Blueprint for Reform

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Findings and Recommendations Prepared by the Bureau of Indian Education Study Group
Submitted to the Secretaries of the Departments of the Interior and Education
Date: June 27, 2014
“Education is how we lift people from poverty to a bright future … The only way
to lift people out of poverty is to give them an education that honors their culture,
their identity, and who they are as human beings.”
- Sally Jewell, Secretary of the Interior
“The President and I believe the future of Indian Country rests on ensuring that
your children receive a high-quality education. Improving academic outcomes for
Native American children has never been more important. Unfortunately, too
many Native American children are not receiving an education that prepares them
for college and career success, too few of them are going to college, and far too
many of them drop out of high school. We need to do better.”
- Arne Duncan, Secretary of Education
“If we’re going to be in control of our destiny, then we have to be in control of
our own education.”
-Everett Chavez, Governor, Pueblo of Kewa
“What I believe should be the ultimate role of the BIE: to encourage tribes and
tribal communities to take over their schools and run those schools themselves.
BIE’s efforts should be to fulfill the goals of the TCSA.”
- Bryan Brewer, President, Oglala Sioux Tribe
The Bureau of Indian Education (BIE) – housed in the U.S. Department of the Interior (DOI) – is
the legacy of the Indian boarding schools established by the Department of War in the mid-19th
Century. The Federal Government created the boarding schools as part of a larger assimilation
policy that sought to eradicate Native cultures and languages through Western education. Many
of the children who attended Government-run boarding schools were taken forcibly from their
homes and sent to schools hundreds or thousands of miles away in an attempt to separate them
from their families and cultures. Over time, the schools evolved, many becoming day schools
for the children in nearby tribal communities. Slowly, educators and the Government began to
recognize that assimilation was not the answer, and that tribes possess vast cultural resources
that might be completely lost if not fostered both in tribal communities and in schools. The
Government ended the devastating policy of assimilation, but sought to fulfill its treaty
obligations and trust responsibility to tribes by continuing to provide and fund education to
Native students.
Although the Federal assimilation policy ended several decades ago, BIE schools – still funded
and many still operated by the U.S. Government – have produced generations of American
Indians who are poorly educated and unable to compete for jobs, and who have been separated
for years from their tribal communities. All of this has contributed to the extreme poverty on
many reservations throughout the country. This Administration is determined to address this

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stain on our Nation’s history by turning the BIE into an organization dedicated to supporting
each tribe’s capacity to educate future generations of students who are prepared for college
and career and know and value their heritage. Therefore, Secretary Sally Jewell of the U.S.
Department of the Interior and Secretary Arne Duncan of the U.S. Department of Education
(ED) have formed an American Indian Education Study Group, consisting of academics, school
practitioners, lawyers, and experts in American Indian affairs.
I. Executive Summary
After several discussions with tribal leaders regarding systemic issues within the BIE, in
September 2013, Secretary of the Interior Sally Jewell and Secretary of Education Arne Duncan
appointed the American Indian Education Study Group (Study Group). They directed the Study
Group to diagnose the causes of too common academic failure in BIE-funded schools, which are
some of the lowest performing schools in the country. Charged with developing and
implementing recommendations to transform the BIE, the Study Group combines management,
legal, education, and tribal expertise to ensure that the Study Group’s recommendations are
grounded in a comprehensive, institutional understanding of how schools work, how effective
teaching and learning occur, and American Indian affairs.1
Based on extensive listening sessions in fall 2013 with tribal leaders, educators, and community
members across Indian Country, and analysis of a wide range of primary and secondary data,
the Study Group proposed to tribal leaders a redesigned BIE. The redesigned BIE reflects its
evolution from a direct education provider to an expert service and support provider, which
promotes self-governance and self-determination through tribal operation of schools. The Study
Group conducted four tribal consultations on its proposal in spring 2014. The redesign seeks to
achieve one overarching goal: that all BIE students receive a world-class education delivered by
tribes and supported by the Department of the Interior.
The Study Group, based largely on written comments and feedback received during tribal
consultations, recommends that the BIE focus on fostering five areas of reform:
Highly Effective Teachers and Principals – Help tribes to identify, recruit, develop, retain, and
empower diverse, highly effective teachers and principals to maximize the highest achievement
for every student in all BIE-funded schools.
Agile Organizational Environment – Build a responsive organization that becomes an expert
in its field and provides resources, direction, and services to tribes so that they can help their
students attain high levels of achievement.

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The Study Group is chaired by the Assistant Secretary – Indian Affairs, Kevin Washburn, and members include
Charles Roessel, the Director of the Bureau of Indian Education; William Mendoza, Executive Director of the White
House Initiative on American Indian and Alaska Native Education; Charles Rose, former General Counsel of the
U.S. Department of Education; Marilee Fitzgerald, former Director of the Department of Defense Education
Agency; Kenneth Wong, Chair and Professor of the Department of Education at Brown University; and Don Yu,
Special Advisor to Secretary Duncan.

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Promote Educational Self-Determination for Tribal Nations – Strengthen and support the
efforts of tribal nations to directly operate BIE-funded schools.
Comprehensive Supports through Partnerships – Foster parental, community, and
organizational partnerships to provide the academic as well as the emotional and social
supports BIE students need in order to be ready to learn.
Budget that Supports Capacity-Building Mission – Develop a budget that is aligned with and
supports BIE’s new mission of tribal capacity-building and exchanging best practices.
Once reformed, the redesigned BIE will sharpen the education priority within the Office of the
Assistant Secretary – Indian Affairs by realigning existing staff positions and resources to
support tribes in building the capacity of their schools, particularly in the areas of talent
acquisition and management, strategic and financial management, and instructional
improvement. Its organization and budget will be aligned to its new structure, providing greater
flexibility and freeing resources to support much-needed educational reforms. Further, departing
from the “command and control” culture that is often driven from Washington, DC, the
redesigned BIE will facilitate sharing of effective practices among tribally-controlled and BIEoperated schools and open up new opportunities in tribal communities to broaden and sustain
school improvement in Indian Country. Finally, the new BIE will promote tribal selfgovernance and self-determination by encouraging tribes to operate BIE-funded schools, while
continuing to fulfill its trust responsibility and treaty obligations.
This report will discuss the nature of the systemic challenges facing the BIE, including insights
and input from numerous tribal listening sessions and consultations the Study Group conducted
across the country (see Appendix A). It will then detail the Study Group’s recommendations in
each of the key areas of reform, highlighting relevant input received in each area of reform. The
Study Group hopes the Secretaries will benefit from these recommendations as they proceed to
formulate policies for BIE and related American Indian education programs.
II. The Urgent Case for Reform
The BIE has never faced more urgent challenges. These challenges include difficulty in
attracting effective teachers to BIE schools located in remote locations, achieving compliance
with academic standards in 23 different states, promoting research-based reforms in tribally
controlled schools, resource constraints, and institutional and budgetary fragmentation. Both a
lack of consistent leadership and strategy – which is evidenced by the BIE having 33 Directors
since 1979 – and an inconsistent commitment from political leadership, have hampered the BIE’s
ability to improve its services. While operation of Federal Indian education has been transferred
to tribes in approximately two-thirds of BIE schools, the BIE has not been adequately
restructured to recognize its new primary role of supporting tribal programs (rather than being
the primary provider of Indian education). Each of these challenges has contributed to poor
outcomes for BIE students and has made it increasingly difficult for BIE leadership to deliver the
resources and support tribes need for their schools to be successful.

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A.

Concentrated Poverty Coupled With Geographic Isolation

Many American Indian students in tribal communities face unique educational challenges,
including severe poverty. For instance, according to the U.S. Census, four of the Nation’s five
poorest counties overlap at least partly with American Indian reservations. These communities
experience a high rate of unemployment and a higher concentration of residents who are
18 years old or younger. For example, the Pine Ridge community experiences an 80 percent
unemployment rate and the per-capita income is less than $8,000 a year. In an interview with
Education Week, the executive director of the Oceti Sakowin Education Consortium (a group
representing tribal schools on Pine Ridge and other South Dakota reservations) described the
schools’ challenge: “[W]e have a lot of young people on the reservation and not nearly enough
jobs. So that presents challenges to us as educators when we are trying to convince our young
people to stay in school, to do well in school, to graduate, to go on to college.”2 This chronic
high unemployment contributes to substance abuse and domestic violence in tribal communities,
factors which present additional obstacles to quality education.
Geographic isolation also contributes to the lack of economic opportunity in tribal communities.
Many reservations are located at great distances from cities and do not benefit from the private
investment and market-based resources that other communities receive. The remote location of
many BIE-funded schools makes it difficult to recruit effective teachers and leaders and to
provide them with ongoing professional development. At the same time, remote locations also
hamper the delivery of needed complementary services.
B.

BIE Students Perform Worse than American Indian Students Attending
Public Schools.

Students in BIE schools perform consistently below American Indian students in public schools
on national and state assessments. For example, based on estimates from a 2011 study using data
from the National Assessment on Educational Progress (NAEP), BIE 4th graders scored on
average 22 points lower in reading and 14 points lower in math than Indian students attending
public schools.3 The gap in scores is even wider when the average for BIE students is compared
to the national average for non-Indian students.4 Furthermore, in reviewing the data on Adequate
Yearly Progress (AYP) in 2012-13 (see Appendix C), the Study Group found that only one out
of four BIE-funded schools, including both tribally-controlled and BIE-operated schools, met the
state-defined proficiency standards. These performance indicators suggest that factors about the
BIE system compound the social and economic disadvantages in Indian Country.

2

Education Week, December 4, 2013, p. 18.
U.S. Department of Education, Institute of Education Sciences, National Center for Education Statistics, National
Assessment of Educational Progress, 2011.
4
Ibid.
3

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C.
BIE Students Perform Worse than Students Attending Department of
Defense Schools and Other Schools with High Minority Populations.
Student outcomes in the two sets of schools funded by the Federal Government – the BIE
and Department of Defense Educational Activity (DODEA) – are dramatically different.
For instance, in 2009, DODEA 4th graders outscored their BIE counterparts by 33 points in
math and by 47 points in reading on the National Assessment for Educational Progress (NAEP).
The DODEA 8th graders outscored BIE 8th graders by 39 points in math and 43 points in
reading. These scores place BIE students at approximately the 13-17th percentiles in the entire
U.S. (and DODEA students at the 49-57th percentiles). Furthermore, when compared to the
18 urban school districts with high minority populations that were selected for NAEP’s Trial
Urban District Assessment, the BIE underperformed all of these school districts except for
Detroit Public Schools.5
D.

Despite the Bureaucracy and Lack of Support, There are Indications of
Progress.

In a recent study by the Northwest Evaluation Association, student achievement “appears to have
improved, most notably in math and for students in lower grades. So, while student achievement
[in BIE schools] still trails that of other students across the United States as of 2012-13, [the
NWEA test] results appear to indicate that student achievement in most grade and subject areas
seems to be trending upward (or remaining stable) from prior years.” This is important because
it indicates that, when education leadership uses diagnostic tools to address students’ academic
weaknesses, improvements in student achievement occur.
This pattern is reflected in two particular examples concerning BIE-funded schools. Dibe Yazhi
Hablti’n O’lt’a, Inc., is a tribally controlled school that had a history of poor academic
achievement in mathematics and reading. When new leadership arrived and helped educators
there organize around the NWEA assessment system, profound improvements in student
achievement followed tremendous academic growth across the school year. Years of stagnation
were replaced with dynamic improvement.
Likewise, NWEA has been a staple of the education program at Nenahnezad, a BIE-operated
school. Because of the school’s leadership and reliance upon diagnostic data to guide
instruction, Nenahnezad consistently out-performs all other elementary schools in the region,
public and private included. In 2012-13, students attending Nenahnezad Community School
were among the highest performers participating in the NWEA’s subset of BIE schools and have
consistently improved or maintained performance since 2009-10 in both math and reading.6
These examples of successful progress show us that improvement is possible and that BIE must
adapt to better support schools and tribes in their efforts at improvement.

5

U.S. Department of Education, Trial Urban District Assessment, the Nations’ Report Card.
Bureau of Indian Education Report on Student Achievement and Growth: 2009-10 to 2012-13, Northwest
Evaluation Association, February 2014.

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III.

Institutional and Budgetary Fragmentation and Legal Provisions Prevent the
Adoption of Research-Based Reforms.

As discussed further below, after reviewing several studies on the BIE and meeting with
numerous stakeholders, it is the Study Group’s conclusion that organizational and budgetary
fragmentation and several legal provisions prevent the BIE from adopting and implementing
significant reforms and limit the BIE’s ability to provide the support that its schools need in
order to be successful.7
A.

Recent Reports Identify Key Management Issues Impacting Delivery of
DOI’s Educational Services.

The Study Group reviewed and accepted the findings and recommendations of two recent
reports: (1) the March 2012 Bronner Final Report (the Bronner Report);8 and (2) the Government
Accountability Office Report 13-774, “Better Management and Accountability Needed to
Improve Indian Education” (the GAO Report).
1. The Bronner Report States that Differences Between BIA and BIE
Missions Impairs BIA’s Ability to Effectively Deliver Support Functions
to BIE.
The Bronner Report found that the Indian Affairs’ Office of the Deputy Assistant Secretary for
Management (DAS-M) and the Bureau of Indian Affairs (BIA) face enormous challenges across
a wide range of core support functions and casts doubt on whether the BIA can manage and
support the BIE effectively. Notably, the Bronner Report states that the “BIA and BIE are
dramatically different from both mission and operational perspectives. As a result, points of
view concerning support function effectiveness do not necessarily originate from a similar
organizational culture or mindset.”9
This difference in mission goals and operational perspectives between the DAS-M’s office, BIA,
and BIE causes shortages and unmet needs at the school level. For instance, the Bronner Report
states that the BIA’s procurement office fails to distinguish between the needs of a school system
and that of a Federal agency, which causes a failure to timely deliver services, supplies, and
textbooks during the time schools are in session.10
This difference also manifests itself when DAS-M employees conduct the hiring of BIE
principals, teachers, and other educational specialists. The Bronner Report discusses the

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The Study Group will be proposing several amendments that would address some of these statutory provisions.
U.S. Department of the Interior, Bureau of Indian Affairs, Final Report: Examination, Evaluation, and
Recommendations for Support Functions, Bronner, 2012, p. 11, available at
http://www.bia.gov/cs/groups/public/documents/text/idc017342.pdf .
9
Ibid. p. 11
10
Ibid, p. 54.
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perceived lack of understanding, on the part of DAS-M staffing specialists, regarding the
qualifications for reading specialists and special education teachers.11
One report found that there is a large number of outstanding school maintenance projects,
including many that involve safety violations in schools. 12 It also found that, if DOI were to
replace or perform building rehabilitation on all of the 68 highest-risk school facilities, it could
cost an estimated $1.3 billion.13
2. GAO Report Indicates that DOI has Difficulty Delivering Administrative
Services to BIE.
The GAO Report, dated September 13, 2013, documents similar management and operational
issues within the BIA, the DAS-M’s office, and BIE, noting that “[f]ragmented administrative
services and a lack of clear roles for BIE and Indian Affairs’ Office of the [DAS-M] …
contributed to delays in schools acquiring needed materials, such as textbooks.”14
Among other recommendations, the GAO recommended that DOI revise its “strategic workforce
plan to ensure that employees providing administrative support to BIE have the requisite
knowledge and skills to help BIE achieve its mission and are placed in the appropriate offices to
ensure that regions with a large number of BIE schools have sufficient support.”15 The GAO
also recommended that DOI develop a strategic plan that includes detailed goals and strategies
for BIE and for those offices that support BIE’s mission, including BIA, to help Indian Affairs
implement realignment.16
After the GAO Report was released, the Appropriations Committees, in their Joint Explanatory
Statement on the Consolidated Appropriations Act, 2014, stated their expectations that DOI
implement certain management reforms:
The Committees are concerned that management challenges within the
Department, the Bureau of Indian Affairs, and the Bureau of Indian Education
(collectively, “Indian Affairs”), as identified in a September 2013 report by the
Government Accountability Office (GAO-13-774), may impact the overall
success of the students in the system. Although the Committees are
encouraged that Indian Affairs concurred with all of GAO’s recommendations
and that a full-time director of the Bureau of Indian Education is in place after
a vacancy of more than a year, the Committees expect the Secretary to oversee
implementation of these management reforms.17
11

Ibid, p. 89.
Ibid.
13
Ibid, p. 80.
14
U.S. Government Accountability Office. Better Management and Accountability to Improve Indian Education.
Government Printing Office, Month 2013, p. 1.
15
Ibid, p. 27.
16
Ibid, p. 27.
17
Explanatory Statement on H.R. 3547, the “Consolidated Appropriations Act , 2014”, (P.L. 113-76, Jan. 17, 2014);
Jan. 15, 2014 Cong. Rec. at H975.
12

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B.

Study Group’s Listening Sessions Build on the Findings in the Bronner and
GAO Reports.

