points under its existing regulations to implement this scoring factor instead of making a regulation change to do so. USDA stated that using existing flexibility in the regulations could meet the intent of the recommendation more quickly than by permanently changing the regulation. USDA stated that it has established policy guidance to states that addresses scoring for projects with health and sanitation risks. We will monitor the actions that USDA has taken in response to this recommendation and evaluate them when complete.
Recommendation: The Director of IHS, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 7)
Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open
Comments: As of December 2019, IHS had reviewed the 2011 task force report and summarized actions taken and challenges associated with implementing the remaining recommendations. IHS stated that it anticipated discussing its summary with the other members at a future tribal infrastructure task force meeting. We will evaluate IHS's actions when they are complete.
Recommendation: The Administrator of EPA, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 8)
Agency: Environmental Protection Agency
Status: Open
Comments: As of June 2020, EPA had discussed the 2011 task force report with the other member agencies to identify and implement additional actions to increase collaboration at the national level. EPA published a summary matrix of relevant funding sources on the task force website and compiled a draft document summarizing actions the task force member agencies have taken to implement recommendations from the 2011 report. We will continue to monitor EPA's actions in response to this recommendation.
Recommendation: The Assistant to the Secretary of Agriculture for Rural Development, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 9)
Agency: Department of Agriculture
Status: Open
Comments: In July 2019, the task force member agencies met to discuss the status of the recommendations in the 2011 task force report. The agencies each agreed to compile information about the actions they had taken and consider new actions in 2020. USDA stated in December 2018 that the task force agencies had made progress in developing efficiencies in environmental review processes and with online tribal resources and training, in addition to other areas. We will evaluate USDA's actions after the task force has compiled all actions taken in response to the 2011 report and evaluated what further actions or responses should be conducted.
Recommendation: The Deputy Assistant Secretary of the Department of Housing and Urban Development's Office of Native American Programs, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 10)
Agency: Department of Housing and Urban Development
Status: Open
Comments: As of December 2019, the task force members had agreed to jointly consider the actions they have taken from the 2011 report and to discuss additional actions they could take to increase collaboration at the national level. We will evaluate HUD's actions once they are complete.
Recommendation: The Commissioner of Reclamation, in cooperation with other members of the tribal infrastructure task force, should review the 2011 task force report and identify and implement additional actions to help increase the task force's collaboration at the national level. (Recommendation 11)
Agency: Department of the Interior: Bureau of Reclamation
Status: Open
Comments: In April 2018, Reclamation met with other members of the task force and the agencies reviewed and discussed the 2011 task force report recommendations. As of December 2019, the task force members had agreed to jointly consider the actions they have taken from the 2011 report and to discuss additional actions they could take to increase collaboration at the national level. We will evaluate the agency's actions once they are complete.
Recommendation: The Director of IHS, in cooperation with other members of the tribal infrastructure task force, should direct IHS area offices to identify and pursue additional mechanisms to increase their collaboration. (Recommendation 12)
Agency: Department of Health and Human Services: Public Health Service: Indian Health Service
Status: Open
Comments: As of December 2019, IHS headquarters hosted a meeting that included staff from IHS Areas, EPA headquarters, and EPA regions to discuss additional mechanisms to increase collaboration, including best practices for identifying projects for joint funding collaborations. In addition, IHS and the other tribal infrastructure task force members agreed to jointly draft a memo for distribution to their field offices that would include contact information for other member agencies and encourage interagency coordination. We will evaluate IHS's remaining actions to satisfy this recommendation when they are complete.
Recommendation: The Assistant to the Secretary of Agriculture for Rural Development, in cooperation with other members of the tribal infrastructure task force, should direct USDA state offices to identify and pursue additional mechanisms to increase their collaboration. (Recommendation 13)
Agency: Department of Agriculture
Status: Open
Comments: In December 2018, USDA stated that it would send a memo to its state directors and program directors encouraging them to coordinate with tribal governments, IHS, EPA, and other members of the tribal infrastructure task force on funding infrastructure projects. As of December 2019, task force members had drafted a joint memo to distribute to their field offices encouraging additional coordination. We will evaluate USDA's actions in response to this recommendation once they are complete.
