Detailed Information on the
Bureau of Indian Affairs - Tribal Colleges Assessment

Encourage Tribal Colleges to participate in the collection of data in support of the performance measures.

Develop performance goals and measures, baseline information and targets.

Develop a process to encourage Tribes to participate in the collection of information in support of the performance measures.

Develop a process for and schedule independent program evaluations.

Measure: Percent increase in the number of degrees granted by BIE funded and tribally controlled Junior and Senior College/Universities.

Explanation:

Measure: Percent of students in BIE operated colleges that graduate within time frames that are consistent with colleges operating in similar socio-economic conditions.

Explanation:

Is the program purpose clear?

Explanation: The progarm is intended to provide Native Americans with post secondary education opportunities. Native Americans are primarly located on remote Indian reservations with limited access to post secondary schools. The Bureau of Indian Affairs (BIA) role is to promote a progam of comprehensive higher education services of high quality that are financially and geographically accessable that meet individual, business and community needs. The BIA program strives to achieve its purpose through four program elements: (1) undergraduate scholarships (scholarships) for Indian students attending any accredited college or university, (2) direct Federal operations of two post secondary schools named Haskell Indian Nations University and Southwestern Indian Polytechnic Institute (HINU/SIPI), (3) operations grants for 25 Tribally Controlled Colleges and Universities (TCCUs), and (4) special higher education programs (shep) for graduate level studies, for members of a Federally recognized Indian Tribe.

Evidence: P.L. 105-244-Higher Education Amendments of 1998, Title IX PART A Extension and Revision of Indian Higher Education Programs Sec. 901 Tribally Controlled Colleges and Universities, Sec. 902 Reauthorization of Navajo Community College Act; P.L. 95-471 Tribally Controlled Community College Assistance Act of 1978; 25 USC Chapter 20 Tribally Controlled College or University Assistance Sec. 1802 Purpose; 25 CFR PART 41 Grant To Tribally Controlled Community Colleges and Navajo Community College; 25 CFR PART 40 Administration of Educational Loans, Grants, and Other Assistance for Higher Education; 1921 Snyder Act Title 25 USC 13, Expenditure of Appropriations by Bureau of Indian Affairs.

Does the program address a specific and existing problem, interest or need?

Explanation: The program addresses a significant problem for the Native American community, low rates of post secondary education as compared to the non-Native American community. Based on the 2000 Bureau of Census data, approximately 26% of the US white population reported total schooling of a bachelor or graduate degree. By contrast, only 13% of the US American Indian and Alaska Native population reported total schooling of a bachelor or graduate degree. Whites tend to graduate from college and graduate school at twice the rate of American Indian and Alaska Natives. To help bring parity to Indian Country, BIA provides annual financial assistance for approximately 9,500 Indian students seeking undergraduate degrees, direct operations of two post secondary schools (HINU/SIPI) which serve approximately 2,000 Indian students seeking post secondary degrees and training, operational funding for 25 TCCUs which provide college and training to 20,000 Indian students and provides fellowships for 299 Indian students preparing to or attending professional or graduate level schools.

Evidence: P.L. 105-244: P.L. 95-471; 25 USC Sec. 1802; 25 CFR 41; 25 CFR 40; 25 USC 13; Census Data 2000 Educational Attainment.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: BIA's post secondary program provides education services and opportunities to American Indians and Alaska Natives, which do not duplicate other funding sources. These post secondary programs are based on a unique legal and political relationship with Indian tribes over many years. While other Federal funding sources of post secondary programs offer funds to Indian undergraduate students, TCCUs, HINU/SIPI, and graduate level Indian students, these grants or awards are competitive and not awarded because of a legal or political relationships with Indian tribes. BIA's contribution to the TCCUs ranges from 25% to 38% of operating expenses based on specific Tribal authorizations and the number of students attending the respective TCCUs. Since the passage of the TCCU Act, BIA's contribution has provided base funding and the TCCUs have been encouraged to supplement their total funding requirements from other sources and the Equity in Educational Land-Grant Status Act allows for access to the opportunities afforded other institutions.

Evidence: P.L. 105-244: P.L. 95-471; 25 USC Sec. 1802; 25 CFR 41; 25 CFR 40; 25 USC 13

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The program does not appear to have major design flaws. However, TCCU's argue that because appropriations are less, by about one-third, then the annual authorized funding limit they are not able to raise graduate rate. BIA has not been able to demonstrate that additional funding will increase the program's overall effectiveness in raising the number of Indian students receiving bachelor and graduate degrees.