Using the recommendations in the Bronner and GAO Reports as a foundation, the Study Group
then conducted additional, first-hand listening sessions in South Dakota, Mississippi, Oklahoma,
Washington, New Mexico, Arizona, and Washington, DC (see Appendix A for participants in
the listening sessions). The Study Group met in person with over 300 stakeholders, including
BIA and BIE staff, principals and teachers at numerous BIE-funded schools, tribal leaders, and
national organizations such as the National Congress of American Indians and the National
Indian Education Association. The Study Group also set up an e-mail account
(IAEDSolutions@BIA.Gov) where it received over 150 comments that contained
recommendations regarding how the BIE could improve the delivery of educational services
(see Appendix B for illustrative e-mail comments). The Study Group then received additional
feedback during the consultations it conducted in April and May 2014.
In general, the recommendations the Study Group received from stakeholders mirrored some of
the recommendations cited in the Bronner and GAO reports. For instance, the Study Group met
with dozens of principals of BIE-funded schools who largely complained that the BIE’s
complicated bureaucracy made school operations so disorganized and inefficient that it
prevented them from focusing on their primary mission of instructional leadership. Many
expressed frustrations regarding the DAS-M’s office and the BIA, and the BIE’s inability to
affect operational decisions made by the BIA, especially regarding major repairs to school
buildings. Numerous principals complained about overly burdensome regulatory requirements
and that they routinely had to respond to duplicative data calls from different offices within the
BIE, including the Division of Performance and Accountability and the Associate Deputy
Director Offices. Numerous stakeholders also complained about the BIE’s “command and
control” culture, its poor customer service, and the need for BIE to focus itself on supporting
tribes in building the capacity of their schools.
Additional concerns from the listening sessions in Indian Country included:
● Many school facilities are in poor and failing condition and not conducive to a 21st Century
teaching and learning environment;
● Many principals and teachers expressed concerns that funding appropriated by Congress to
the BIE is not reaching the school level and may be paying for unnecessary overhead costs;
● BIE schools have difficulty recruiting and retaining effective teachers and leaders due to the
remote location of their schools, lack of teacher housing, and poor school conditions;
● BIE programs and policies are too restrictive and prevent schools from implementing Native
language and culture classes;
● Principals and teachers feel unprepared for implementation of the Common Core State
Standards (CCSS) and schools lack the information technology (IT) infrastructure to
administer cutting-edge assessments aligned with the CCSS;
● BIE and BIA are sometimes unresponsive to BIE schools’ requests for assistance regarding
alternative definitions of Adequate Yearly Progress (AYP) accountability workbooks, and
facility repairs; and

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● School boards and tribal councils lack training on their roles and responsibilities, often
micromanage day-to-day affairs at schools, and are not prepared to make effective and
efficient hiring decisions.
It is clear from the comments received that stakeholders continue to express frustration and
confusion about the BIE school system and the roles of schools, principals, BIE, BIA, DAS-M,
DOI, and ED. In addition, it is important to note that the Study Group encountered many DOI
and BIE employees who were extremely committed to their jobs and remarkably talented. In
many cases, employees were performing at impressive levels given the constraints placed on
them.
C.

The BIE Fragmented and Prescriptive Budget Cannot be Used Strategically
to Support School Reforms.

The Study Group analyzed the BIE budget structure and found it to be highly fragmented and
prescriptive. Specifically, the BIE annual budget typically consists of 46 different budget subactivities, and the BIE receives this funding from Congress through multiple sources (ED, Health
and Human Services, BIA and DAS-M). Furthermore, approximately 99 percent of the BIE’s
funding is formula-based and designated directly to schools. The BIE has no direct access to
these funds, leaving the BIE Director with less than 1 percent of the total budget for
discretionary purposes. This is in sharp contrast to a typical school district, where the school
board and the superintendent would maintain 12 to 15 percent of funding for discretionary
purposes. The lack of discretionary allocation authority substantially weakens the BIE’s ability
to exercise strategic leadership or achieve educational priorities. In other words, the BIE budget
structure reduces the BIE to a mere pass-through and constrains the BIE’s ability to leverage the
funding it provides to schools to drive reforms.
Moreover, due to a unique provision in the Tribally Controlled Schools Act, tribally controlled
schools are permitted to retain Federal carry-over funds and also place any current or carried
over grant funds in interest-bearing accounts prior to expenditure. In other words, the Tribally
Controlled Schools Act provides an incentive for tribally controlled schools not to spend funding
they receive from BIE and ED. Under the Act, schools already may spend any interest income
earned on any school costs, but must spend the principal in accordance with the purposes of the
respective programs. The BIE has contributed to this issue by not implementing policies that
encourage schools to fully utilize funds and discourage schools from planning for carry-over.
According to our review of Fiscal Year (FY) 2012 A-133 audits of tribally controlled grant
schools, a substantial amount of carry-over funds exists in some schools. For instance, although
the audit information is incomplete, approximately 80 BIE-funded tribally controlled schools
have retained approximately a total of $125 million in unspent funds that have accumulated over
time. The ED and BIE should provide tribes with technical assistance and practical guidance
with respect to the activities and projects for which these can be expended under current laws.

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D.

The Self-Determination Context of BIE’s Unique School System Challenges
DOI to Deliver Services and Resources to Tribally Controlled Schools Using
Different Models.

In addition to organizational and budgetary fragmentation, important Federal Government
principles unique to the field of Indian affairs challenge the BIE to improve performance in its
schools with specialized attention.
1. Mandates are Inconsistent with the Purpose of the Tribally Controlled
Schools Act.
The DOI fully supports the principles of self-determination that are embedded in the Tribally
Controlled Schools Act (TCSA) and the Indian Self-Determination and Education Assistance
Act. The TCSA prohibits DOI from issuing regulations that address the planning, development,
implementation, and evaluation of the Tribally Controlled School Act grants.18 In general, if a
tribally controlled school meets the statutory eligibility requirements (generally financial in
nature), the Secretary of the Interior must continue to provide the school with funding.19 As a
result, DOI cannot, for example, require tribally controlled grant schools to adopt a performancebased evaluation system that includes student achievement as a measure, or remove chronically
ineffective full-time employees (FTEs) from BIE-funded schools. This is not just an issue
important to the BIE; tribes similar challenges in holding their tribal schools accountable. As
discussed in further depth below, the Study Group recommends that the BIE provide incentives
to tribally controlled schools, since such an approach is more closely aligned with the purpose of
the Tribally Controlled Schools Act.
2.

BIE is not eligible for certain Federal programs that provide
assistance to states and local school districts.

The BIE has been ineligible to participate in several funding opportunities available only to State
Educational Agencies (SEA) and Local Education Agencies (LEA). Lack of access to certain
programs that are designed to build SEA and LEA capacity further constrains DOI’s ability to
reform the BIE-funded schools. The ED and DOI have already agreed to explore potential
avenues to increase the resources that are available to BIE for that purpose.
3.

Appropriations Legislation Generally Prohibits BIE from Funding
New Charter Schools.

Public Law 112-14 generally prohibits BIE from funding any new charter schools (some were
already in existence prior to 1999): “Funds made available under this Act may not be used to
establish a charter school at a Bureau-funded school (as that term is defined in section 1141 of
the Education Amendments of 1978 (25 U.S.C. § 2021)), except that a charter school that is in

18
19

25 U.S.C. § 2509.
25 U.S.C. § 2505.

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existence on the date of the enactment of this Act and that has operated at a Bureau-funded
school before September 1, 1999, may continue to operate during that period…”
Several tribes are already operating charter schools under applicable state charter school
legislation. The Study Group encourages the Department to consider changes in future budget
proposals that would indicate support for tribally controlled, operated and funded charter schools
in states that authorize charter schools. If legislation is amended to allow BIE to fund additional
charter schools, we would also propose the Department evaluate charter school funding requests
on a case-by-case basis to ensure alignment with state charter requirements and in a manner that
would prevent duplicative funding, dilution of per student funding and is consistent with
legislation that addresses grade expansion. Such an assessment conducted on a case-by-case
basis would also ensure that tribal education priorities are preserved.
IV.

Recommendations for Transforming the BIE

Federal efforts in American Indian education have been fraught with the legacy of boarding
schools and the lack of consistent leadership and long-term strategy for the BIE. As in all other
areas of Government services, Federal American Indian programs generally work best through
tribal self-determination, when tribal institutions are enlisted to direct them. The goals for the
BIE that are presented in Section I of this report are aligned with President Obama’s agenda to
(1) ensure that our Nations’ students are ready for college and careers; and (2) promote tribal
self-determination. Accordingly, in order for the BIE to achieve these goals, it must shift
significant attention towards providing the services, resources, and technical assistance that
tribes need in order to operate high-achieving schools, while also ensuring quality education in
the remaining BIE-operated facilities.
A.

A Federal and Tribal Vision: A World-Class Instruction for All BIE
Students Delivered by Tribes

Support tribes in their efforts to ensure that all BIE students are well-prepared for college,
careers, and tribal citizenship.
If redesigned, the BIE can help provide the services, resources, and technical assistance that
tribes need in order to directly operate high-achieving schools. In turn, this restructuring will
result in schools that can adequately prepare their students for college and the workforce. The
BIE should also provide tribes with high quality professional development in the areas of parent
involvement, Common Core State Standards, high quality assessments, integration of language
and culture, and effective use of data in decisionmaking. The Study Group envisions a
redesigned BIE becoming a resource center and provider of technical assistance to all tribally
controlled schools.
A redesigned BIE must also make instructional improvement a top priority. High performing
school systems have focused on multiple instructional improvement strategies, including:
improving the curriculum through the adoption of the Common Core State Standards and aligned
high quality assessments; implementing job-embedded professional development (e.g., using
technology to deliver support) with coaches (essential for the remote and geographical dispersion
of its schools); and supporting/enhancing the skills of principals and other school leaders to

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effectively evaluate teacher performance. These reforms recognize that delivering excellent
instruction requires teachers and principals to develop a repertoire of technical and strategic
instructional and leadership skills. Further, turnaround research has found that the best
performing school systems intervene at the level of the individual student, developing processes
and structures within schools that are able to identify whenever a student is starting to fall
behind, and then intervening to improve that child’s performance. There are strategies that
schools can use to compensate for the disadvantages resulting from some students’ home or
community environment.20
As discussed above, to achieve world-class instruction for all BIE students, the Study Group
proposes that DOI focus on the following five core areas of reform: (1) highly effective
teachers and principals; (2) agile organizational structure; (3) promotion of self-governance;
(4) comprehensive supports through partnerships; and (5) budget aligned with previously
stated priorities. The five core areas of reform are discussed further below:

20

How the World’s Most Improved School Systems Keep Getting Better, McKinsey & Company, November 2010.

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B.

Reform Area One: Highly Effective Teachers and Principals

Help tribes to identify, recruit, develop, retain, and empower diverse, highly effective
teachers and principals to maximize the highest achievement for every student in all
BIE-funded schools.
Student outcomes can improve only with changes in classroom teaching and learning. While
research has suggested many ways to improve a school system’s outcomes for students, three
factors matter most: (1) hiring effective teachers and principals; (2) developing teachers and
principals continuously; and (3) providing targeted support to ensure every child can benefit
from high quality instruction. Research demonstrates that the main driver of the variation in
student learning at school is the quality of teachers and principals. Seminal research based
on data from Tennessee showed that if two average 8-year old students were given different
teachers – one of them a high performer, the other a low performer – their performance deviated
by more than 50 percentile points within 3 years.21 Effective principals are also critical to
student achievement. Replacing an “average” principal with an outstanding principal in an
“average” school can increase student achievement by over 20 percentile points.22
There is no one-size-fits-all model of reforms for low performing school systems. The reform
literature suggests that the starting point for a school’s improvement is a deliberate examination
to determine its deficiencies and its capacity to reverse its own course. From this process, each
school develops a school improvement plan that applies best practices and interventions that
meet the unique needs of each school. Accordingly, the Study Group’s recommendations focus
on how a redesigned BIE can help tribes recruit, hire, and develop effective teachers and leaders
(new and tenured), and promote teacher and school accountability. Such support from the BIE
will include innovative recruitment and outreach, professional development, collaborative
practice, coaching, career tracks, rigorous certification and selection requirements, and sustained
support from the BIE to tribes.
Because talent recruitment is a serious challenge in many rural BIE and tribally controlled
schools, the Study Group recommends that the BIE focus on developing the skills of current
instructional staff by providing them with robust, sustained professional development, including
incentives for teachers to enroll in the National Board Certification program. The BIE should
also implement a portfolio of talent recruitment, retention, and career development strategies.
Such a plan may include several components, including a gap analysis between academic needs
and the supply of qualified teachers by subject areas, creating housing and other incentives for
potential teachers, and supporting a school climate that is conducive to teaching and learning.
During recent consultations, several BIE stakeholders emphasized that the lack of adequate
housing for teachers on reservations was the most significant challenge they faced when trying to
recruit teachers to their schools. These stakeholders requested that the BIE and ED provide them
with greater flexibility to spend Federal education funding on capital investments such as teacher
housing.
21
22

Sanders and Rivers, Cumulative and Residual Effects of Teachers on Future Academic Achievement, 1996.
Marzano, Waters, McNulty, School Leadership That Works: From Research to Results, 2005.

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An essential element of developing instructional and leadership talent capability is a
performance-based teacher and principal evaluation and support system that has multiple
measures, including student growth, to inform professional development. The BIE is currently
piloting such an evaluation system in BIE-operated schools in two of its regions and intends to
scale up implementation of this system to BIE-operated schools in the Eastern region during the
next school year. Based on the implementation experience during the pilot phase, the Study
Group supports sharing the successes of the performance-based evaluation system with tribally
controlled grant schools for their consideration in the near future. At the same time, the Study
Group recognizes that the BIE may need to provide incentives to tribally controlled schools to
highlight the opportunities of adopting such a system.
The Study Group also recommends a system of performance-based evaluation for non-certified
staff, including business managers/personnel, home living specialists, food services
supervisors/leads, school transportation leads, and facility managers. This system would enable
schools that have experienced enrollment declines in the classroom to identify its most effective
staff in the face of required cuts.
The Study Group analyzed the staff-to-student ratio across all BIE-funded schools (see
Attachment D). For BIE-operated day schools, the ratio of certified teaching staff to students
was 1 to 10. However, the ratio was lower in tribally controlled day schools, which had an
average of 1 certified teaching staff to 8.7 students. Similar patterns were found regarding the
ratio between non-certified employees and students. In BIE-operated day schools, that ratio was
1 to 5.2, as compared with a ratio of 1 to 4 in tribally controlled day schools. In other words,
when faced with a declining enrollment, tribal school boards would be able to make hiring
adjustments, informed by staff performance, especially in the non-certified positions.
During recent tribal consultations, several BIE stakeholders stated that some BIE schools have
high numbers of non-certificated staff due to lack of access to services that are available to other
school systems. School staffing decisions must take into account the unique circumstances of
each school. For instance, because many of these schools are located in remote regions, they
must hire water technicians, firefighters, boiler operators, plumbers, electricians, and carpenters.
In addition, BIE operates 65 facilities with residential programs that require full time staffing
24 hours a day, 5 to 7 days a week. Critically, however, BIE lacks the ability to ensure that
tribally controlled schools adopt certain human capital reforms, including performance-based
evaluations tied to student achievement. Accordingly, as discussed in greater detail in Section D
below, the Study Group recommends that Congress provide BIE with incentives to promote such
school improvement efforts in tribally controlled schools.

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Human Capital Recommendations:
● Improve BIE’s existing internal capacity to provide technical assistance to tribes around
professional development, modeling, coaching, and the monitoring and evaluating process;
● Upgrade the skills of existing teachers and principals (e.g., instructional coaches at the school
level, professional development focused on differentiated instruction, project-based learning,
and cooperative learning) by providing incentives for instructional staff to voluntarily enroll
in the National Board Certification program and professional development process;
● Improve BIE’s ability to help tribes develop and resource talent management and acquisition
programs within tribal educational agencies;
● Create new, high quality teacher pipelines from colleges, including tribal colleges and
universities (TCUs), to BIE schools by providing TCUs with support to improve and expand
effective teacher education programs;
● Provide incentives to recruit effective teachers and principals (e.g., allow schools to spend
funding on teacher housing, providing housing stipends, loan forgiveness, and educational
benefits);
● Provide incentives to tribes to adopt certain staffing formulas and performance-based
evaluations that are tied to student achievement; and
● Ensure appropriate reward and remuneration structure for teachers and principals.
C.

Reform Area Two: Agile Organizational Environment

Build a responsive organization that provides resources, direction, and services to tribes so
that they can help their students attain high levels of achievement.
The second area of reform focuses on addressing the numerous complaints that principals at BIEfunded schools have regarding the bureaucracy at BIE, BIA, and the DAS-M’s office.
According to this feedback, this bureaucracy requires principals to focus an inordinate amount of
time on school operations, rather than focusing on their primary mission of instructional
leadership. This governance structure – where decisionmaking power over school operations is
divided among the BIE, BIA, and the DAS-M’s office – also hinders attempts to reform the BIE
in a systematic and comprehensive manner. These multiple centers of power and competing
priorities affect BIE’s policy agenda and make it difficult to implement reforms or sustain any
meaningful progress.
Research shows that management redesign that co-locates decisionmaking authority and reduces
bureaucracy can enable low-performing school systems to leverage resources and talents to raise
student academic performance. In an extensive analysis of a U.S. Department of Education
longitudinal school achievement database (1999-2003) of over 100 school districts, a research
team found that an integrated management system enabled school districts to improve their
academic performance.23 School districts that shifted from a fragmentary system to a
coordinated, integrated system saw a closing of the achievement gap with the statewide averages
23

Wong, et al., The Education Mayor, 2007.

