Implementation of the Title VI Indian Education 

Formula Grants Program 

Volume I: Final Report 

Prepared for: 

U.S. Department of Education 

Office of Planning, Evaluation and Policy Development 

Policy and Program Studies Service 

Prepared by: 

SRI International 

Katrina Woodworth 

Kirby Chow 

Wei-Bing Chen 

Policy Studies Associates 

Leslie M. Anderson 

Alisha Butler 

Brenda Turnbull 

Center for Indian Education, Arizona State University 

Bryan Brayboy 

University of Alaska Anchorage 

Diane Hirshberg 

2019 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

This report was produced under U.S. Department of Education Contract No. GS-10F-0554N/BPA Order ED-PEP-16-

A-0005/TO02 with SRI International. Jean Yan and Joanne Bogart served as the contracting officer’s 

representatives. The views expressed herein do not necessarily represent the positions or policies of the 

Department of Education. No official endorsement by the U.S. Department of Education of any product, 

commodity, service or enterprise mentioned in this publication is intended or should be inferred. For the reader’s 

convenience, this publication contains information about and from outside organizations, including hyperlinks and 

URLs. Inclusion of such information does not constitute an endorsement by the Department. 

U.S. Department of Education 

Betsy DeVos 

Secretary 

Office of Planning, Evaluation and Policy Development 

James Blew 

Assistant Secretary 

Policy and Program Studies Service 

Gregory Fortelny 

Director 

2019 

This report is in the public domain. Authorization to reproduce it in whole or in part is granted. While permission to 

reprint this publication is not necessary, the citation should be: U.S. Department of Education, Office of Planning, 

Evaluation and Policy Development, Policy and Program Studies Service, Implementation of the Title VI Indian 

Education Formula Grants Program, Volume I: Final Report. Washington, D.C., 2019. 

This report is available on the Department’s website at: 

http://www2.ed.gov/about/offices/list/opepd/ppss/reports.html. 

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20202. 

Content Contact: 

Jean Yan 

Phone: (202) 205-6212 

Email: Jean.Yan@ed.gov 
 

 

 

 

 

 

 

 

 

 

 

 

Acknowledgments 

We wish to thank the many individuals who contributed to the completion of this report. We are 

especially grateful to the Title VI grant coordinators for their cooperation in completing the survey for 

this study and to the nine grantees that graciously hosted the study team for site visits. Without their 

support, this study and report would not have been possible. 

We are also grateful for the guidance and support of the U.S. Department of Education. In particular, we 

thank Jean Yan, Joanne Bogart, and Stephanie Stullich of the Policy and Program Studies Service for their 

careful guidance and support throughout the study. From the Office of Indian Education, we thank 

Angeline Boulley, Bernard Garcia, Angela Hernandez-Marshall, Wanda Lee, Tara Ramsey, Joyce 

Silverthorne, Kimberly Smith, and Annabelle Toledo. From the White House Initiative on American 

Indian and Alaska Native, we thank Ron Lessard. From the Office of the General Counsel, we thank Jill 

Martin and Sharone Pasternak. From the Budget Service, we thank Margaret Levy. From the National 

Center for Education Statistics, Institute of Education Sciences, we thank James Deaton. 

We also acknowledge the thoughtful contributions of our technical working group members, David 

Beaulieu (University of Minnesota, Duluth), Yatibaey Evans (Fairbanks North Star Borough School 

District), Carrie Giovannone (independent consultant), Mary Hermes (University of Minnesota, Twin 

Cities), Kevin Shendo (Pueblo of Jemez), and Sydna Yellowfish (Edmond Public Schools). 

Finally, we wish to thank several members of the study team who helped collect and analyze data and 

prepare this report. In particular, we thank site visitors Sequoia Dance and Amanda Tachine from 

Arizona State University’s Center for Indian Education and Tandra Turner from Policy Studies Associates. 

We thank SRI research associates Hannah Cheever and Elise Levin-Guracar and the SRI editing and 

report production team, Mimi Campbell, Roxanne Jones, and Katie Roberts. Finally, we thank SRI’s Shari 

Golan and Deborah Jonas for their overall support and oversight. 

We appreciate the assistance and support of these individuals, and any errors in judgment or fact are 

the responsibility of the authors. 