Evidence: BIA formula for HINU and SIPI, TCCU regulations, Scholarship financial unmet need form

Is the program effectively targeted, so that resources will reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: The program is effectively targeted to reach the inteneded beneficiaries -- colleges and students. For HINU/SIPI and TCCUs funds are distributed by formula based on the Indian Student Count (ISC). For undergraduate scholarships (scholarships) for Indian students attending any accredited college or university, funds are distributed from the Tribal Priority Allocation base to the BIA Regional Office where funds are provided to the Tribe via the PL 93-638 Indian Self Determination, Contract and Compact and or Grant process. The Special higher education programs (shep) for graduate level studies are earmark in the budget line item activity Special Program and Pooled overhead for Special Higher Education Scholarship and funds distribution are made under a Grant Process to the American Indian Graduate Center.

Evidence: Fund Distribution Documents (FDD); Tribally Controlled Community College Grant Application OMB # 1076-0018; Grant Agreement/Amendment OIEP FORM 21; Tribal College & University Indian Student Count (ISC) Reporting Form OIEP Form 22; Indian Student Count for FY 04; Higher Education Scholarship Contract Standard Form 30,; American Indain Graduate Center Grant Agreement form/requistion. NCES Profile of Undergraduates in US Postsecondary Education Institutions: 1999-2000.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: BIA has identified new long term and annual measures, which are included in the Department's current strategic plan, for achieving parity between the Tribal community and US rural area national average on college graduation. For the 2005 budget, no efficiency or scholarship measures were identified. In addition, the measures developed do not cover all aspects of academic quality and operational efficiency and the data collection methodology has yet to be developed to ensure that BIA measures are the same as national measures. For example, there are no measurement of student advancement rates; number of transfer students to four-year institutions; first-time, full-time graduation rate after three years; percentage of educational and general activities on instruction and academic support; etc. BIA will be investigating these and other measures as they finalize their performance reporting.

Evidence: Performance measures and 3 year results analysis of degrees conferred. Haskell and SIPI enrollment and graduation data for three academic years

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The new long term measure of achieving parity between Tribal community and US rural area national average on college graduation is an ambitious target, given the fact that based on the 2000 Bureau of Census data, approximately 26% of the US white population reported total schooling of a bachelor or graduate degree. By contrast, only 13% of the US American Indian and Alaska Native population reported total schooling of a bachelor or graduate degree. Whites tend to graduate from college and graduate school at twice the rate of American Indian and Alaska Natives. In terms of obtaining Associate degrees conferred, from 1976-77 to 1997-98 the percentage distribution of degrees conferred indicates 75.7 white compared to 1.1 American Indian/Alaskan Native this is indicative that achieving parity of college graduation is ambitious.

Evidence: Performance measures and 3 year results analysis of degrees conferred. FY 05 Budget submission Appendix 11; Table A Total enrollment Title IV postseconday NCES fall 1998) Table 263- Associate degrees conferred 1976-77 to 1997-98) NCES.

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: GPRA goals and new measures in proficiency for required core courses are as follows:1) Number of Degrees granted by Junior and Senior Colleges and Universities will increase by 2%, 2) Number of students achieving proficiency by passing the two required freshman level English courses or testing out, will increase by X% from the previous academic year and 3) The number of students achieving proficiency by passing the one required freshman level Math course or testing out, will increase by X% from the previous academic year. However, BIA should consideration adding measures on academic quality and operational efficiency, such measures as student advancement rates; number of transfer students to four-year institultions; first-time, full-time graduation rate after three years; space utilization, percentage of educational activities on instruction and academic support.

Evidence: Performance measures and 3 year results analysis of degrees conferred. FY 05 Budget submission Appendix 11

Does the program have baselines and ambitious targets for its annual measures?

Explanation: While the BIA has base line data on graduation rates, base line data for the annual goals are being established in 2004. In addition, measures such as measurement of student advancement rates; number of transfer students to four-year institutions; first-time, full-time graduation rate after three years; classroom and laboratory space utilization, percentage of educational and general activities on instruction and academic support are being added. The data results for the Annual measures will be collected from TCCUs, Haskell and SIPI through the revised TCCU Annual Report form. The Annual Report Form was modified through the Federal Register Notice process to reflect the data collection for revised performance measures.

Evidence: Copy of revised TCCU Annual Report Form; Federal Register Notice.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: All partners in the four elements of the Post secondary programs work towards the education and graduation of Federally recognized Native American students through the fulfillment of the new annual performance goals and then provide performance reporting through the submission of annual reports and surveys.