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in core subject proficiency.24
In the remaining schools run by the BIE, and in tribally controlled schools supported by the BIE,
an integrated management structure for the BIE could improve student outcomes in similar ways.
While acknowledging that BIE-funded schools are unique, it helps to address the problem of
institutional fragmentation within this set of schools.
An integrated management structure would also help the BIE better provide services to tribally
controlled schools. In order for the BIE Director to perform his/her responsibility to raise Native
student performance, the Director – and not the BIA or DAS-M’s office – must be enabled to
make decisions regarding functions that affect school quality and performance. Schools must
receive primary attention in meeting their needs in talent management and acquisition (namely,
hiring qualified teachers and principals in a timely manner), strategic and financial management,
IT infrastructure, facilities, data management, and instructional resources, including support for
implementation of the Common Core. Such an integrated management system would create the
necessary conditions to enable schools to improve their academic performance, as evidenced in
other districts that implemented the change in their management and governance systems.
Redefining the role of BIE’s central office as a school improvement organization with an
improved focus on building the capacity of tribes and tribal education agencies would allow
the redesigned BIE to accomplish the following:
● Fulfill the directive in the Tribally Controlled Schools Act that BIE be responsive to the
needs of tribal communities;
● Improve services that are delivered to tribally controlled schools, including services
involving new school construction, major repairs, and other operations and maintenance
issues for facilities;
● Ensure that decisions affecting school operations, including the design of buildings and IT
needs, at BIE-funded schools are aligned to educational goals and priorities; and
● Provide incentives to replicate successful tribally controlled school structures.
The DOI can achieve this goal by transforming the BIE into a lean and efficient school
improvement organization, which is primarily focused on providing services and resources to
BIE-funded tribally controlled schools that improve school operations and instruction, rather
than expending its resources on the direct operations of schools. The Study Group proposes that
the redesign recommended here occur in two phases for two reasons: first, to provide principals
at BIE-funded schools with immediate relief; and, second, to ensure that BIE’s long-term
24

In statistical terms, districts with integrated management, relative to other districts in the state, improved their net
proficiency standing on the average by approximately 0.15 to 0.19 standard deviations in elementary reading and
math. A more recent analysis on 10 years of student achievement data (1999-2010) for all the schools across three
states (New York, Massachusetts, and Illinois) provides additional supportive evidence on the positive relationship
between integrated management system and student achievement. In New York State, there is a significant, positive
relationship between a school in an integrated system and achievement growth in 8th grade math and reading, and in
4th grade math. In Chicago, there is a significant positive relationship between integrated management and
achievement growth in 8th grade math and reading. In Boston, integrated management has a significant, positive
effect on 4th grade math proficiency.

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trajectory is aligned with increased tribal control over schools and improved delivery of services.
In short, BIE must become an expert educational agency before it can effectively support tribally
controlled schools.
The first phase of this transformation plan will address long-standing concerns that the Study
Group heard from principals and other school officials regarding poorly managed school
operations. Major stakeholders such as the National Indian Education Association have
recommended that, in order to address poor school operations, that BIE have control over
decisions affecting school operations in its schools. In order to immediately address these
concerns, we recommend that BIE operationalize this transitional phase before the start of the
2014-15 school year. To the greatest extent possible, to avoid the need for additional hiring,
the Study Group recommends that the initial phase would be staffed with existing full-time
employees (FTEs) and resources from the DAS-M’s office, BIA, and BIE, and will focus on
improving the operational support that BIE should be providing to its schools. This school
operations division will report directly to the BIE Director, thereby improving efficiency and
accountability.
Accordingly, the Study Group recommends that the BIE create Education Resource Centers,
geographically positioned close to schools and staffed with mobile School Solutions Teams that
can be deployed to schools to provide customized support that meets the unique needs of each
school. Instead of issuing mandates to schools, these teams will ensure that principals and
teachers have the resources and support they need in order to operate high achieving schools.
These teams can be effective in assisting schools in their improvement efforts by making
available data-supported best practice models in such areas as school management and climate,
professional development, curriculum, and instruction. The teams will not be micromanaging or
directing reforms in schools, but would be directed to listen to principals and teachers and then
provide the support that is requested.
The second phase of the BIE redesign will ensure that BIE’s resources and staff are focused on
BIE’s longer-term mission of transferring control over schools to tribes. Accordingly, it will also
ensure that tribes have the necessary resources and customized support they need in order to
succeed. At the start of the second phase, School Support Solutions Teams located in regional
offices will be deployed to schools to provide customized technical assistance. Each tribe and
school is different, but these needs could include additional support in the areas of teacher and
principal recruitment, professional development, and evaluation; acquisition; school facilities;
financial management; and technology.
Agile Organizational Structure Recommendations:
● Support BIE-funded schools to develop and resource or improve their own talent
management, logistics, and information technology divisions;
● Offer tribes financial management and budget execution guidance and training;
● ● Provide customized technical assistance to enable tribal educational agencies to perform
LEA-like functions to manage their schools;
● Facilitate tribal consortia for purchase of universal products and services to reduce costs
(e.g., textbooks, technology, and special education related services);

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● Assist tribes by training human resource staff at tribal schools and recruiting highly effective
teachers and principals through the use of effective marketing and through the use of national
connections and the development of a database;
● Develop a toolbox of interventions to meet and/or customize to the needs of schools in
varying states of performance;
● Share best practices and research in teaching, learning, and leading schools
(e.g., effective interventions to improve student achievement and reduce the
achievement gap); and
● Provide, if necessary, training to school boards.
D.

Reform Area Three: Promote Educational Self-Determination for Tribal
Nations

Strengthen and support the efforts of tribal nations to directly operate BIE-funded schools.
In order to align the BIE’s redesign with President Obama’s core policy of self-determination for
tribes, we recommend that the BIE support tribal nations in assuming control over BIE-funded
schools. Increasing tribal control over BIE schools would recognize the sovereign status of
tribes and provide them with greater discretion to determine what should be taught to their
children. This includes the decisionmaking authority to determine whether students should be
taught their Native languages, cultures, and histories in BIE-funded schools.
Supporting the efforts of tribal nations to govern their own schools will also lead to improved
student achievement. As demonstrated in other areas in which tribal governments have assumed
control of government services, tribal nations often improve the delivery of services because
tribes: (1) understand the needs of their communities better than the Federal Government does;
and (2) are more likely to be held accountable for results by local communities.
Further, supporting the efforts of tribal nations to govern their own schools would help
accountability and reduce institutional fragmentation throughout the BIE-funded school system.
Under the current statutory and administrative framework, the BIE acts as a quasi-SEA for some
funding purposes, while its grant and contract schools operate as LEAs. These tribally controlled
schools receive funding directly from the BIE, are directly operated by local school boards, and
are highly independent agents.25 As a result, the current structure does not provide tribal
governments an opportunity to manage the schools located on their lands as an LEA does. This
contributes to the overall institutional fragmentation of the BIE-funded school system, making it
more challenging to implement reforms in a comprehensive and system-wide manner across a set
of schools located on a single reservation.

25

There are exceptions to this general practice. For instance, the Mississippi Band of Choctaw operates their eight
tribally controlled grant schools as a single LEA. Here, the Tribe is the direct recipient of BIE funds. The Study
Group considers this integrated governance structure a best practice.

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The Department of the Interior fully supports tribes’ sovereign right to determine the structure of
their own tribal government and school systems; however, that support can be strengthened by
facilitating the sharing of information on and exploration of particularly efficient and successful
school structures.
Self-Determination Recommendations:
● The Study Group recommends providing incentives to tribal governments to assume control
over remaining federally operated schools, including providing full funding for contract and
grant support costs and addressing facility needs for schools;
● Encourage and provide opportunities for tribal nations to operate and manage their schools
and receive funding directly from the BIE;
● Clarify the maximum amount of discretion that tribally controlled schools have to teach
Native languages, cultures, and histories to their students;
● Provide technical assistance on how curriculum regarding Native languages, histories, and
cultures can be aligned to Common Core State Standards; and
● When requested, provide customized technical assistance through School Solutions Teams to
support tribes when tribes request assistance regarding resources or support for improving
school operational practices at BIE-funded schools.
E.

Reform Area Four: Comprehensive Supports through Partnerships

Foster family, school, community, and organizational partnerships to provide the academic as
well as the emotional and social supports BIE students need in order to be ready to learn.
The BIE students, and American Indian students generally, face a multitude of challenges,
including emotional trauma and depression due to numerous environmental factors such as high
unemployment, rampant crime, substance abuse, and poor health outcomes. In order to address
the unique needs of this student population, the Study Group recommends that DOI and its
partners live up to BIE’s mission and take a holistic approach to provide comprehensive support
to BIE students so they can come to class ready to learn.
Facilitating public and private partnerships between tribes and local, regional, and national
organizations will ensure that all schools have the opportunity to benefit from resources made
available. Leveraging local and national expertise, for example, will enable schools to more
effectively address student needs, such as social and emotional counseling, bullying prevention,
parent engagement, and early childhood education. The DOI can take a critical first step in
creating public/private partnerships by reinstating the National Fund for Excellence in American
Indian Education (the Fund), a congressionally chartered non-profit foundation with the mission
of supporting BIE-funded schools. With a strong Executive Director and an active Board, the
Fund – which was organized and incorporated in 2004, but has been inactive since early 2007 –
could support the BIE in addressing needs in a more expedient and strategic manner. It would do
so by soliciting and managing private donations to support BIE’s important work. Further, with
constrained budgets at both the Federal and tribal levels, partnerships have become increasingly
important in equipping the BIE to continue fulfilling its trust responsibility for American Indian
education. At the local level, BIE-funded schools should also be encouraged to collaborate with

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local public schools on issues such as school calendars, professional development, and
curriculum implementation to increase consistency as students transition between school
systems.
In addition, the Study Group recommends that the BIE’s approach cut across all Federal agencies
and their community-based programs that serve tribal communities. Because each agency has
traditionally implemented these programs in separate silos, tribes experience redundancy,
disconnection, and a waste of Federal resources. On the other hand, if Federal agencies work
hand-in-hand (with each other and with tribes), and break out of those silos that stifle reform,
they can fundamentally transform BIE schools and the distressed tribal communities in which
they are located.
Comprehensive Supports through Partnerships Recommendations:
● DOI can take a critical first step in creating public/private partnerships by reinstating the
National Fund for Excellence in American Indian Education, a congressionally chartered
non-profit foundation with the mission of supporting BIE-funded schools;
● Coordinate with other Federal agencies so that community-based tribal grants help provide
wraparound services to students attending BIE-funded schools;
● Work with Indian Health Service (IHS) to increase and institutionalize the practice
of providing of school-based services to ensure that students are ready to learn and
can focus (e.g., provision of immunizations in time for start of school and counseling
services);
● Provide incentives to tribes to co-locate other tribal support services near BIE schools; and
● Work with the tribal grant schools to improve applications and obtain all available E-rate
funding.
F.

Reform Area Five: A Budget Aligned to Support New Priorities

Develop a budget that is aligned with and supports BIE’s new institutional focus of providing
resources and services to tribes.
In order to properly serve tribally controlled schools, the BIE’s budget must be aligned with its
new priorities as identified in the circles of reform discussed above. There are some budget
supports that cut across all four circles – e.g., investments in IT infrastructure and 21st Century
teaching and learning environments – and others that are specific to particular circles of reform.
These budget supports are described in more detail below.


Invest in Infrastructure to Improve Teaching and Learning

Based on tribal consultation and other available information, the Study Group believes
BIE currently lacks the necessary infrastructure that would undergird any serious effort
to reform this set of schools. During recent tribal consultations, the Study Group
repeatedly heard that issues related to the poor condition of school facilities demanded
so much time and attention from principals that they were diverted from their primary
mission of instructional leadership. Furthermore, in an official Federal report published

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in 2011, a negotiated rulemaking committee found that “63 [BIE funded] schools
remaining in poor condition as of September 2011 require an estimated $1.3 billion
to elevate them to an acceptable condition.”26 The same report estimated that
approximately $967M is needed to address BIE’s repair and maintenance backlog.27
The Study Group finds that DOI’s Federal appropriations for BIE school facilities
have not kept pace with the deterioration of school facilities and the essential educational
requirements for 21st Century teaching and learning, e.g., integration of technology and
multi-media in instruction. Of the 183 BIE schools, 34 percent (63 schools) are in poor
condition, and 27 percent are over 40 years old. These substandard conditions are not
conducive to educational achievement, and they unfairly restrict learning opportunities
for students.
Although buildings alone do not make a 21st Century teaching and learning environment,
research has found that the quality of where we learn affects the quality of how we learn.
Multiple studies have found significant links between inadequate facility conditions and
poor performance for students and teachers.28 In addition, the quality of physical
environments – including those impacting temperature, lightning, acoustics, and age –
affect dropout rates, test scores, student behavior, and teacher retention, which are all
issues at BIE-funded schools. For example, researchers at Georgetown University have
found that improving a school’s physical environment can increase test scores by up to
11 percent. Other studies have found a difference of between 5-17 percentile points in
the achievement of students in poor buildings and those students in educationally
appropriate school buildings (when socioeconomic status of students is controlled).29
Thus, the condition and upkeep of BIE-funded schools must be addressed in the
ongoing discourse about student achievement, teacher effectiveness, and accountability.
In recent hearings regarding DOI’s 2015 budget, there appears to be evidence of
bipartisan interest from both the House and Senate Appropriations and Authorizing
Committees to address BIE school facilities issues. The Study Group recommends
that DOI seek an increase in funding to support new school construction, the Study
Group will assist BIE in developing a 6-year facilities plan to bring all schools in poor
condition to an acceptable condition level. This plan would be based on a similar
6-year strategy used by DODEA to successfully replace and upgrade 70 percent of
its schools in poor condition – a $3.7 billion investment. This plan could be used in
future budget formulation.
The Study Group also recommends that DOI invest in broadband, as well as seek
additional funding from other agencies, for all BIE-funded schools since such an
investment cuts across the other four circles of reform. Many of the BIE’s schools
26

Negotiated Rulemaking Committee Report “Broken Promises, Broken Schools,” at p. 9, available at
http://www.bia.gov/cs/groups/xraca/documents/document/idc1-025523.pdf.
27
Id. at p. 9.
28
Negotiated Rulemaking Committee Report “Broken Promises, Broken Schools,” at p. 9 (“These studies have
found that the quality of physical environments – including temperature, lighting, acoustics, and age of facilities –
affects dropout rates, teacher retention, test scores, and student behavior”) and appendix c (citing studies).
29
Ibid.

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are located in the most remote locations in the country, and most schools have only a
T1 level of connectivity – woefully inadequate to meet the demands of 21st Century
teaching and learning. To ensure that BIE students have equal access to the College
and Career Ready and aligned computer-based online assessments (either Smarter
Balanced Assessment Consortium (Smarter Balanced) or the Partnership for Assessment
of Readiness for College and Careers (PARCC)), the Study Group proposes a critical
one-time start up investment on a sound IT infrastructure.
By helping connect teachers to students and parents, and helping schools share classes,
curricula, and other resources, broadband-enabled teaching and learning has begun to
fundamentally reshape education at all levels and has improved access to expanded
educational opportunities for all students. Broadband access is particularly important
for schools located in remote locations because it can mitigate the devastating impact
that geographic isolation can have on student achievement, particularly lack of access to
deep applicant pools of effective teachers and principals. Still, research shows that rural
schools and communities have insufficient broadband coverage when compared with
their non-rural counterparts and are in danger of falling further behind, particularly as
the rest of the country races forward with implementation of the College and Career
Ready Standards and aligned assessments.
The information technology infrastructure in virtually all BIE schools requires significant
upgrades. In an initial assessment of BIE IT capabilities, it is estimated that 25 percent of
BIE schools still use the Windows XP operating system. Smarter Balanced and PARCC
require, at a minimum, Windows 7. Many new computers must be purchased that are
capable of running Windows 7. Additionally, 60 percent of BIE-funded schools do not
have the bandwidth or computers to administer a test 3-5 times annually (as proposed
by Smarter Balanced). An investment must be made in network bandwidth to bring
BIE-funded schools up to the necessary bandwidth levels. Additionally, the technology
infrastructures within the schools need improvements across the board. New wiring,
switches, routers, wireless access devices, and more need to be purchased so schools
have well-functioning networks. Lastly, teachers need professional development so
they can effectively use the new tools and technology.
The Study Group suggests a one-time, startup investment of funding that would be
used to make the following basic upgrades to the BIE’s IT infrastructure: (1) procure the
type of computers and software necessary to administer online assessments; (2) increase
bandwidth in schools to ensure digital delivery of these assessments; and (3) provide
the resources and training that staff need to administer these online assessments
effectively and efficiently. Management performance metrics will include the number
of BIE-funded schools that have computers, software bandwidth, and staff to effectively
administer 21st Century academic assessments.

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

Aligning Budget to Support Self-Determination

In order to support the BIE’s efforts to promote tribal control over schools, the Study
Group proposes that DOI request and increase in tribal grant and contract support costs
for tribally controlled grant schools in its 2016 budget request. The Indian Affairs 2015
budget request for grant support costs for schools is $48.2M, the same as the 2014
operating plan level. According to the DOI 2014 Budget Justification, $48.2M “will fund
approximately 67 percent of the need” of tribally run BIE funded schools.30 During tribal
listening sessions and consultations, numerous tribal leaders and other BIE school
officials at tribally controlled schools explained how the shortfall impacts their schools
and stated they were using instructional funds to pay for administrative and operational
costs as schools.
The Study Group believes that this shortfall is a major obstacle to tribal operation of
BIE funded schools and a major deterrent for tribes considering assuming operations over
BIE run schools. Grant and contract support cost funds are expended on administrative
overhead costs for schools including business operations, payroll, personnel, annual
audits, information technology, and reporting. During tribal consultation and listening
sessions, principals and tribes reported that the shortfall forces schools to use funding
from their base instructional budget to pay for administrative costs which, in turn,
reduces the amount of funds available for classroom instruction.
The Study Group believes that the best ideas with respect to Indian education do not
originate in Washington, DC. At the same time, the Study Group also believes that the
BIE is an a position to (1) see which programs are working well for BIE-funded schools
across the country; (2) make connections between successful tribes and those that are
struggling; and (3) share best practices. Mindful of the principles of tribal selfdetermination, the Study Group knows that it would be inappropriate and wholly
inconsistent with tribal sovereignty for BIE to mandate tribally controlled schools adopt
any “best practice,” as determined by BIE. At the same time, given that BIE’s unique
position in relation to tribally run schools, BIE may identify programs being implemented
by other tribes with successful outcomes. The Study Group therefore recommends the
BIE offer funding incentives for tribes that choose to voluntarily adopt and implement
BIE identified best practices that are currently being implemented by other BIE-funded
schools or another schools system.
The Study Group believes that it is critical for DOI to have funding to offer these
incentives to tribally run schools. With that funding, the Study Group recommends
DOI consider adapting the successful, competitive grants approach currently being used
by the U.S. Department of Education as models. Such a competitive grant would target
resources to help tribes align tribal educational priorities to President Obama’s education
reform agenda to improve student outcomes and ensure all BIE students are college and
career ready. Performance metrics for the incentive grant could include student and
30

Dept. of the Interior, Indian Affairs, Budget Justifications, Fiscal Year 2014, at p. IA-BIE-2 & IA-BIE-3,
available at http://bia.gov/cs/groups/xocfo/documents/text/idc1-021730.pdf.