Implementation of the Title VI Indian Education Formula Grants Program i 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Contents 

Executive Summary....................................................................................................................................... v 

Title VI Program Description ................................................................................................................. vi 

Study Design .......................................................................................................................................... vi 

Summary of Findings ............................................................................................................................ vii 

Chapter 1. Introduction ................................................................................................................................ 1 

Title VI Program Description .................................................................................................................. 1 

Study Design ........................................................................................................................................... 3 

Data Collection Activities and Analysis Methods ................................................................................... 5 

Study Limitations.................................................................................................................................... 6 

Technical Appendices ............................................................................................................................. 6 

Chapter 2. Providing Title VI-Funded Services to Eligible American Indian and Alaska Native Students.....7 

Title VI-Funded Services ......................................................................................................................... 7 

Supporting Culturally Responsive Education ....................................................................................... 13 

Coordinating with Other Programs ...................................................................................................... 19 

Chapter Summary................................................................................................................................. 23 

Chapter 3. Identifying Program-Eligible Children and Planning Services to Meet Their Needs ................. 24 

Identifying Program-Eligible Children .................................................................................................. 24 

Planning Services.................................................................................................................................. 33 

Chapter Summary................................................................................................................................. 41 

Chapter 4. Measuring Progress Toward Title VI Project Objectives .......................................................... 42 

Project Objectives................................................................................................................................. 42 

Measuring Progress.............................................................................................................................. 45 

Chapter Summary................................................................................................................................. 48 

References .................................................................................................................................................. 49 

Implementation of the Title VI Indian Education Formula Grants Program ii 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibits 

Exhibit 1. Distribution of Title VI grantees, by type, 2017–18 .................................................................. 2 

Exhibit 2. Distribution of Title VI grantees, by grant award size, 2017–18 ............................................... 3 

Exhibit 3. Case study sample, by grantee type, geographic region, and award size................................. 5 

Exhibit 4. Services and activities provided through Title VI grants, by service category, 2017–18 .......... 8 

Exhibit 5. Title VI grant-funded services and activities provided, by grantee type, 2017–18................... 9 

Exhibit 6. Title VI grant-funded services and activities provided, by grant award size, 2017–18........... 10 

Exhibit 7. Grantees reporting offering teachers/and or support staff professional development 

on Title VI-funded services and activities, 2017–18................................................................ 11 

Exhibit 8. Title VI-funded services and activities for which professional development was 

offered or planned, by grantee type, 2017–18 ....................................................................... 12 

Exhibit 9. Title VI-funded services and activities for which professional development was 

offered or planned, by grant award size, 2017–18 ................................................................. 13 

Exhibit 10. Title VI grantee practices to support culturally responsive education for 

American Indian and Alaska Native (AI/AN) students, 2017–18............................................. 14 

Exhibit 11. Title VI grantee practices to support culturally responsive education, 

by grantee type, 2017–18 ....................................................................................................... 16 

Exhibit 12. Title VI grantee practices to support culturally responsive education, 

by grant award size, 2017–18 ................................................................................................. 16 

Exhibit 13. Grantees reporting challenges to using culturally responsive practices to deliver 

Title VI-funded services, 2017–18 ........................................................................................... 17 

Exhibit 14. Factors challenging grantees’ efforts to deliver Title VI-funded services using 

culturally responsive practices, 2017–18 ................................................................................ 18 

Exhibit 15. Federal, state, and local programs with which Title VI grantees coordinated 

grant-funded services and activities, 2017–18 ....................................................................... 20 

Exhibit 16. Programs with which grantees coordinated Title VI-funded services and activities, 

by grant award size, 2017–18 ................................................................................................. 21 

Exhibit 17. Programs with which grantees coordinated Title VI-funded services and activities, 

by grantee type, 2017–18 ....................................................................................................... 21 

Exhibit 18. Grantees reporting challenges to coordinating Title VI-funded services with 

other programs, 2017–18........................................................................................................ 23 

Exhibit 19. Strategies grantees used to identify students eligible to receive Title VI-funded 

services, 2017–18 .................................................................................................................... 26 

Exhibit 20. Strategies grantees used to identify students eligible to receive Title VI-funded 

services, by grant award size, 2017–18................................................................................... 27 

Exhibit 21. Title VI grantees reporting challenges with strategies to identify eligible children, 

2017–18................................................................................................................................... 28 

Exhibit 22. Strategies grantees used to promote accuracy and completeness of the data 

collected on the ED 506 forms, 2017–18 ................................................................................ 30 

Exhibit 23. Title VI grantee strategies to promote accuracy and completeness of the data 

collected through the ED 506 forms, by grant award size, 2017–18 ...................................... 31 

Implementation of the Title VI Indian Education Formula Grants Program iii 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 24. Title VI grantees reporting challenges using strategies to promote accuracy and 

completeness of the data collected through the ED 506 forms, 2017–18 ............................. 32 

Exhibit 25. Stakeholder groups from which Title VI grantees collected information, 2017–18 ............... 34 

Exhibit 26. Strategies Title VI grantees used to collect information from stakeholder groups, 

2017–18................................................................................................................................... 35 

Exhibit 27. Strategies Title VI grantees used to collect information from stakeholder groups, 

by grant award size, 2017–18 ................................................................................................. 35 

Exhibit 28. Strategies Title VI grantees used to collect information from stakeholder groups, 

by grantee type, 2017–18 ....................................................................................................... 36 