Evidence: TCCU and survey reports, Higher education annual report, AIGC annual report, Template provided for partner review. Federal Registier Vol.69, No. 74/Friday April 16, 2004 Notices

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: The two post secondary progam elements -- HINI/SIPI and TCCU -- are required to maintain accreditation from a nationally recognized accrediting agency, which are considered independent academic reviews. These accrediting entities require academic accreditation evaluation on a 3-5 year cycle. From the evaluation, any academic deficiences are corrected by the accreditation process. As to the non-academic portions of the program -- scholarship and SHEP -- independent evaluation/reviews have been limited. In addition, evaluations are discouraged under P.L. 93-638. BIA should encourge the colleges to participate in independent reviews of these two program elements.

Evidence: HINU Accreditation reports 9/26/03, SIPI Accreditation Report 2/14/2000; Singel Audit report Oglala Lakota College for FY ended 9/30/2002; Administrative Review current schedule. Independent Compliance panel review 2004

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: While the HINU/SIPI and TCCUs do create performance based budget packages, the scholarship program has focused on cost per student counts and has failed to focus on how the level of funding reflects graduation rates. BIA budget request write-ups will be modified with the FY 2006 budget. The budget will make a presentation based on comparisons in scholarship funding to the number of students that are able to complete their educational objectives and graduate.

Evidence: Appendix 11 of the FY 05 President's Budget Request

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: Additional performance measures to track the proficiency level of students in required courses to assist and correct problem areas and ensure student success have been developed. In addition, scholarship performance measures are to be developed. BIA will also review non-Indian postsecondary education institutions and ensure that in making comparisons with Indian institutions, like measures are being compared.

Evidence: Appendix 11 of the FY 05 President's Budget Request

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: BIA collects and uses performance information to effectively manage the program. The BIA currently collects information from TCCUs and HINU/SIPI on the number of degrees conferred, and they collect an annual program description report on the scholarship program that outlines the results of funding. The BIA will begin collecting data based on the revised TCCU's annual report, for the TCCU's and HINU/SIPI and the HE annual report, to make even better informed decisions about the program. BIA will be reviewing non-Indian post secondary education institutions to ensure that when making comparisons with Indian institutions, that like measures are being compared. In addition, BIA will review measures that both Indian and non-Indian institutions are being asked to provide by other agencies to determine if measures should be added to BIA's list or if BIA measures should be revised to reduce the reporting burden on Indian institutions.

Evidence: TCCU and survey reports, Higher education annual report.

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Although Individual performance plans for the SES personnel include individual GPRA performance measures there is no evidence that the program managers below the SES level have performance measures included in their annual performance plans, and if they did, that BIA actually used these measures in evaluating individuals.

Evidence: Haskell Presidents Performance Plan sample. Directors SES Performance Plan

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: Federal funds are fully obligated annually to grantees. All grants are subject to annual compliance audits under the Single Audit Act. BIA works with grantees to correct any problems identified by audits. No systematic problems have been identified through audits.

Evidence: Copy sample of Grant document and Fund Distrubution Documents. Single Audit.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The BIA is in its first year of collecting cost data and to date no comparative analysis has been done on any of the programs to determine cost effectiveness or efficiencies. However, the BIA has begun working to collect comparative data from community colleges to draw cost and efficiency comparisons for TCCU and HINU/SIPI. BIA expects to have the analysis complete by September and from the analysis develop efficiency measures. Haskell and SIPI currently use student data management systems that are conducive to enhancing the performance of the schools in terms of management information. Haskell uses the Comprehensive Academic Management Systems (CAMS) which functions as an operational information system, and SIPI uses a custom designed management information system software called Student Admissions and Reporting System (STARS) that provides for reports on admission statistics, enrollment, and assessment information etc.

Evidence: Sample table of data to be gathered and analyzed. MIS: STARS and CAMS

Does the program collaborate and coordinate effectively with related programs?

Explanation: Under the Budget Process, BIA collaborates with the Native American Budget advisory council to develop a meaningful budget proposals for all BIA programs. The Education Line Officers collaborates with the local tribes to get input in developing program priorities for BIA. All financial aid offices must keep track of all avenues of funding supplied to applicants to determine eligibility for scholarship funding under HE on the basis of unmet need. This requires that there be constant collaboration with all scholarship and grant programs that offer assistance. Through collaboration with the Small Business Administration, SIPI is developing and implementing a small business development training program targeting American Indian entrepreneurs.

Evidence: Sample Financial Approval Package Form, SIPI/SBA agreement October 1, 2003.