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teacher attendance rates, graduation rates, college enrollment rates, measures on educator
accountability, and performance on standardized assessments.


Aligning Budget to Support Effective Teachers and Principals

The investments in infrastructure and broadband described above would help recruit
and retain effective teachers and principals to BIE-funded schools (e.g., the provision
of teacher housing and professional development delivered online). The Study Group
believes that it is also critical to grant the BIE necessary funding to provide additional
incentives to recruit effective teachers and principals. For instance, the Group
recommends providing the BIE with the funding capacity to provide housing stipends,
loan forgiveness, and educational benefits would make BIE-funded schools a more
attractive place to work. In addition, the Group suggests that DOI also invest in
posting available positions at BIE-operated schools on the USAJOBS website.
Nonetheless, even with these benefits, due to the extreme geographic isolation of these
schools, it is critical to invest in upgrading the skills of existing staff. The Study Group
would recommend that BIE should have the budgetary capacity to provide high-quality
professional development to staff in tribally operated and BIE operated schools – for
instance, support for National Board Certification of teachers – would help the BIE
make progress towards achieving its goals.


Aligning Budget to Create an Agile Organizational Structure

Congress appropriates a significant amount of money to the BIE each fiscal year,31 but
this funding cannot be leveraged to the maximum extent in driving reforms because:
(1) the vast majority of this funding is formula-based; and (2) other entities, including
BIA and the DAS-M’s office, have significant control over its execution. Furthermore,
ED provides $200M in funding to DOI, and those funding streams are also fragmented.
The Study Group believes that one way to reduce this budgetary fragmentation, would be
to address the issue in future BIE budgets by providing the BIE with flexibility to control
over how its own budget is executed. An alternative model would be the DODEA budget
structure, which receives one appropriation from Congress (e.g., DODEA does not
receive any funding from other agencies nor do other offices within DOD control how
DODEA’s funding is used). This integrated budget structure provides the Director of
DODEA with a sufficient amount of discretion to ability to set educational priorities for
the entire school system.

31

According to a study conducted by BIE staff in 2011, the per pupil expenditure for BIE’s K-12 day schools was
approximately $13,116, and $15,550 for its boarding schools. Much of BIE’s remaining budget is used to fund nonK-12 programs, including funding for 32 tribal colleges and universities ($89M), operations at eleven dormitories
($24.5M), and a scholarship program for American Indian youth ($32M).

24

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Similarly, a more integrated budget structure would enable the BIE Director to be
more responsive to changing circumstances and better equipped to meet the unique
needs of diverse tribes and schools on a case-by-case basis. The Study Group believes
that eliminating the multiple players that control various aspects of BIE’s budget would
free BIE from unnecessary bureaucracy, provide for flexibility and, in turn, help support
the creation of a more agile organizational environment.
Finally, for each of the investments proposed by the Study Group, the Group
recommends that BIE monitor progress through the adoption of performance metrics and
conduct evaluations to identify effective strategies for continued investment.
VI.

Conclusion

The foregoing proposals are underpinned by a fundamental belief that all students, especially
American Indian students attending BIE schools, can learn. Accepting anything less says
nothing about these students, but rather speaks volumes about a failure of leadership and political
will. Every child can learn; every school can succeed. Challenging educational circumstances,
however, require vision, uncompromising values, conviction, and the courage to make difficult
decisions, especially when redesigning a broken institution. Challenging circumstances present
opportunities: an opportunity to unleash untapped potential; to be bold; to solve a problem
previous generations refused to tackle. That is the challenge the BIE presents to us today.

25

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APPENDIX A
Participants at Listening Sessions and Tribal Consultations
Last Name

First Name

Title

Organization

Aaron
Abeita
Abeita
Abeita
Aceveda
Acosta
Adson
Allery
Alvares

Michael
Fernando
James
Juan Rey
Casemro
Geneva
Lemuel
Aaron
Cesar

Superintendent
Council Member
Council Member
Council Member

Muckleshoot Tribal School
Isleta Tribal Council
Isleta Tribal Council
Isleta Tribal Council

School Board Member
Superintendent

Tohono O’odham Nation
Shonto Prep School
Gila Crossing Community School
National Congress of American
Indians

Anderson
Antone
Antone
Antone
Archambault
Archambault
Arviso
Ashley

Greg
Phyllis
Cynthia
Priscilla
Dave
Sunshine
Emily
John

Superintendent

Eufala Dormitory
Gila River Education
Gila River
Gila Community Crossing School
Standing Rock Sioux Tribe
Standing Rock Sioux Tribe
Bureau of Indian Education
Bureau of Indian Affairs

Ashley
Barehand
Basnau
Baum
Begay
Begay

Martina
Dora
Rick
Dawn
Edwin
Margie RS

Begay
Begay
Begay
Begaye
Begiasiua
Belone
Benally
Benally
Benjamin

Cordella
Catherine
Michelle
Irene
Dr. Noreen
Phil
Jacqueline
Tim
Joyce Flournoy

Tribal Council Member

Education Specialist
Assist. Director-Office of
Information

Director

Casa Blanca Community School
Gila River Community School
Chief Leschi School
Office of the Solicitor
Chooshgai
Navajo Dine Bi Olta School Board
Association, Inc.

Administration
Program Specialist
Director
Executive Director
Teacher

26

Hotevilla Bacavi Community School
Bureau of Indian Education
Black Mesa Community School
Tribal Education Department
Navajo Nation
Many Farms Community School
Navajo Nation
Isleta Pueblo Elementary

July 9, 2014: Revised for typographical and formatting inconsistences

Benneman
Big
Birdletter
Biscoe
Bixby
Blue Earth
BlueEyes
Bohanon
Bordeaux
Bough

Charlene
Rosemary
Lydia
Catherine Belinda
Norma
Emersen
Faye
Joseph
Deborah
Brian

Human Resources

Bowlier

Connie

Cheyenne River Sioux Tribal
Education Agency

Bradford
Bradley
Brady
Brave Eagle
Bravo
Brawr
Breuer
Brewer
Brewer
Bundy
Butler
Byrnes
Campa
Campbell
Campbell
Cardenas
Castillo
Cedar Face
Chapin
Chavez
Chavez
Chavez
Chelsea
Chimoni
Claymore
Coffland
Coin
Conroy

Jim
Jacque
Bob
Dayna
Robert
Elma
Jody
Jodie
Bryan
Dr. Michael
Edwina
Erin
Lucie
Katherine
Matt
Freddie
Shawna
Francis
Jake
Everett
Ruby
Ervin
Mike
Emelda
John
Don
Leora
Bradley

Tribal Education
Director
Tribal Education

Consultant
Principal
Education Specialist

Associate Director
Director

Program Specialist
Oglala Sioux Tribal President
Superintendent
Governor
Partner
Education Specialist
Tribal Education
Principal
Union Steward

Teacher
Teacher
Teacher
Superintendent
Principal
School Board

27

Blackwater Community School
Gila Crossing Community School
Oglala Sioux
University of Oklahoma
Standing Rock Community School
Dzilth-Na-O-dith-hle-School
Muskogee, Ok
Loneman School
Bureau of Indian Education

Pine Ridge
Blanca Community School
Human Resources Team
Tribal Education Department
Hualapai
St. Stephens WY
Lakota Sioux
Bureau of Indian Education
Two Eagle River School
Shawnee, Ok
Udall Law Firm
Bureau of Indian Education
Bureau of Indian Education
Jemez Day School
Pine Ridge High School
Pyramid Lake
Navajo Nation
Isleta Pueblo Elementary
Dzilth-Na-O-dith-hle-School
Pine Ridge High School
Isleta Pueblo Elementary
Quileute Tribal School
Tuba City Boarding School
Second Mesa Day School
Pine Ridge School

July 9, 2014: Revised for typographical and formatting inconsistences

Cook
Craddock
Cumming
Cummings

Robert
Steven
Harley
Charlie

Curley
Curran
David
Davis
Dawasema
Dawasema
Dearman
Dee
Delome
Dorpat
Dorsett
Dosahue
Dunn
Duran
Dworakwoski

Ray
Jim
Jerry
Rosie
Donald
Madonna
Tony L.
Chester
Betrice
Norm
Teresa
Leon
Steve
Shawn
Patrick

Eaglestaff
Eastman
Edgar
Elkin
Eskeets
Espinoza
Fapans
Faria
Farlo

Donna
Nadine
Melissa
Tom
Emerson
Derid
Anthony
Debra
Dr. Cherje

Fatheree
Fingston
Fitzgerald
Floyd
Flyingman
Fohrenkan
Foreman
Fourier
Fred

Catherine
Cindy
Marilee
Kay
Franda
Robin
Sherri
Paula
Rebecca

Teach for America
Chairperson
Oglala Sioux Tribe Education
Chair

Oglala Sioux

Little Singer Community School
Teach for America
Chief of Logistics
Associate Deputy Director

Superintendent
OST Legal Dept.
Director
Director

Asst. Associate Director of
Ed.
Education Line Officer
Superintendent
Special Assistant
Supervisory Civil Engineer
RST-TFA

Bureau of Indian Education
Hopi Tribe
Riverside Indian School
Navajo Nation
Chief Leschi School
Cheyenne Arapahoe
Pine Ridge
Chickasaw
Taos Pueblo
Academic Accountability Team
Bureau of Indian Education
Tiospa Zina Tribal School
Chickasaw Nation
Bureau of Indian Affairs
Little Wound School
Las Vegas Paiute Tribe

Cheyenne River Sioux Tribe
Agency Education
Education Line Officer
Court Reporter
(Former) Director
Oklahoma State Legislature
Supervisory Program Analyst

28

Bureau of Indian Education
U.S. Department of Defense
Oklahoma City, Ok
Bureau of Indian Education
Gila Crossing Community School
Muckleshoot Tribal School
Little Wound
Moencopi Day School

July 9, 2014: Revised for typographical and formatting inconsistences

Fritzler

Charitina

Fyant
Garro
Germany
Gibbons
Gilman
Godinez

Shelly
Myra
David
Lynn
Glenn
Lucinda

Gonzales
Gonzalez
Gregores
Gregory
Gross
Gulibert
Haarstad
Haas
Hacker

Theresa
Ruben
Wendy
Orena
Shirley
Felicia
Erick
John

Hale
Hamley

Harjo
Hartman
Hastings
Hawkes
Hejtmanek
Hence
Herrera
Hettich
Haas
Honahni
Honanie
Hughes
Humetewa
Hunter
Jackson
Jaime
Jaramillo
Jaramillo
Jewell

Bob
Jonathan

Jeff
Lucyann
Tracy
Jim
Michael
Mike
Bernadette
Roy
Tom
Cecelia
Dan
Doris
Michael
Howard
Sharon
Dr. Mark
Leticia
Cynthia
Larry
Sally

First People’s Center for
Education
Teacher
Tribal Education

Teacher
Council Member
Administrator
Principal

Oglala Sioux Tribe Education
Coordinator
Member Navajo Nation
Associate Deputy Director

Indian Ed. Coordinator
Director
Education Line Officer
Executive Director
Superintendent
White House Intern
Superintendent
Director/Human Resources
Oglala Sioux Tribe
Tribal Council Member

Salish & Kootenai
Isleta Pueblo Elementary
Mississippi Choctaw
Oglala Sioux
Hopi High School
Greasewood Spring Community
School
Isleta Pueblo Elementary
Gila Crossing Community School
Isleta Pueblo
Sac & Fox Nation
Pierre Indian Learning Center
Santa Fe Indian School
Salt River Elementary School

Navajo Nation
Bureau of Indian Education

Norman Public Schools
Eastern Oklahoma Tribal Schools
Arizona South
Alamo Navajo School Board, Inc.
St. Stephens Indian School
Santa Fe Indian School
Bureau of Indian Education
Hopi Tribe
Hopi-Moencopi Day

Consultant on Indian Affairs
Pueblo of Santa Ana
Federal Programs Coordinator Riverside Indian School
Quileute Tribal School
School Board Member
Quileute Tribal School
Council Member
Isleta Tribal Council
Vice-President
Isleta Tribal Council
Secretary
U.S. Department of the Interior
29

July 9, 2014: Revised for typographical and formatting inconsistences

Jiron
Jiron
Johansen
Johnson
Johnson
Johnson
Johnson
Johnson
Johnstan
Jojola
Jojola
Jones
Jose
Juan
Keel

Douglas
Phillip
David
Wayne
Lynn
Victoria
Manuel
Sherry
Tyson
Denise
Geraldine
Genevieve
Verlon
Marjorie M.
Dale

Keel
King
King
Kinnison
Kip
Kitsopoulos
Knight
Krech
LaPlante
Laurkie
Lawton
Lee
Lente
Lessensl
Lewis
Little
Little
Little Axe
Little Singer
Little Singer
Logan
Lolnitz
Lomahaftewa
Lomahaftewa

Jefferson
Carmen
Gaye Leia
Akilah
Penny
Gloria Coats
Patricia
Sandra
Mike
Richard
Ray
Deborah
Michael Allen
Rior
Stephen
Eanie
Justin
Troy
Leo John
Etta Shirley
Leilla
Darlene
Gloria
Jolene

Council Member
Council Member
Chief, Special Education
Tribal Education
Regional Solicitor’s Office
Teacher
Intergovt. Liaison
Director
Teacher
Tribal Education Department

BIE Boarding School
Chief – Office of Facilities
Management and
Construction
Teacher
Education Specialist

Isleta Tribal Council
Isleta Tribal Council

Isleta Pueblo Elementary
Gila River
Sisseton Wahpeton
Quinault
Isleta Pueblo Elementary
Isleta Pueblo
Big Pine Paiute Tribe
Tohono O’odham Nation
Tohono O’odham Nation
Bureau Indian Affairs

Isleta Pueblo Elementary

Governor
Superintendent
Program Support
President

Bureau of Indian Education
Hobbs Straus Dean &Walker
Two Eagle River School
American Horse School
Duckwater
Gila Crossing Community School
Bureau of Indian Affairs
Laguna Pueblo
Chief Leschi School
Bureau of Indian Education
Isleta Tribal Council

Lt. Governor

Gila River Indian School

Chairperson
Superintendent

Loneman School
Modoc

Winnebago Tribal Health
Koyukuk Tribe
Second Mesa Day School
Second Mesa Day School

30

July 9, 2014: Revised for typographical and formatting inconsistences

Lomtv
Longie
Lopez
Lords
Lovin
Lucas
Lucero
Lunderman
Lyan
Macias
Malo
Marquez
Martinez
Martinez
McArthur
McIntire
McIntosh
Mendoza
Mendoza
Merdenian

Leo
Joel
Julia
Eric
Brenda
Lucy
Joseph
Richard “Tuffy”
Michelle
Esther
Rachel
Fernando
Elizabeth
Racheal
Hank Edmo
Chris
John L.
Gregory
William
Tina

Mike
Mitsel

Jeffrey
Mikayla

Miyasato
Molina
Monroe
Moore
Moore
Moore
Morehead
Morris
Morrison
Nelson
Nelson
Nelson
Nez
Nez
Nite
Norris
North

Mona
Mario
Elsie
Henry
Jacob
Patrick
Jellene
Kay
Anthony
Danielle
Dan
Steve
David
Victoria
Jerome
Debora
Eric

Academic Achievement
Principal
Assistant Principal
Council Member
Tribal Council
Teacher
Education Specialist

Teacher
Assistant Principal
Operations Manager
Education Line Officer
Governor
Executive Director
Oglala Sioux TribePresident’s Office

Acting Principal
Director
Tribal Council Member
Inter-Tribal Council
Principal
Principal
Assistant Principal

Principal
Retired
Department of Education
Education Line Officer

31

Chickasaw Nation
Bureau of Indian Education
San Simon School
Shoshone-Bannock Tribal School
WaHeLut Tribal School
Hopi Tribe
Isleta Pueblo
Rosebud Tribal Education
Isleta Pueblo Elementary
Bureau of Indian Education
Chooshgai Community School
Gila Crossing Community School
Isleta Pueblo Elementary
To’Hajiilee Community School
Shoshone Bannock Tribal School
Salt River Pima
Navajo Region
Gila River Community
U.S. Department of Education

Pinon Community School
Oglala Sioux Tribe Education
Agency
Pine Ridge High School
Gila River Indian Community
Leupp Schools, Inc.
Arizona
Arizona
Riverside Indian School
Sac and Fox Nation
Laguna Elementary School
Second Mesa Day School
Pine Ridge Line Office
Education Northwest
Santa Clara Day School
Black Mesa Community School
Bureau of Indian Affairs
Arizona State
Bureau of Indian Education

July 9, 2014: Revised for typographical and formatting inconsistences

Nuttle
Old Chief
Olsen
Oosahwee

William
Bill
Eric
Sedelta

Program Specialist

Otero
Ouco
Pablo
Pablo
Padilla
PalmateerHolder
Pankovits
Parker
Parton
Pauley
Pedro
Perkins
Pickering
Pieper-Jordan
Pino
Plummer
Poououma
Power
Provost
Quimayousie
Ramirez
Raymond
Record
Redbird
Reedy
Reimer-Edef
Reinhardt
Roanhorse
Roberts Hystop

Katie
Karen
Christina
Winfred
Josephine
Lynn

Teacher
Coordinator

Rodin

Jenni

Tressa
Allan
Terry
Linda
Anita
Danielle
Dwight
Seanna
Henry
George
Melvin
Jacquelyn
Irving
Cheryl
Renee
Tom
Caryn
Ernest
Patricia
Constance
Marty
Maxine
Julie

Rodriguez
Dennis
RomanNose

Chief Financial Officer
Associate Director

Council Member
Tribal Leader

President
School Board Member
School Board
Department of Education

School Board Member
Superintendent
Oglala Sioux Tribe
Associate Deputy Director

Indian Education Coordinator
School Board Member
Regional Solicitor’s Office

Bureau of Indian Education
Blackfeet Nation
Santa Fe Indian School
White House Initiative AI/AN
Education
Isleta Pueblo Elementary
Gila Crossing Community School
Gila Crossing Community School
Isleta Tribal Council
Coldville Tribe

Awanuiavapgs
Wichita & Affiliated Tribes
U.S. Dept. of Education
Auburn, WA
ShoBan School
Oklahoma
Blackwater Community School
Navajo Nation
Moencopi Day School
Blackwater Community School
Bureau of Indian Education
Hopi Tribe
Moore Public School
Riverside Indian School
Tanana Chiefs Conference-Alaska

Professor
Dineyazhe

Oglala Lakota College-Dev.
Ed. Dept.,
Office of Facilities
Management and
Construction
Director

32

Santa Rosa Day School
Tanana Chiefs Conference Vice
President

Bureau of Indian Affairs

Tribal Education Departments

July 9, 2014: Revised for typographical and formatting inconsistences

Rose
Ross

Quinton
Jolyn
Margaret

Rousseau

Anthony

Rullianus
Sakiestewa
Saladera
Salyers
Sam
Sanchez
Sanchez
Sandoval
Sandoval
Sauer
Sauve

Georgeous
Norma
Kevin
Denise
Walt
Virginia
Barbara
Patricia
Yolanda
Linda
Michalle

Scott
Scribner
Secakuyva
Segrove
Seworestewa
Shaw

George
Zach
Corey
Michael
Alden

Shaw
Shendo
Shirley
Silas
Sinquah
Sly
Smith
Sovo
Spoon
Starr
Stevens
Stevens
Tah
Tahy
Taken Alive
Talayumptewa
Talley

Claudia
Lesa B.
Kevin
Etta
George
Alma
Gloria
Grace
Casey
Tresh
Goldie
Bart
Joan
Andrew
Emery
Jesse
David
Nikki

Principal
Oglala Sioux Tribe
Member/Educator
Director – Information
Resources

K-12 Coordinator
NASIS

Council Member
School Administrator
Parent

National Assembly
Sequoyah High School

Bureau of Indian Affairs

Hopi Tribe
Pine Ridge High School
Bureau of Indian Education
Duckwater Shoshone
Isleta Pueblo Council
Santa Fe Indian School
Navajo Nation
Gila River Indian Community

Administration for Children
& Families

Planner
Chief Financial Officer,
Comptroller
Projects
Principal

Education Liaison
Teacher
Education Line Officer
Director of Education
Associate Deputy Director
Parent
Superintendent

Education Line Officer

33

Government Accountability Office
Chickasaw Nation
Hopi Tribe
Eastern Oklahoma Tribal Schools
Hopi-Moencopi Day

Absentee Shawnee Tribe
Pueblo of Jemez
Little Singer School
Hopi Tribe
Second Mesa Day School
Cherokee Nation
Edmond Public School
Bureau of Indian Education
Absentee Shawnee Tribe
Bureau of Indian Education
Navajo
Arizona State University
Standing Rock Sioux Tribe
Bureau of Indian Education
WIHAIANE

July 9, 2014: Revised for typographical and formatting inconsistences

Tapija
Taylor
Tehraar
Teller
Tepp
Tewa
Thomas
Thompson
Thompson
Thunder
Tinnt
Tokeinna
Topash
Torres
Trahan
Trottier
Tso
Tsosie
Tsotigh
Tyen
Valentine
Valenzuda
Walker
Wauwow
Weatherly
Webster
Wells
West
White
White Crust
White Eagle
Whitebear
Whiteeyes
Whitehorse
Whitford
Williams
Williamson
Wilson
October
Witherspoon

Emma
April
Rita
Verna
Rose
Marilyn
Dr. John L.
Patricia
Patti
Adrienne
Jason
Robert
Tom
E. Paul
Rodney
Neal
Matthew
Katleen
Jacob
Barbra
Rebecca
Patricia
Bill
Loretta
Jim
Catherine
Danny
Mark
Kalvin
Frankie
Robert
Ronald
Robert
Brenda
Harvey
Marie
Jeff
Ryan
Manuella
Dwight

Hualapai
Chickasaw Nation
Special Education Team
Secretary

Isleta Tribal Council

Tribal Council

Hopi Tribe
Bureau of Indian Education

Tribal Education
Oglala Lakota College STEM

Governor
Principal
Legislative Analyst

Native Village of Wales
Pokagon Band Potawatomi
Isleta Pueblo
Sioux Tribe
To’Hajiilee Community School
Navajo Nation
Cove Day School

Technical Assistance Co.

Regional Director

Administrative Support
Executive Officer
Acting Principal
Director
SIG Coordinator

Acting Education Line
Officer
Principal
Principal
Special Education

34

Loneman School
Santa Rosa Ranch School
Gila River Indian Community
Bureau of Indian Affairs
Jamestown S’Klallam
Bureau of Indian Education
Chickasaw Nation
Pine Ridge High School
Navajo School Board
Pine Ridge High School
Oglala Lakota
Winnebago Tribal Health
Bureau of Indian Education
Aneth Community School
Wa He Lut Tribal School
Little Singer School
Gila River Community School
Oglala Lakota
Casa Blanca Community School

July 9, 2014: Revised for typographical and formatting inconsistences

Wohnson
Wright
Yatsattie
Yazzie
Yazzie
Yazzie
Yellowfish
Yepa
Young

Rondi
Kara
Charlene
Emma
Lorraine
Rena
Sydna
Gloria
Cynthia

Teacher

Education Line Officer
Director
Supervisory Ed. Specialist

35

Karuk Tribe
S’Klallam Tribe
Isleta Pueblo Elementary
Leupp Schools, Inc.
Black Mesa Community School
Bureau of Indian Education
Edmond Public School
Bureau of Indian Education

July 9, 2014: Revised for typographical and formatting inconsistences

APPENDIX B
Illustrative Comments from Tribal Leaders and Other BIE Stakeholders During Study
Group Listening Sessions and Tribal Consultations
Reform Area 1: Highly Effective Teachers and Leaders
Just some challenges that I want to let you know what we deal with. [H]iring is a huge issue.
[U]ntil we get HR under our belt or underneath our umbrellas, it’s always going to be an issue.
When we go to hire teachers and we’re dealing with it right now, they can be certified in the
State of Oklahoma but they can’t BIE’s requirement, then we lose them. Right now we’re trying
to hire a Spanish teacher that can go anywhere in the State of Oklahoma and teach but she
doesn’t meet qualifications of the BIE. Tony Dearman, Superintendent Riverside Schools
(Anadarko Tribal Consultation)
Why don’t we have teachers, counselors, principals, superintendents, and all the other
maintenance workers and those things wanting to come here? Why can’t we recruit these people
to come here? Well, they’re not going to come here just because we tell them we love them.
They’re going to come here and work because we pay them a competitive wage and we’ve got
to teach them a trade and respect them for what they do when they get here. Jefferson Keel,
Lieutenant Governor of the Chickasaw Nation (former President of the National Congress of
American Indians) (Anadarko Tribal Consultation)
Housing for teachers is very inadequate. As a result, Northern Cheyenne cannot get and keep
qualified teachers. The teachers have to travel from Billings, which is far away, and if there is
inclement weather than there may not be class that day. Housing is a priority that needs to be
addressed. Northern Cheyenne Nation via Quinton Roman Nose, Executive Director, Tribal
Education Departments National Assembly (TEDNA)
We need well-trained administrators and teachers and staff. The only way to get that is offer
salaries that are higher, provide some kind of housing assistance to get there. Where I am, we
have teachers driving 160 miles a day to get to school. If they get offered jobs in their
hometown, I know we’re going to lose them. Mark Jacobson, Principal and Acting
Superintendent, Quileute Tribal School (Auburn Tribal Consultation)
They have been trying to get new school for a long time. The current building does not have
sufficient heating, it leaks, and there is a roof issue. Children have to wear their coats in class in
the winter. Leech Lake is supposed to be a high priority, but nothing has come of it yet. This
needs to be addressed. Leech Lake Band of Ojibwe via Quinton Roman Nose, Executive Director,
TEDNA
Offer all teachers a grant to become board certified (free whether they pass or not).
Bradley Budinger
But one of the things we notice is that we can’t get teachers to stay. They come and we have
even had some drive through the parking lot and go and leave. Right? And they’ve already

36

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had a signed contract. Michael Hawk, Executive Director, Alamo Navajo School Board (Gila
River, Arizona Consultation)
If you’re not educating your local people you’re not going to ever fill all those slots. It’s
impossible. You don’t have the capacity or the population to do that with all the openings, at
least in Navajo country. I’m sure other tribes are the same. Michael Hawk, Executive Director,
Alamo Navajo School Board
One of the things we’ve done in Alamo, we’ve had teachers come through that we have recruited
and it’s very hard work. We are isolated by 62 miles of nowhere. And one of the things that we
have done is provided incentives because we have broadband, we have infrastructure, we have
those types of things. We have upgraded the school to make it less institutionalized and more
receptive for the children that come to school. It’s a learning environment. Michael Hawk,
Executive Director, Alamo Navajo School Board, (Gila River, Arizona Consultation)
The 2014 operating plan that BIA central office put together provides only $169,000 for teacher
pay for the schools. So that’s only 7.8 percent of the amount that’s needed to adequately fund
teacher pay to retain quality – attract and retain quality teachers, so that has to be looked at.
That’s not good. Michael Hughes (Gila River Consultation)
But we also need to make sure that have we have the proper tools and materials for our teachers
to – because the community I come from, housing is really difficult for people coming in, so we
can retain them at the schools. We have about 90 houses but 50 of them are just not liveable.
And so it just leaves us the few that are out there that we are trying to renovate. It’s very hard to
do that as well because these are homes that were probably there back in the 30s or, you know –
yes, they have asbestos that you have to do and it’s very expensive to demo those places. And so
we try to retain our teachers and when we ask them to come out to live on the reservation and to
try to fight the dirt and the wind just like the gentleman said. And so you know, in our homes we
try to fight that as well. They are falling apart as we speak. So I want to see if there’s certain
restrictions that we can eliminate, so we can bring home and bring in good teachers and
effective, highly qualified teachers and just this year I had – this gentleman said someone came
to see the campus and they drive in and turn around and left. It’s the same thing happened to me.
They saw the housing and said no, thank you, and they left… And teachers are really hard to
find. Our SPED teachers are very hard to find. Nurses are hard to find. I had to, you know, try
to talk them into staying… Sometime they stay for a couple of months and then they can’t handle
it. Jacqueline Benally, Many Farms Community School (Gila River Tribal Consultation)
Additionally, when President Carter enacted the Civil Service Reform Act of 1978 he eliminated
the retirement system for Bureau-funded schools. So we are on the 401k plan which really hurts
us. The reason it hurts us is because we are competing with the Arizona Retirement System, and
so when teachers want to come out to Hopi High think say, what kind of retirement do you have?
We don’t. It’s all self-funded. And so I would recommend then to the Federal Government that
we look at reinstituting the pension plan for teachers and administrators for zero funded schools.
It would help a lot in our recruiting efforts. Glenn Gilman, Principal, Hopi High School (Gila
River Tribal Consultation)

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One of the things that I would tell you that I would dearly love to see is a leadership academy for
administrators and principals and those people who are coming into the BIE system like myself.
I had to totally learn alone. Michael Bundy, Superintendent, Two Eagle River School (Auburn
Tribal Consultation)
There should be a training program for new superintendents, new principals that come to BIE
schools, because it’s the blind leading the blind. We’re just doing what we think is best and
trying to muddle through as best we can. I have no idea or had no idea what reports were due or
when they were due or anything like that. And you get that call when you’re going to lose your
funding by March 31st unless this report is done. What report? Mark Jacobson, Principal and
Acting Superintendent, Quileute Tribal School (Auburn Tribal Consultation)
Since Native students travel between the public, BIE, charter, and tribal contracted or grant
schools in their communities, the BIE should work with local non-BIE school systems, tribes,
and their education agencies to ensure school calendars, professional development, and CCSS
curriculum implementation support one another and provide consistency for Native students.
National Congress of American Indians and National Indian Education Association
The Study Group should also provide concrete steps, such as offering premium pay and housing,
or preparing local tribal citizens to teach, in order to assist schools having trouble recruiting and
retaining experienced teachers and administrators. National Congress of American Indians and
National Indian Education Association
Reform Area 2: Agile Organizational Environment
I really, truly appreciate the upfront points on the bureaucracy. Because tribal schools have
historically followed the same organizational structure of top down management, top down
decisionmaking. And that needs to change. Lynn Palmanteer-Holder, Tribal Council Member,
Confederated Tribe for the Colville Reservation (Auburn Tribal Consultation)
We as Schools report to our ELO, to our ADD West Director, and to the DPA. In the course of a
week there are usually one to two reports due. I usually work on my reports from 5a.m. to 6a.m.
so that I have some time to go into the classroom. Reports in Native Star, which is many, also
NASIS requirements, Annual/Academic reports, Special Education reports, Finance Reports, HR
Paper Work always needed, etc. and the list goes on. I only have 79 students, however I work on
reports usually from 5 to 6 a.m. as stated before and then at least another hour at work. Oh, I
forgot quarterly budget reports. A major problem with being a Principal is you are more a
manager and data entry administrator vs. a leader in the educational system (LEARNING).
Along with these reports, the requirements in Safety, going Green, etc. come into play. If you
factor in all the teleconference meetings or meetings that require one to go to the BIE Office
most of the day is covered with requirements towards Federal policies instead of ensuring
learning is going on in the classroom. Gary Tripp, Principal, T’siya Day School
Currently, teachers have been cut from using copy paper. Pencils, sharpeners, and other
materials are so inferior they break constantly. Teaching positions are unfilled. And, wireless

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internet goes unused without wireless computers to use them on (all most all computers hadn’t
had wireless cards installed when wireless networks were made available). Bradley Budinger
It is critical to remember without resolving the facility funding issue, the schools in the north will
have to shut down in March because there will be no funds to pay electric, phone or heating
bills! This funding is appropriated by Congress to the schools to be used specifically for the
above bills but is being constrained by BIA Facility Management Offices! AHS is not asking for
extra funding (even through the SIG allowed us to hire 7 more teachers and raise our academic
scores), we only are asking for what Congress has already approved for our school – 100 percent
facility funding, 100 percent administration cost funding and Federal healthcare for our school
employees. The cuts in the facility and admin costs have to be made up with the students ISEP
funding which is supposed to be used to hire instructional staff and purchase curriculum and
resources for our students. Gloria Coats-Kitsopoulos, School Superintendent, American Horse
School
[Human resources] has many problems, the biggest is unqualified staff. People are
unprofessional, never return phone calls, emails and mailed or expressed mail correspondence,
everything takes months to accomplish, and if qualified people worked in [human resources]
I believe processes would function faster and more efficient. I constantly have to resend
documents repeatedly, which is a waste of time and material. To bring on a new staff it takes
a minimum of 3 months, not conducive if you’re trying to run a school. Still using a DOS
based program called FPPS, not tied into FBMS or Quicktime, having to use multiple systems
is a waste of time and money. Sydney Gates, Business Technician San Ildefonso Day School
Acquisitions is a major disaster, 4 years later we still have the same issues with no resolve –
The DOI should have an ongoing data base of approved vendors for which we can pull, again
the business tech’s have to be well rounded in purchasing IT equipment, textbooks, instructional
material, facilities and operations, again we should only be the processors. Utilize the experts
to make special purchases not the [business technicians]. We are business people, not IT or
teachers. Often time we are responsible in finding speech therapists and creating documents to
meet acquisitions requirements. Professional staff should be researching therapists, IT
equipment etc. The [business technicians] have to research and find qualified vendors to meet
the mission of the principal and IT and other areas of school function with very little tools and
knowledge. The [business technicians] finds and procures the contractor, creates the requisition,
processes the requisition, pays for the requisition, adjusts costs in FBMS if necessary no
separation of duties. Where are the internal controls? Sydney Gates, Business Technician
San Ildefonso Day School
The Bureau funded schools struggle with knowing which acronym to go to for assistance when
they need help. Often when in need of help with facility issues the schools will go to the BIA
and are told to go to the BIE and the BIE will state they have to wait for the BIA or OFMC
before they can help. When help is needed with other issues there is no clear directions given as
to which acronym to go to for help. Very often reservations or geographic areas are played
against each other. Deborah Bordeaux, former Principal of Loneman School