Does the program use strong financial management practices?

Explanation: Contractors must meet the standards for Tribal or Tribal Organization Management Systems, including the Standards for Financial Management systems. Grantees must adhere to Principles for Determining Costs Applicable to Grants. HINU/SIPI adheres to the Federal Finance System (FFS), and the Bureau received a clean audit on financial practices in FY 2003.

Evidence: 25 CFR Subpart A General provision Part 900 ; Copy of the latest Bureau Annual financial report

Has the program taken meaningful steps to address its management deficiencies?

Explanation: HINU/SIPI have implemented an independent personnel system under PL 105-337, the Administrative Systems Act of 1998, 112 Stat.3171, to improve hiring practices. The deficiencies were, that the personnel system was not addressing the needs of the HINU&SIPI. To effectively and efficiently provide quality post secondary education, the institution must employ top-quality faculty, administrators, support staff and technical/specialist workforce. Hiring restrictions and overly complex job classifications unduly exhaust valuable resources (staff, time, and budget), and unnecessarily detract attention from the institution's educational mission.

Evidence: PL 105-337 Haskell Indian Nations University and Southwestern Indian Polytechnic Institute Administrative Systems Act of 1998; 25 CFR 38.15 Southwestern Indian Polytechnic Institute

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: Administrative Reviews are conducted by the Deputy Director with a team that includes Education Line Offices and program specialist, this review includes HINU and SIPI. Reviews of the Annual Reports are conducted and monitoring procedures are in place for all Grantees. The Audit and Evaluation office tracks all single audit report as submitted, and collaborates with Grant officer and the grantee to resolve material weakness identified in the audit. Further, the BIA requires the Grantees to submit a performance report.

Evidence: Annual Report, Monitoring Schedule with check list of compliance reviews.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: The graduation results are collected through the TCCU Annual Report form and on the GPRA performance reports. The BIA provides copies of the overall performance report to all Central Office and Field Directors and final performance information is reported in the Performance and Accountability Report for DOI.

Evidence: GPRA data collection forms, Sample Performance Report, 2003 PAR

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: Based on the results of the annual data collected, the program has demonstrated some progress. However, BIA has and continues to develop new performance measures and baselines to better demonstrate program progress. If these new measures were in place, BIA still does not have the data to demonstrate progress.

Evidence: BIA Performance Reports; 2003 PAR; Performance reports from Green book, Continued accreditation of TCCUs and Postsecondary

Does the program (including program partners) achieve its annual performance goals?

Explanation: The results of the annual data collected from all programs shows the BIA has achieved its annual performance goals on degrees conferred. While BIA does has base line data for graduation rates and accreditation the collection methodoloy and measures need to be reviewed to ensure they are the same script as non-Native American institutions. BIA is establishing base line data for the new proficiency goals during FY 2004, and will ensure that all the new measures collected to compare Indian institutions with non-Indian institutions will have the same definition data collection scripts.

Evidence: BIA Performance Reports; 2003 PAR.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: BIA is developing efficiency measures.

Evidence: AIHEC contract, AIGC grant; On-line/Distance learning (Bay Mills, SIPI. HINU)

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: A current study available on NCES_IPEDS shows that Bureau Community colleges compare favorably to similar rural community colleges on their individual graduation rates. The BIA will be tracking parity with US rural average for graduation through the DOI strategic plan, however, the Department of Education has not finished establishing their baseline level for a national graduation rate and necessary statistical data will not be available until late in calendar year 2004 to develop a comparison based upon community college achievements.

Evidence: DOI's strategic plan. NCES-IPEDS comparsion of data of selected community colleges

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: Accreditation reviews are done by recognized accrediting associations. All of the programs are responsible for obtaining audits in accordance with the Single Audit Act Amendments of 1996 (31 U.S.C. 7501et. Seq.). As to the non-academic portions of the program, scholarship and SHEP, no independent evaluation/reviews are required and, infact, are discouraged under P.L. 93-638. However, one review was conducted on the Scholarship program by an outside entity. The review was conducted by Kate Sildes of NIGA and evaluated such areas as Federal commitment to education, expected growth in college enrollment, the rising cost of higher education, comparison of the BIA Scholarship program to National benchmarks, in which the only disparity seems to be the low level of resources to address the needs of all grant requests. At least one independent evaluation was conducted on TCCUs in 2004 which included an independent panel that reported compliance with P.L. 95-471

Evidence: Sample copy of accreditation report; Sample of Single Audit. Independent Compliance panel review 2004.