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When it comes to reports, there’s so many more reports and things and almost like duplication
that the BIE is requiring. Let me give you a good example. School improvement, you have your
school improvement plans. And I was doing that. At the same time, I’m doing what the State of
Montana is requiring. We’re an accredited school, and we were getting in trouble for
accreditation. How come? You’re missing school improvement reports. So I’m supposed to be
doing school improvement to the State of Montana. At the same time, I have got school
improvement reports that are going out to BIE. Totally different creatures. Michael Bundy,
Superintendent, Two Eagle River School (Auburn Tribal Consultation)
The education system within the BIE in my estimate needs a great deal of changes or
improvements. Let me start by talking about the difficulties a school has with Human
Resources. It is very difficult to get someone hired or even get volunteer assistance in the
Schools. I believe it takes 2 to 3 months to run someone through the whole process (with ever
going new paper work and changes) and get a teacher to come into the school. HR is their own
identity, and therefore employees answer to a supervisor instead of a Superintendent or Bart
Stevens, the ADD West Supervisor. HR really needs to be under the control of ADD west.
Food contracts are not negotiable? Currently the contract with Sysco has been renewed, but the
prices are higher than some other food vendors. Why does BIA keep this vendor? Other
vendors also have a better variety and quality of food. Another thing with the Sysco accounts,
we have no point of contact to speak with regarding the contract or invoices being posted. The
contract amount that is on the UDO reports that we receive are not correct. The invoices are
being charged to the wrong “line” so now it shows that we are in the negative. Nona J. Narango,
Business Technician, Santa Clara Day School
The Tribe has been waiting for years, literally years, for an inspection to be conducted by the
BIE Albuquerque Office to finalize occupancy permits. The Albuquerque office has still not
come out to do the necessary inspections to finalize the permits. This and other inefficiencies
need to be corrected. Sault Ste. Marie Tribe of Chippewa Indians via Quinton Roman Nose,
Executive Director, TEDNA
BIE has not yet released the standardized test scores to the Schools. These scores are essential
determined if AYP was met, and BIE needs to release those scores as soon as possible.
Quinton Roman Nose, Executive Director, TEDNA
Alternative AYP – ED and DOI have never provided a final response to the efforts being made
to develop and Alternative AYP by several schools. Deborah Bordeaux, former principal
Loneman School
I had the honor of working at a unique school, Cheyenne-Eagle Butte. Since it is part public
through the State of South Dakota and part BIE (operated) under a collaborative agreement,
that school is probably the only school that received an AYP status from two entities. Three
years ago the school received a “made AYP” status from the State of South Dakota and a “didn’t
make AYP: status from the BIE for the same exact students, same exact accountability plan that
really belonged to the BIE. I sent an appeal and tried to argue the point with BIE, but my
argument was too logical and I simply asked, “Why wouldn’t the BIE want to use the

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Accountability Plan correctly to determine AYP and have more of their schools make AYP?”
Now, we are at another impasse with the new online testing. Nadine Eastman, Superintendent,
Tiospa Zina Tribal School
One thing I would like to say that I haven’t heard is the question, have we satisfied the GAO
Report and address the issues in the Bronner Report. I think we have, with the presentation this
morning... I think we have addressed those issues so I think we’re going forward with that.
Greg Anderson, Superintendent of the Muskogee Creek Nation Dormitory (Anadarko Tribal
Consultation)
I agree and support the Centers of Excellence, but we need to start educating a new wave of
Native American teachers because right now we have very few Native American teachers, very
few community teachers that we have. Lieutenant Governor Steven Lewis, Gila River Indian
Community (Gila River Consultation)
The BIA has a very, very bad practice of forcing people to submit data for reports that are just
based on the idle curiosity of someone in the central office and nobody ever uses it and it’s a
huge waste of time. So you don’t want to end up with that. Michael Hughes (Gila River Tribal
Consultation)
One of the problems of moving forward is that the Bureau of Indian Affairs is not a full-fledged
bureau. If you go to the Department of the Interior internet site… and you click on “who we
are,” the Department of the Interior, and click on “organizational chart,” you will see an
organization chart for the Department of the Interior. And under the Assistant Secretary for
Indian Affairs you will see Bureau of Indian Affairs but that there is no Bureau of Indian
Education there. And people say, well, what happened to the BIE? I say, “there is no BIE.” It’s
sort of a stepchild of the BIA that gets neglected and forgotten about most of the time. So one
of the things that should be considered is the establishment of a real Bureau of Indian Education
in the process of doing the 2016 budget. So what would that mean? Well, a real BIE would
have its own annual budget justification, a reboot that some of you know about that’s separate
from the BIA...A real BIE would have its own administrative budget and staff who would be
responsible for accounting, budget, contract and facility information technology and not have
to go over to the BIA. Michael Hughes (Gila River Consultation)
We call Albuquerque. We don’t get a correct answer. We can’t reach anybody. We send an
email to Billings, and then it goes to Albuquerque, and then it comes back through Billings, and
then back to me again. It just makes it kind of frustrating. Harvey Whitford, Principal, Wa He
Lut Indian School (Auburn Tribal Consultation)
One of the things I’m happy to see in the Report is that there appears to be pushing things out of
the central office and more into the field with technical assistance. And I’m hoping that that
technical assistance will also create either bureau offices, like our office or tribally created
offices like our office, to give the schools the technical assistance they need to maintain the
buildings. Michael Segroves, Eastern Oklahoma Tribal Schools (Anadarko Tribal Consultation)

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Unfortunately, DOI continues to fail at including education experts and educators in key policy
and budget decisions. As we work to find ways to increase the effectiveness of the BIE and
improve the state of Native education, we must have people leading in Washington who
understand the needs of our students and have the authority to drive successful reform.
National Congress of American Indians and National Indian Education Association
Reform Area 3: Promote Self-Determination
I want to give a suggestion that you add another pillar. It’s not enough what you have down here
[in the draft Report]. And to me it’s unconscionable that you’ve left off what should have its
own pillar, culturally based education and immersion schools. And I’m not talking about
teaching our Native languages for one hour a day or for half an hour a day. What I’m talking
about is immersion magnet demonstration schools within existing Bureau of Indian Education
schools. This is something that’s deserving of its own pillar. Ryan Wilson, President, National
Alliance to Save Native Languages (Pine Ridge Tribal Consultation)
Just this past week I was at Carlisle Barracks in Carlisle, Pennsylvania [the First federal school
for American Indian students]. I looked at the facilities and those kids – in fact, the school there
gave me a picture of the very first class that came from – the students that came from Pine Ridge
Reservation, and you look at those faces – and they’re very proud of this. But if you look at the
faces of those children, of these kids, they’re not proud to be there. In every picture you ever see
of Indian schools during that era, you don’t see any smiles. You don’t see any acceptance. What
you see are people – are kids that have been trained to sit, act, a certain way for fear of a lot of
things. Jefferson Keel, Lieutenant Governor of the Chickasaw Nation (former President of the
National Congress of American Indians) (Anadarko Tribal Consultation)
I read the Study Group pillars, and I don’t see any concrete recommendations that allow for
self-determination. I don’t see recommendations for waivers to NCLB rules and regulations or
[tribal] alternatives to AYP… The United States Government must give free reign in determining
and implementing our own educational programs. I think there’s still time to do this, and I hope
you will change your education pillar to reflect this official request, because I don’t see anything
in your study yet. Jesse Taken Alive (Anadarko Tribal Consultation)
Looking at the preliminary report, I’ve read it and I do appreciate the fact that the Study Group
seemed to have listened and heard what we have said. So I look at the tribes having – that
capacity builds and helping with the capacity to operate these bureau-funded schools, because
I do believe that we have those children’s interest at heart and we know more about them at the
local level than they do in Washington D.C. Gloria Sly, President, Tribal Education
Departments National Assembly (Anadarko Tribal Consultation)
I appreciate the tribal leaders that are here because ultimately it starts at home…I’ve been
to a lot of tribal education (inaudible), and I think until our tribes actually take ownership of
[education], and say, we’ve got to get a head start, we’ve got to get a kindergarten, we’ve
got to start reading programs in our homes, it’s – we’re always going to have problems
in our education system. Tony Dearman, Superintendent of Riverside Schools (Anadarko
Tribal Consultation)

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And I just want to say that worrying about the Navajo Nation is not exactly a bad thing. It’s
actually a good thing; it’s building the capacity of tribes. And I think one thing is to be able to
give the Navajo Nation the resources to be able to help and service our schools and that’s what
I see as one of the great concepts that’s contained in this is helping the tribe build its capacity
because one of the causes that’s come up is the tribe is not ready. I t’s really a heart breaker to
think that your own people, your own nation, your government can’t do it. It just doesn’t fly.
The only way the tribe can do it is if it’s allowed the ability to do it. And I’m hoping through
something contained in this document that the Department of Education and other tribal
educations departments are allowed that same opportunity to do for their own schools. Matt Tso,
Legislative Analyst, Dine Department of Education (Gila River Tribal Consultation)
A part of tribal sovereignty and self-determination is our right to fail. We have that right, and we
are asking for that right. But we also have the right to succeed, and we have the know-how, as it
was pointed out earlier, we have the knowledge. Basically we’re talking about tribal control.
Robert “Tuffy” Lunderman, Rosebud Sioux Tribe Council Member (Pine Ridge Consultation)
We talk about building foundations and how tribes can take over these schools. We’ve got to
give the tribe a reason to take over this school. They’ve got to want to do that. You know, and
you’ve got to get a foundation – you’ve got to give a foundational reason for wanting to give you
money to help these students. The only way we can do that is to give them evidence that we
truly mean what we say when we say we’re going to reform this system and raise the level and
quality of education in this country for our Indian students. And if we truly believe that, then we
can do it. Jefferson Keel, Lieutenant Governor of the Chickasaw Nation (former President of the
National Congress of American Indians) (Anadarko Tribal Consultation)
Immersion programs not only increase academic achievement, but also guarantee that a student’s
language will be carried forward for generations. Our communities’ unique cultural and
linguistic traditions are crucial for the success of our students and are critical cornerstones
for providing relevant and high quality instruction as part of an education that ensures Native
students attain the same level of academic achievement as the majority of students. NIEA
and NCAI request the BIE ensure that reform strengthens the ability of the Federal Government
to support tribes in the delivery of culturally-relevant curricula. National Congress of American
Indians and National Indian Education Association
The report says the BIE will transition from running schools to serving tribes. However, the BIE
must ensure it has the ability to continue serving tribes who decide their trust principles would be
violated if the agency forces a tribe to assume operational responsibility of a former BIE school.
National Congress of American Indians and National Indian Education Association
Rather, we need a change in capacity and a restructuring that supports community collaborators
who will sit with a principal chief in Oklahoma or a pueblo governor in New Mexico to find
solutions to local problems. National Congress of American Indians and National Indian
Education Association

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The 3-year competitive incentive-based grant, similar to existing Race to the Top initiatives for
which BIE continues to be excluded, could provide much-needed resources to tribes for
accelerating local reforms and aligning education services to tribal education priorities that
include language and culture. Further, performance metrics for the grant could include student
attendance rates, graduation rates, college enrollment rates, and measures on educator
accountability. In order to catalyze reform efforts and create a set of high-performing, tribally
controlled grant schools, BIE could also provide on-going technical assistance to building the
capacity of those schools that applied for, but did not receive, a grant. National Congress of
American Indians and National Indian Education Association
It is important to note that a competitive grant idea has garnered some opposition in remarks
from tribes. To address this, such a competition should not replace existing funds from other
much-needed programs. National Congress of American Indians and National Indian Education
Association
Reform Area 4: Comprehensive Supports through Partnerships
The kids that come to these schools, in many cases, come from troubled backgrounds. Many
times they come from broken homes; they come from places where they’re not wanted; they’re
not love and they’re not treated very well because of a lot of things. Regardless of whether we
can blame it on drugs, alcohol, or the dysfunctional family unit. Whatever it is, these kids come
here and they come here with an expectation that they need to be treated in a humane way, in a
loving way. Sometimes that happens and sometimes it’s not so good. I’m not saying that just
about Riverside, I’m talking about all the BIE schools across the country. Jefferson Keel,
Lieutenant Governor (and former President of the National Congress of American Indians)
(Anadarko Tribal Consultation)
The next thing is that our students suffer from trauma. This is another thing that we to at Alamo
since we have a clinic there we have – how many people – how many schools here believe that
their students have because of poverty and unemployment and the issues going on at home their
students have ideations of either suicide or homicide or a combination? Everybody here, right?
Everybody. Michael Hawk, Executive Director, Alamo Navajo School Board (Gila River
Consultation)
If we want to really do innovative work to support these gaps and bridge these gaps and
problems that our children are falling through the cracks, then we need more innovative ways of
looking at partnerships in regards to these social problems. Our children are, the majority of our
children in some way or another have been or are victims of the emotional trauma, of historical
trauma, and so we – without dealing with those social problems as well, that’s when you start to
see the high dropout rate, the cycle of, you know, most of our children not getting through high
school, let alone starting to see the changes and actually making it to the 8th grade so we need to
start to look at that in a very innovative way including the students as well with – excuse me –
with teachers. Lieutenant Governor Steven Lewis, Gila River Indian Community (Gila River
Tribal Consultation)

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I like the information that’s being shared. But I am concerned about the factors of the students
suffer from trauma. That’s kind of the psychosocial issue that’s identified here as impacting
academic performance. And many of our tribal students not only come from families of trauma,
we can list all of those social ills, and we all would understand. But my concern is that they tend
to be more of our transient students. And that’s something that’s not being tracked…But when
we have transient students coming and going and rolling over, possibly 30 percent of the
population in our tribal school is in and out, relocating from one community to another that has
an impact on academic performance. Lynn Palmanteer-Holder, Tribal Council Member,
Confederated Tribe for the Colville Reservation (Auburn Tribal Consultation)
Reform Area 5: Budget Alignment
The Blackwater Community School’s education program from early childhood through grade
two receives funding from the Department of the Interior, Bureau of Indian Education. Since
school year 2009-2010 funding has risen only 5 percent, less than $330.00 per student.
Historically funding would have risen by 12 percent over the same 3 year time period.
Insufficient funding has resulted in the school not being able to provide raises to its faculty and
support staff for the past 4 years, there by affecting retention of high quality instructional staff.
The No Child Left Behind legislation requests schools to hire and retain highly qualified staff.
This is impossible to do given the current budget situation, as we have to complete with other
schools in our area. We have also been unable to provide professional development of
opportunities for teachers to ensure they remain current in practices that are changing due to the
implementation of the Common Core standards. Without adequate funding schools in the BIE
school system are not able to meet this requirement. Due to lack of funding we have been unable
to purchase new textbooks and computers to support the move to the new standards that are
supported by the Department of Education and Arizona State Department of Education. We also
have not been able to provide extra-curricular activities, summer education programs to retain
and enhance learning, and address much needed deferred maintenance. Henry Pino, Blackwater
School Board President (Gila River Tribal Consultation)
The other thing [we are] on the same page is, I think I hit on the budget is not aligned with the
school improvement. I do think you need to look into de-categorization of funding because it
makes you more nimble and multi-faceted in the construct of its approach. You might look into
that because now it’s very rigid when you try to – we went through this in early childhood and
Head Start funding where we couldn’t commingle funds and then we got that. There is pass
through the bond administration so that helps. Michael Hawk, Executive Director, Alamo Navajo
School Board (Gila River Consultation)
The proposal by the Study Group to build capacity of tribal the organizations and grant school is
commendable, however, it is also noted there are additional resources to support this effort.
Suzanne Acuna, Blackwater Community School, School Board Member (Gila River Tribal
Consultation)

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[O]ne of the biggest obstacles to tribal control of schools is inadequate funding for tribal grant
support costs. The CFO for the Santa Fe school mentioned that this morning. One of the great,
great things that happened right now with Assistant Secretary Washburn is full funding for
contract support costs for tribal 638 contracts in self-government. That’s a historic change. So
they’re doing it with 630, tribal 638 and it’s time to do that with the schools. The budget request
for 2015 for tribal grant support costs is $48 million which is the same as the 2014 operating
cost. In last year’s read back it was pointed out that $48 million would fund 67 percent of the
need. Well, full funding need for tribal grant support costs is $5 million. So if we remove that
impediment to tribal contracting or grant status for schools, BIA should request $75 million for
tribal grant support costs in the 2016 budget. Michael Hughes (Gila River Tribal Consultation)
We face the dilemma by having to use our ISEP funds to pay for electrical bills, custodial help,
heating and general maintenance. We pay about $250,000 out of our ISEP funds alone for this
every year. And administrative cost grants are being seriously constrained, so we are having
have a little bit of a problem with segregation of duties. Shirley Gross (Pine Ridge Consultation)
The question about using carry-over money for other unallocated type projects, my experience
over many, many years… money that’s carried over, because it has such categorical rules, you’re
restricted and don’t use it – you can’t just go out and do, you know, a project for the school or
like playground equipment. Title I says you can buy supplies, but you can’t buy textbooks with
it. The rule always has been that textbooks are expected to be purchased out of your school
budget, which would be your general fund. So there are these rules that you have to learn.
[K]nowing the rules is important in understanding how you can use that extra carry-over money.
Most of the time, if it’s in category funding, special education, for example, you can’t just go out
and use it for anything. I would love to use my carry-over money, special education, Title I, and
so on, but I’m restricted in the rules that that funding came down through. The auditors will
come calling and ask, why are you spending that money? And I have to be able to justify
that…Great, [the stimulus funding] will help us, but because it was in Title I or special
education, we could not use it in our general education fund, which is where we needed it.
So if I’m laying a math teacher off, for example, special education fund, I couldn’t use that.
And also Title I is limited to supplement, not supplant. So that’s the foundational principle.
So it’s something that the school should be doing or offering, is general education, which would
be our general fund. We couldn’t use these other dollars. Michael Bundy, Superintendent, Two
Eagle River School (Auburn Tribal Consultation)
I have a comment as an administrator. I’m like freaking out if somebody has carry-over. Why
are you not spending your money? There has to be a really good justification why there’s any
money left, especially with the underfunded programs that we’re all operating. I mean,
sometimes in my opinion, in my observation, that has been because of the lack of administrative
fiscal management experience of an administrator…So I would be wanting to assess why there’s
so much carry-over. Is it a spending mechanism that has restrictions? They don’t know how to
spend it? Whatever. There has to be some kind of intervention somewhere. Lynn PalmanteerHolder, Tribal Council Member, Confederated Tribe for the Colville Reservation (Auburn Tribal
Consultation)

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[C]arry-over funds flexibility would be greatly enhanced if administrators could take any carryover funds that they have and use them for the purpose of for their school board, and where they
as the leader of the school feel that it will advance the students in their culture, social, and safety
practices at the school. My focus is on all of that. Harvey Whitford, Principal, Wa He Lut Indian
School (Auburn Tribal Consultation)
To support BIE budget autonomy and tribal negotiations, we also request that BIE reform
include the creation of a Tribal Education Budget Council that functions similar to the Tribal
Interior Budget Council. National Congress of American Indians and National Indian Education
Association
For too many years, DOI had made other programs under its purview priorities while Native
Education programs and the BIE were considered afterthoughts. National Congress of American
Indians and National Indian Education Association
As a result of BIA authority over the BIE budget, the BIE is often low in priority when compared
to other programs. National Congress of American Indians and National Indian Education
Association
The BIA currently funds only 65 percent of support costs in the 126 tribally managed schools
and residential facilities under the BIE purview. This forces the schools to divert critical
classroom education funding in order to cover the unpaid operational costs, which make it
unrealistic to improve educational outcomes and bridge the achievement gap among Native and
non-Native students. National Congress of American Indians and National Indian Education
Association
Cross-Cutting and General Comments
Another recommendation is to streamline bureaucratic operational processes such as hiring
staff, contracting for services, purchasing basic supplies, requests for repairs, and improve
responsiveness of service to meet the unique needs of a school and school year
operations...Another is to prepare our principals and teachers for the implementation for the
Common Core and insure an effective information technology infrastructure to administer the
21st Century assessment...And lastly, improve the quality of technical assistance and support to
all schools including safety and capacity of schools to transition to tribally-controlled schools.
Again, these are our recommendations. Thank you. Greg Mendoza, Governor, Gila River (Gila
River Consultation)
Thanks for being upfront. Seriously. I’m talking about the fact that we have somebody who
actually comes from Department of Education who’s actually speaking the truth and sitting next
to BIE. And this is collaboration. And that’s a good thing. Lynn Palmanteer-Holder, Tribal
Council Member, Confederated Tribe for the Colville Reservation (Auburn Tribal Consultation)
I have heard from tribal leaders that, oh, the BIA is having another consultation. Why should we
go? We go, they’re going to tell us what they’re going to do anyway. And so with that kind of
attitude I think it’s permeated for a long time because of the BIE process. But I can tell you that,

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you know, through this process and the people involved in this, they’re committed to make
changes. In the past decade or maybe more we’ve never had an opportunity to make some
meaningful changes within the BIE’s system. I heard a former BIE Director who spent a year
up in Washington DC and said “I spent all my time listening to people telling me why we can’t
change this. Why we can’t do this; why we can’t do that.” And I think this process here is an
eye-opener. You know, we’ve got here not only the Secretary but also – both the Department
of Interior and Education but also the Administration. They want to make changes. We need to
have changes. Quinton Roman Nose, Executive Director, TEDNA and member of Riverside
Indian School Board (Anadarko Tribal Consultation)
I think there are so many significant flaws in this [draft Report], it’s almost, you could say an act
of folly so much that’s in it, but there’s also some really powerful important things in here that
I hope you don’t lose sight of because there’s so many significant flaws. And so one of the
things is they validated a lot of issues the tribal people have been saying for decades that is
wrong with the Bureau of Indian Education, Bureau of Indian Affairs. For the first time it’s been
validated. It’s been put in a report for everybody to look at, so I commend you guys for that.
That’s transparent; that’s honest. And that’s something that we all can go forward and work
with. There are also some really positive solutions in here as well, and I hope we don’t lose sight
of that. Ryan Wilson, President, National Alliance to Save Native Languages (Pine Ridge Tribal
Consultation)
I am so appreciative of the Bureau’s efforts to solicit input in what I see will become
transformational in terms of the journey of education that our institutions [will undergo]. And
it’s good to see our tribal leadership here, and our tribal educators who will be charged with
helping to implement the vision that you have outlines. And these four pillars are amazing in
what they propose. They will provide a basis for, again, the transformation that is necessary to
move us away from a bureaucratic monster that is cumbersome and unresponsive and lacking in
the compassion that is conveyed by some of the staff members that we have here in our midst. I
think it’s important for us to feel that the institution is responsive. And I think the findings of the
study go a long way. I know there’s trepidation, I know there’s concern that maybe we will bite
off more than we can chew. But as my colleague, Mr. Anderson, conveyed, we have to look at
the ending, it doesn’t matter what our beginning was. Jacob Tostigh, former Indian Education
Director, Anadarko Public Schools (Anadarko Tribal Consultation)
We need to keep moving forward. If we lose some of the acceleration we’ve had, we’re not
doing justice to the families, the tribe, and the children that come into our gates. I’ll give you a
small example. Our testing started this week, the Washington State test. We had a rally on
Friday. We’re going to rock it. We’re going to rock the test. We prepare the children for the
rally that week. We had a lot of thinking go into it…We’re all in it, including the families,
the tribes and the communities the kids come from. The State test is all of us, including the
custodians, the cooks, the bus drivers. We’re all there. Harvey Whitford, Principal, Wa He Lut
Indian School (Auburn Tribal Consultation)
Just to close, I think one of the things that has bothered me for the longest time is how we can
build schools in Afghanistan and Iraq, and we can buy buildings there, but we can’t find the
millions of dollars that we need to fix [the BIE]. And I think that’s what we need to do, and use

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all the leadership and power that we have to do that. Michael Segroves, Eastern Oklahoma
Tribal Schools (Anadarko Tribal Consultation)
So once [American Horse School] got the School Improvement Grant, I thought, “here we go,
we’re going to make a difference.” And we did. We went up our 60 points. And the next year
we had our advanced education accreditation inspection at American Horse School. The lowest
score we received we got a two in technology because our BIE bandwidth was not wide enough
so we could take the exams that we were supposed to take. Gloria Coats-Kitsopoulos, School
Superintendent, American Horse School (Pine Ridge Tribal Consultation)
I have seen a lot of initiatives come and go. I’ve seen a lot of initiatives start and fail and get
sidetracked. And it’s not often that I get an opportunity to talk positively about something I see
the Federal Government trying to do. And I’m glad to be able to do that today. Michael Hughes
(Gila River Tribal Consultation)
If you go to any branch chief at any agency in the BIA and say, what are your GPRA measures
they can’t answer that question because there’s no communication, no discussion, no training,
within the BIA and every BIA staff person is expected to figure that out on their own.
Michael Hughes (Gila River Tribal Consultation)
Blackwater Community School supports the Bureau’s effort to improve educational
opportunities for all Indian students. Many of the recommendations contained in the study
group’s report reflected many recommendations from previous reports on Indian education
beginning in 1920s including those from the National Academy of Public Administration in
1995 and 2001...This has been a pattern of Indian Affairs to start an initiative but fail to continue
them. We urge Indian Affairs to carry through with this initiative. Suzanne Acuna, Blackwater
Community School, School Board Member (Gila River Tribal Consultation)
The focus for our Tribe will follow the four pillars of reform. The Hopi tribe wants to identify,
recruit, retain, and empower diverse, highly effective teachers and principals. We want to build
a responsive structure with appropriate authority, resources, and services so that our students can
attain high levels of student achievement. The budget will be established to build capacity to
insure best practices are implemented. And, finally, we want to cultivate family and community
to partner with all state holders to ensure all students are successful. Hopi Tribal Chairman,
Herman Honanie (Gila River Tribal Consultation)
[W]e do not want the Federal Government to abrogate, to stop, to in any way start to back away
from their trust responsibilities to Indian Country in regards to education. I think that’s what
tribal leaders, especially me, are most concerned about. Lieutenant Governor Steven Lewis, Gila
River Indian Community (Gila River Tribal Consultation)
By the occupation that you’ve had today, just by looking at your plan, in theory it looks good, on
paper it looks good. But when you actually implement it at our school, at our Navajo Nation, it’s
going to be hard to implement it the way that you want because of the political clout of some of
these people and our tribal history of managing money and managing programs...I think in
theory it looks like a good model and it could be workable, but with people who knew how to

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manage and be able to have the right credentials and not be politically motivated, then it could
work. Jeffrey Mike, Pinon Community School, School Board President (Gila River Tribal
Consultation)
I have spoken to the general assembly on the need for tribal leaders to step up and elevate
education on our agenda and to begin to actively participate in issues related to education and
education planning. Why? You can talk about AYP, all the issues structurally within the –
administratively within the school system. But the reality is, tribal leaders are the ones who
have - we are the ones ultimately responsible to set policy, prioritize what is going to be
funded, how we’re going to allocate those funds, what percentage of funds goes where.
Lynn Palmanteer-Holder, Tribal Council Member, Confederated Tribe for the Colville
Reservation (Auburn Tribal Consultation)
I do like what you’re saying. I do like what is in the report – the preliminary report that you have
put out. You will be in the work-study group and I’m looking forward [to working with you]…
Other individuals, in the same capacity, as the Director of BIE and OIE who have not been able
to move and make reform, but I think that with the President, who is listening, who is ordering
this, two Secretaries and more who are willing to come together to work on these issues, that this
may be the time when we can see improvement in our BIE-funded schools and the changes and
reforms that you make. Gloria Sly, President, Tribal Education Departments National Assembly
(Anadarko Tribal Consultation)
Sometimes, as you’ve heard, our bandwidth is so bad in our most of our tribal schools, there’s
email I don’t even get. I can click on the email, I’ll go get up and visit a classroom, and come
back, and it hasn’t opened. I live in an RV park 5 days a week. My RV has better connectivity
than the school. And I’m just using a little jetpack through Verizon. We have got to solve that
problem too. Our kids are lacking educational opportunities, because we can’t access the
Internet. Mark Jacobson, Principal and Acting Superintendent, Quileute Tribal School (Auburn
Tribal Consultation)
I don’t know where BIE is on the community net or the USDA fiber work that’s being done
across the Nation, but there was – every state has been receiving funds for rural communities to
gain access, and schools are a priority. Schools and hospitals. It’s kind of scary to hear that
Quileute is still out there not having fiber or broadband access, and that should be federally
funded. I mean, that’s what’s happening across the Nation. And a number of schools like
Tulalip and Yakima Nation and a number of nations or tribes around Washington State have
benefited from that program. So I wish that BIE would be in there fighting with USDA to get
some of those dollars and break some ground to get fiber out to our schools. That’s a priority.
Lynn Palmanteer-Holder, Tribal Council Member, Confederated Tribe for the Colville
Reservation (Auburn Tribal Consultation)
Currently, teachers have been cut from using copy paper. Pencils, sharpeners, and other
materials are so inferior they break constantly. Teaching positions are unfilled. And, wireless
Internet goes unused without wireless computers to use them on (all most all computers hadn’t
had wireless cards installed when wireless networks were made available). Bradley Budinger

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The SWO operates two PL 100-297 Grant schools which encompasses nearly 700 Sisseton
Oyate Children. The 2013 facility funding is constrained 48.56 percent which forces the school’s
to supplement needed facility operational funding from other budgets. We are requesting field
hearings regarding the constrainment of facility funding. This funding level is vastly inadequate.
Further cuts due to sequestration of 14/15 school year budgets will be devastating. Chairman
Robert Shepherd, Sisseton Wahpeton Oyate
One of the biggest concerns Northern Cheyenne has is the construction program. They have a
100 year old building for their school. It has no new technology and is dilapidated. BIA has
given the Northern Cheyenne some temp buildings, but there was nothing that went with them.
Thus, these buildings are not in use. Further, if they don’t have computers and new instruction
materials, the buildings can only go so far. Northern Cheyenne Nation via Quinton Roman Nose,
Executive Director, TEDNA
Despite the overwhelming data on the school facility construction and renovation needs, and a
plethora recommendations submitted by tribes and the School Facilities and Construction
Negotiated Rulemaking Committee, the BIE has yet to make significant changes or initiate a
thoughtful, deliberative approach in resolving the issues. At a minimum, the BIE must comply
with the congressional directive to reopen the school construction priority process. Equally
important though, BIE and the Administration must advocate for replacement school
construction funding. In our view, the Administration should seek a similar 5-year, $5 billion
special funding package that was employed to bring parity among the Department of Defense
funded schools through repair or replacement. We also note that, unlike the BIE Facilities Plan,
the DOD 5-year Facilities Plan includes the replacement schools costs for projects anticipated to
occur during that period. Submission Dzilth-Na-O-Dith-Hle Community Grant School

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APPENDIX C
Academic Performance for BIE-Funded Schools as Measured by the Status on Adequate
Yearly Progress (AYP), 2012-13
AYP Status SY2012- BIE-Operated
13
Schools

Tribally Controlled Total
Schools

No. of Schools

57

126

183

Met AYP

9

17

26

Met AYP in New
Mexico (2011-12)

5

3

8

Total Schools Met
AYP

14 (24%)

20 (17%)

34 (19%)

No. of Schools under
“Restructuring” (Low
Performance for
years)

17 (29%)

42 (35%)

59 (34%)

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APPENDIX D
Numbers of Full-Time Employees (FTEs) at BIE-Funded Facilities
1.

Numbers of FTEs at BIE Day Schools (Non-Dormitory Facilities)
State

Grade
Range

Students Tribal
Enrolled or BIE

Employees
(All Staff)

Certified
Educators

CA

6th – 12th

115

Tribal

Noli School

44

18

ND

6th – 8th

319

BIE

Turtle Mountain Middle School

80

40

NM

6th – 8th

98

Tribal

Laguna Middle School

34

9

AZ

7th – 12th

623

Tribal

Hopi Jr/Sr High School

159

53

NC

7th – 12th

459

Tribal

Cherokee High School

112

66

NM

7th – 12th

216

Tribal

Shiprock Northwest High School

137

48

NV

7th – 12th

78

Tribal

Pyramid Lake High School

41

13

MS

7th – 8th

167

Tribal

Choctaw Central Middle School

41

23

AZ

9th – 12th

115

BIE

Tohono O’odham High School

20

10

ND

9th – 12th

455

Tribal

Turtle Mountain High School

261

119

WA

9th – 12th

67

Tribal

Yakama Nation Tribal School

37

10

WA

9th – 12th

107

Tribal

Lummi High School

117

63

IA

K – 12th

260

Tribal

Meskwaki Settlement School

98

43

AZ

K – 12th

322

Tribal

Rock Point Community School

76

32

AZ

K – 12th

424

Tribal

Dishchii’bikoh Community School (Cibecue)

90

30

FL

K – 12th

117

Tribal

Miccosukee Indian School

55

33

KS

K – 12th

46

Tribal

Kickapoo Nation School

33

10

MI

K – 12th

106

Tribal

Hannahville Indian School

50

31

School Name

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July 9, 2014: Revised for typographical and formatting inconsistences

WI
WI

Grade
Range
K - 12th
K - 12th

WY

K - 12th

184

Tribal

St Stephens Indian School

71

36

AZ

K-2nd

201

Tribal

Blackwater Community School

42

14

NM

rd

84

BIE

Bread Springs Day School

23

12

rd

52

BIE

Sanostee Day School

12

5

th

Pine Springs Day School

20

5

Casa Blanca Community School

48

23

State

NM

K-3
K-3

Students Tribal
School Name
Enrolled or BIE
224
Tribal Lac Courte Oreilles Ojibwa School
372
Tribal Oneida Nation School

Employees
(All Staff)
105
130

Certified
Educators
46
100

AZ

K-4

89

BIE

AZ

K-4th

280

Tribal

NM

th

58

BIE

Beclabito Day School

21

12

th

96

BIE

Tse’ii’ahi’ Community School (Standing Rock)

28

16

ND

K-5

th

708

BIE

Turtle Mountain Elementary School

111

78

NM

K-5th

208

Tribal

Laguna Elementary School

32.5

17

SD

th

219

Tribal

Crow Creek Sioux Tribal Elementary School

31

9

th

77

Tribal

Little Singer Community School

27

7

AZ

K-6

th

172

Tribal

Kin Dah Lichi’i Olta

46

8

AZ

K-6th

123

BIE

First Mesa Elementary School

28

15

AZ

th

154

Tribal

Hopi Day School

38

12

th

87

BIE

Keams Canyon Elementary School

16

8

AZ

K-6

th

196

Tribal

Moencopi Day School

48

14

AZ

K-6th

265

Tribal

Second Mesa Day School

57

19

AZ

th

399

Tribal

Salt River Elementary School

61

40

th

44

BIE

Cove Day School

8

5

NM

AZ

AZ

AZ

K-4
K-4

K-5
K-6

K-6
K-6

K-6
K-6

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State

Grade
Range

MS

K-6th

628

Tribal

MS

K-6th

126

NM

th
th
th

NM

K-6
K-6

Students Tribal
Enrolled or BIE

Employees
(All Staff)

Certified
Educators

Pearl River Elementary School

99

71

Tribal

Standing Pine Elementary School

33

17

247

Tribal

Atsa’ Biya’ a’zh Community School

41

17

29

BIE

San Ildefonso Day School

7

3

Santa Clara Day School

23

13

Te Tse Geh Oweenge Day School

8

4

School Name

NM

K-6

124

BIE

NM

K-6th

14

Tribal

NM

th

166

BIE

Isleta Elementary School

29

18

th

143

BIE

Jemez Day School

27

14

NM

K-6

th

352

BIE

Baca/Dlo’ay Azhi Community School

61

39

WA

K-6th

181

Tribal

Lummi Tribal School System

117

63

NM

th

400

BIE

San Felipe Pueblo Elementary School

64

44

th

76

BIE

T’siya Day School (Zia)

18

11

th

Black Mesa Community School

21

5

Cottonwood Day School

34

13

Chilchinbeto Community School

40

14

NM

NM

K-6
K-6

K-7
K-7

AZ

K-8

39

Tribal

AZ

K-8th

246

BIE

AZ

th

131

Tribal

th

219

BIE

Tonalea Day School

37

16

th

AZ

K-8
K-8

AZ

K-8

185

BIE

Santa Rosa Day School

33

19

AZ

K-8th

72

BIE

Havasupai Elementary School

11

6

AZ

th

108

Tribal

Hotevilla Bacavi Community School

38

12

th

191

BIE

Red Rock Day School

37

20

AZ

K-8

th

473

Tribal

Gila Crossing Community School

83

32

AZ

K-8th

211

BIE

John F. Kennedy Day School

45

28

AZ

K-8
K-8

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July 9, 2014: Revised for typographical and formatting inconsistences

State

Grade
Range

AZ

K-8th

254

BIE

AZ

th

150

BIE

th

K-8

Students Tribal
Enrolled or BIE

Employees
(All Staff)

Certified
Educators

San Simon School

46

31

Santa Rosa Ranch School

16

8

School Name

ID

K-8

113

Tribal

Coeur d’Alene Tribal School

35

13

ID

K-8th

90

Tribal

Shoshone-Bannock School District No, 512

36

21

ME

K-8th

101

Tribal

Indian Township School

58

21

ME

th

97

Tribal

Beatrice Rafferty School

40

24

MI

K-8

th

283

Tribal

JKL Bahweting Anishnabe School

102

46

MS

K-8th

200

Tribal

Bogue Chitto Elementary School

55

36

MS

K-8th

249

Tribal

Conehatta Elementary School

58

39

MS

th

144

Tribal

Red Water Elementary School

40

23

MS

K-8

th

140

Tribal

Tucker Elementary School

36

22

NC

K-8th

511

Tribal

Cherokee Elementary School

102

68

ND

K-8th

524

Tribal

Tate Topa Tribal School

179

67

ND

K-8

th

140

Tribal

Theodore Jamerson Elementary School

66

27

ND

K-8

th

205

BIE

Dunseith Day School

43

23

ND

K-8th

248

BIE

Ojibwa Indian School

56

27

ND

K-8th

33

Tribal

Twin Buttes Day School

50

24

NM

th

84

Tribal

Ohkay Owingeh Community School

21

9

NM

K-8

th

159

BIE

Taos Day School

37

21

NM

K-8th

208

BIE

Sky City Community School

39

24

NM

K-8th

106

Tribal

Na’Neelzhiin Ji’Olta (Torreon)

44

13.5

NM

th

163

BIE

Ojo Encino Day School

25

13

K-8

K-8

K-8

K-8

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July 9, 2014: Revised for typographical and formatting inconsistences

State

Grade
Range

Employees
(All Staff)

Certified
Educators

NM

K-8th

134

Tribal

Dibe Yazhi Habitiin Olta’, Inc. (Borrego Pass )

42.5

11

NV

K-8th

12

Tribal

SD

th

Duckwater Shoshone Elementary School

4

1.5

261

th

Tribal

American Horse School

43

12

SD

th

209

Tribal

Loneman Day School

55

12

K-8

172

Tribal

Porcupine Day School

46

14

SD

K-8th

133

Tribal

Wounded Knee District School

38

14

SD

th

52

Tribal

Rock Creek Grant School

31

9

th

83

Tribal

Sitting Bull School

33

7

SD

K-8

th

155

Tribal

Enemy Swim Day School

68

22

WA

K-8th

119

Tribal

Wa He Lut Indian School

38

14

WI

th

202

Tribal

Menominee Tribal School

43

26

120

Tribal

Ahfachkee Day School

59

24

25

13

36
6848

22
3277.2

SD

SD

FL

K-8
K-8

K-8
K-8

K-8

th

PK-12

th

Students Tribal
Enrolled or BIE

School Name

LA

PK-8

91

Tribal

Chitimacha Tribal School

ME

PK-8th

87
25611

Tribal

Indian Island School
TOTALS

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2.

Number of FTEs at BIE Boarding Schools (having a BIE-funded academic unit)
State
SD
OK
ND
SD
AZ
MS
NM
AZ
AZ
CA
NM
NM
OK
OR
SD
AZ
AZ
NM
SD
SD
SD
AZ

Grade
Range
5th - 8th
4th - 12th
5th - 8th
6th - 12th
6th - 8th
7th-12th
7th-12th
9th-12th
9th-12th
9th-12th
9th-12th
9th-12th
9th-12th
9th-12th
9th-12th
K-12th
K-12th
K-12th
K-12th
K-12th
K-12th
K-5th

Students Tribal
Enrolled or BIE
173
Tribal
476
BIE
89
Tribal
252
Tribal
100
Tribal
398
Tribal
596
Tribal
304
Tribal
408
BIE
328
BIE
246
Tribal
454
BIE
365
Tribal
343
BIE
238
BIE
152
Tribal
329
Tribal
270
Tribal
838
BIE
850
BIE
249
Tribal
170
Tribal

School Name
Pierre Indian Learning Center
Riverside Indian School
Circle of Nations
Crow Creek Reservation High School
Theodore Roosevelt School
Choctaw Central High School
Santa Fe Indian School
Greyhills Academy High School
Many Farms High School
Sherman Indian High School
Navajo Preparatory School
Wingate High School
Sequoyah High School
Chemawa Indian School
Flandreau Indian Boarding School
Leupp School, Inc.
Rough Rock Community School
Pine Hill Schools
Cheyenne-Eagle Butte School
Pine Ridge School
Marty Indian School
Hunters Point Boarding School

58

Employees
(All Staff)
93
195
91
26
23
131
205
114
80
111
101
134
117
136
87
59
111
111
132
154
109
45

Certified
Educators
26
59
19
13
8
51
63
38
28
25
25
43
40
31
20
17
40
27
74
80
33
11

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State
AZ
AZ
AZ
NM
NM
NM
UT
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
AZ
NM
NM
NM

Grade
Range
K-5th
K-6th
K-6th
K-6th
K-6th
K-6th
K-6th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th
K-8th

Students Tribal
Enrolled or BIE
139
BIE
111
Tribal
105
Tribal
189
BIE
158
BIE
158
BIE
162
BIE
278
Tribal
170
BIE
260
BIE
121
BIE
1276
BIE
159
BIE
179
Tribal
189
Tribal
363
Tribal
356
BIE
106
Tribal
388
Tribal
253
BIE
48
BIE
373
BIE

School Name
Jeehdeez’a Academy, Inc.
Wide Ruins Community School
Nazlini Community School
Mariano Lake Community School
Crystal Boarding School
Nenahnezad Community School
Aneth Community School
Many Farms Community School
Dennehotso Boarding School
Kaibeto Boarding School
Rocky Ridge Boarding School
Tuba City Boarding School
T’iis Nazbas Community School
Dilcon Community School
Greasewood Springs Community School, Inc.
Shonto Preparatory School
Kayenta Community School
Naa Tsis’aan
Lukachukai Community School
Pueblo Pintado Community School
Lake Valley Navajo School
T’iis Ts’ozi Bi’Olta’ (Crownpoint)

59

Employees
(All Staff)
32
36
36
39
35
44
40
80
36
50
28
232
49
46
64
123
87
32
89
70
18
82

Certified
Educators
11
10
9
19
13
23
16
28
15
21
14
114
17
14
19
44
37
11
32
38
8
37

July 9, 2014: Revised for typographical and formatting inconsistences

State
NM
NM
NM
NM
NM
AZ
WA

Grade
Range
K-8th
K-8th
K-8th
K-8th
K-8th
K-9th
K-9th

Students Tribal
Enrolled or BIE
110
BIE
396
Tribal
169
BIE
446
BIE
181
Tribal
113
BIE
147
Tribal
14731

School Name
Chi Chil’tah Community School
Ch’ooshgai Community School
Tohaali’ Community School
Wingate Elementary School
Dzilth-Na-O-Dith-Hle Community School
Seba Dalkai Boarding School
Paschal Sherman Indian School
TOTALS

60

Employees
(All Staff)
34
121
43
122
69.5
33
50
4185.5

Certified
Educators
16
44
18
46
16.5
12
16
1489.5

July 9, 2014: Revised for typographical and formatting inconsistences

3.

Number of FTEs at BIE Colleges

Employees

Instructors
(subset of
employees)

Annual Base Funding

Haskell Indian Nations University

201 (154)

38

$11,500,000

Southwestern Indian Polytechnic
Institute

103 (101)

22

$8,378,541

304

60

$19,878,541

State

Student
Enrollment

Name of Postsecondary
Institution

KS

846

NM

488

Totals

1,334

61

July 9, 2014: Revised for typographical and formatting inconsistences

4.

Numbers of FTEs at BIE Dormitories
*Pinon Community School and Hanaa’dli Community School/Dormitory, Inc. have kindergarten classrooms but do not house
those students. Shiprock Reservation Dormitory is operated by a high school. Jones Academy has an academic program for
grades 1-6 and 7-12 students attend public school. BIE has not developed a separate classification for this school up to this point.

State

Grades

Students

Operation

MT
NM
OK

1-12
1-12
1-12

115
10
60

BIE
Tribal
Tribal

SD

1-12

123

Tribal

OK

1-12
1-12
(1-6
Classes)

56

OK

Employees

Annual Base Funding

18
14
24

$1,787,243
$475,792
$1,078,210

22

$1,325,029

Tribal

Blackfeet Dormitory
Jicarilla Dormitory
Eufaula Dormitory
Sicangu Owayawa Oti
(Rosebud Dormitory)
Chickasaw Children’s
Village

40

$1,010,903

159

Tribal

Jones Academy*

77

$3,141,835

Hanaa’dli Community
School/Dormitory, Inc.*

29

$1,280,416

37
28

$2,350,602
$1,480,313

32.5

$1,448,170

35.5
20

$1,441,936
$1,201,243

11

$2,098,769

15
403

$974,309
$24,422,045

60

Tribal

AZ
AZ

1-12 (Kdg.
Classroom)
1-12 (Kdg.
Classroom)
7-12

83
138

Tribal
Tribal

AZ

9-12

113

Tribal

NM

AZ
UT

9-12
9-12

137
78

Tribal
Tribal

NM

9-12

71

Tribal

NM

9-12

99
1302

Tribal

Name of School

Pinon Community School*
Winslow Residential Hall
T’iisyaakin Residential
Hall (Holbrook)
KinLani Bordertown
Dormitory
Richfield Residential Hall
Shiprock Reservation
Dormitory *
Kinteel Residential
Academy (Aztec Dorm)
TOTAL
62

July 9, 2014: Revised for typographical and formatting inconsistences

APPENDIX E
Current Bandwidth at BIE-Funded Schools

School Name
Aztec High School Dormitory
Duckwater Shoshone School
Jeehdeez’a Elementary School, Inc.
Jones Academy
Nazlini Boarding School
Richfield Residential Hall
Theodore Roosevelt School
Tiisyaatin Residential Hall (Holbrook)
Wide Ruins Community School
Turtle Mountain Community Elementary
School
Turtle Mountain Community Middle
School
Turtle Mountain High School
First Mesa Day (Polacca)
Tuba City Boarding School
Flandreau Indian School
Marty Indian School
Pierre Indian Learning Center
Sicangu Owayawa Oti (Rosebud Dorm)
Wa He Lut Indian School
White Shield School
Tiospaye Topa School

1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1

2XT1
2XT1
4XT1
4XT1
3XT1
3XT1
3XT1
3XT1
3XT1

SEDTA
Recommended
Configuration
5Mbps
1Mbps
20Mbps
20Mbps
10Mbps
10Mbps
10Mbps
10Mbps
10Mbps

No Circuit

2XT1

N/A

0

No Circuit

2XT1

N/A

0

1XT1
3XT1
6XT1
5XT1
4XT1
1XT1
1XT1
1XT1
1XT1
3XT1

6XT1
3XT1
6XT1
4XT1
4XT1
4XT1
3XT1
3XT1
3XT1
2XT1

60Mbps
10Mbps
100Mbps
30Mbps
30Mbps
20Mbps
10Mbps
10Mbps
10Mbps
10Mbps

659
194
1234
365
338
254
112
128
157
193

Current
Recommended
Configuration Configuration

63

User Count
89
9
295
230
136
114
115
135
155

July 9, 2014: Revised for typographical and formatting inconsistences

Dunseith Day School
Blackwater Community School
Lac Coute Oreilles Ojibwa School
San Simon School
Santa Rosa Boarding School
Sky City Community School
Baca/Dlo’ay Azhi Community School
Keams Canyon Elementary School
Chinle Boarding School
Rocky Ridge Boarding School
Greyhills Academy High School
Ahfachkee Indian School
Coeur d’Alene Tribal School
Leupp Schools, Inc
Rough Rock Community School
Santa Fe Indian School Inc
Second Mesa Day School
Shonto Preparatory School
Tiospa Zina Tribal School
Moencopi Day School
Choctaw Central High School
Alamo Day School
Twin Buttes Day School
Wounded Knee District School
Casa Blanca Community School
Cherokee Central High School
Fond du Lac Ojibwe School
Loneman Day School
Navajo Preparatory School Inc
Nay-Ah-Shing School

1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
2XT1
1XT1
1XT1
No Circuit
2XT1
1XT1
1XT1
2XT1
2XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
2XT1
1XT1
1XT1
1XT1
1XT1

3XT1
4XT1
4XT1
4XT1
4XT1
4XT1
6XT1
2XT1
4XT1
3XT1
6XT1
4XT1
2XT1
4XT1
6XT1
6XT1
4XT1
6XT1
6XT1
4XT1
6XT1
4XT1
2XT1
3XT1
4XT1
6XT1
4XT1
4XT1
4XT1
4XT1
64

10Mbps
30Mbps
20Mbps
20Mbps
20Mbps
20Mbps
40Mbps
5Mbps
30Mbps
10Mbps
40Mbps
20Mbps
10Mbps
20Mbps
40Mbps
80Mbps
20Mbps
40Mbps
50Mbps
20Mbps
50Mbps
30Mbps
5Mbps
10Mbps
20Mbps
50Mbps
30Mbps
20Mbps
20Mbps
20Mbps

187
332
297
253
250
225
411
92
333
154
454
219
100
270
479
814
262
465
566
208
544
305
60
133
269
533
316
253
237
236

July 9, 2014: Revised for typographical and formatting inconsistences

St. Francis Indian School
Crow Creek Reservation High School
Gila Crossing Day School
Menominee Tribal School
Circle of Nations-Wahpeton Indian School
Crow Creek Sioux Tribal Elementary
School
Gila Crossing Day School North Campus
Lower Brule Tribal School
Lummi Tribal School
Chitimacha Day School
Indian Island School
Rock Point Community School
Hopi Day School
New Paschal Sherman Indian School
Ohkay Owingeh Community School (San
Juan)
Greasewood Springs Boarding School
Pine Hill Schools
Beatrice Rafferty School
Shoshone Bannock School
St. Stephens Indian School
Hanaa’dli Community School
Pyramid Lake High School

1XT1
1XT1
1XT1
1XT1
1XT1

6XT1
4XT1
6XT1
4XT1
3XT1

60Mbps
30Mbps
50Mbps
20Mbps
10Mbps

656
314
529
231
185

1XT1

3XT1

10Mbps

153

1XT1
2XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1

2XT1
4XT1
3XT1
2XT1
3XT1
6XT1
3XT1
3XT1

N/A
30Mbps
10Mbps
5Mbps
10Mbps
40Mbps
10Mbps
20Mbps

316
133
99
153
446
144
200

1XT1

2XT1

5Mbps

85

1XT1
1XT1
1XT1
1XT1
1XT1
1XT1
1XT1

3XT1
4XT1
3XT1
3XT1
4XT1
2XT1
3XT1

10Mbps
30Mbps
10Mbps
10Mbps
20Mbps
5Mbps
10Mbps

172
360
126
148
248
90
122

Residential Internet Broadband Comparisons:
ADSL (Phone Company): 1.5 Mbps – 20 Mbps
Cable Internet: 12 Mbps – 40 Mbps
Fiber Optic (Internet, or combined with television): 40 Mbps

65

APPENDIX F
Acronyms
Acronym
ADD
AS-IA
AYP
BIA
BIE
CCRS
DAS-M
DoDEA

Definition
Associate Deputy Director
Assistant Secretary-Indian Affairs
Adequate Yearly Progress
Bureau of Indian Affairs
Bureau of Indian Education
College and Career Ready Standards
Deputy Assistant Secretary for Management
Department of Defense Education Activity

DOI
DPA
ED
ELO
ESEA
FACE
FBMS
FI&R
FTE
GAO
GPRA
HR
IDEA
IEP
ISEP
IT
LEA
MI&R

Department of the Interior
Division of Performance and Accountability
Department of Education
Education Line Officer
Elementary and Secondary Education Act
Family and Child Education
Financial and Business Management System
Facilities Improvement and Repair
Full Time Employee
General Accounting Office
Government Performance and Results Act
Human Resources
Individuals with Disabilities Education Act
Individual Education Plan
Individual Student Equalization Program
Information Technology
Local Education Agency
Maintenance Improvement and Repair

Acronym
MOA
MOU
NAEP
NASIS
NCLB
NCAI
NIEA
OFECR

Definition
Memorandum of Agreement
Memorandum of Understanding
National Assessment for Educational Progress
Native American Student Information System
No Child Left Behind
National Congress of American Indians
National Indian Education Association
Office of Facilities and Environmental and Cultural
Resources
OFMC
Office of Facilities Management & Construction
OIG
Office of Inspector General
OMB
Office of Management and Budget
PARCC
Partnership for Assessment Readiness for College and Careers
PIAP
Program Improvement and Accountability Plan
SEA
State Education Agency
SIPI
Southwestern Indian Polytechnic Institute
SMARTER BALANCED
Smarter Balanced Assessment Consortium
STEM
Science, Technology, Engineering & Mathematics
TCSA
Tribally Controlled Schools Act
TCU
Tribal Colleges and Universities
TEA
Tribal Education Agency
USDA
United States Department of Agriculture