Exhibit 29. Groups represented on Title VI Parent Advisory Committees, 2017–18................................37 

Exhibit 30. Title VI Parent Advisory Committee support for planning, 2017–18 ...................................... 38 

Exhibit 31. Data sources Title VI grantees used to plan services, 2017–18 .............................................. 39 

Exhibit 32. Data sources Title VI grantees used to plan services, by grant award size, 2017–18.............40 

Exhibit 33. Grantees reporting challenges to efforts to plan Title VI-funded services and activities, 

2017–18................................................................................................................................... 41 

Exhibit 34. Objectives of Title VI-funded projects, 2017–18..................................................................... 43 

Exhibit 35. Objectives of Title VI-funded projects for American Indian and Alaska Native students, 

by grantee type, 2017–18 ....................................................................................................... 44 

Exhibit 36. Objectives of Title VI-funded projects, by grant award size, 2017–18 ................................... 44 

Exhibit 37. Data sources grantees used to measure progress toward Title VI project objectives, 

2017–18................................................................................................................................... 45 

Exhibit 38. Data sources used to measure progress toward Title VI project objectives, 

by grantee type, 2017–18 ....................................................................................................... 46 

Exhibit 39. Data sources used to measure progress toward Title VI project objectives, 

by grant award size, 2017–18 ................................................................................................. 46 

Exhibit 40. Title VI grantees reporting challenges to implementing data collection or data 

use strategies in 2017–18........................................................................................................ 48 

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Executive Summary 

The Title VI Indian Education Formula Grants program1 represents the U.S. Department of Education’s 

largest investment in addressing the unique academic and cultural needs of American Indian and Alaska 

Native children. The program is aimed at supporting services that (1) are responsive to the unique 

cultural, language, and educational needs of American Indian and Alaska Native students and (2) help 

these students meet academic standards. School districts, tribes, Indian organizations, Indian 

community-based organizations, and Bureau of Indian Education schools receiving this grant are 

required to consult with parents and local tribes in the effort to shape grant-funded services that 

supplement and enrich regular school programs. 

This study examined the nationwide operations of the Title VI grants program to inform the field about 

the strategies grantees used in their implementation of the grant projects. Specifically, the study 

addressed the following questions: 

1. What services do Title VI grants support? 

2. How do grantees work with stakeholders to identify program-eligible children and plan services 

to meet the needs of those children? 

3. How do grantees measure progress toward their project objectives? 

Key findings from the study included the following: 

• According to grant coordinators, the most common Title VI-funded services were academic 

support, cultural enrichment, and parent involvement. 

• Most grantees supported culturally responsive education by incorporating American Indian and 

Alaska Native history and culture into the curriculum and employing American Indian and 

Alaska Native teachers and support staff. 

• Most grantees reported relying on three strategies to identify eligible students: (1) including 

questions about students’ American Indian and Alaska Native status in the school registration 

process, (2) including Title VI student eligibility certification forms in enrollment packets, and (3) 

generating reports on students who identified as American Indian and Alaska Native on school 

enrollment forms. 

• Most grantees collected information about students’ needs from a Title VI Parent Advisory 

Committee and other stakeholder groups, commonly through public hearings, convenings with 

the stakeholder groups, and surveys. 

• Title VI grantees reported using multiple data sources for project planning, including 

administrative data and information from parents, teachers, administrators, and from public 

hearings. 

1 The Indian Education Formula Grants to Local Educational Agencies program is authorized under Title VI, Part A, of the 

Elementary and Secondary Education Act of 1965 (ESEA) as reauthorized under the Every Student Succeeds Act of 2015 (ESSA), 

Pub. L. No. 114-95 (2015). 

Implementation of the Title VI Indian Education Formula Grants Program v 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

• Most grantees used state standardized assessment scores, attendance data, and 

graduation/dropout data to measure progress toward Title VI project objectives. 

Title VI Program Description 

The authorizing legislation calls for culturally responsive teaching and learning services that supplement 

and enrich the regular school program. The program requires that grantees identify goals or “objectives” 

for their local project that are (1) based on a needs assessment and (2) developed in open consultation 

with parents, teachers, representatives of Indian tribes,2 and secondary students (if appropriate). Local 

project objectives could include, for example, increasing American Indian and Alaska Native students’ 

academic achievement, knowledge of cultural identity and awareness, and school attendance. Grantee 

services should support these objectives and may include, for example, culturally responsive academic 

support, mentoring, and educator professional development; native language instruction; and parent 

involvement. Grantees are expected to assess progress toward their project objectives. 

Under the Title VI program, school districts,3 tribes, Indian organizations, Indian community-based 

organizations, and Bureau of Indian Education (BIE) schools submit an application and receive funds 

based on the number of eligible students. For the 2017–18 school year, the Title VI program provided 

grants to 1,304 grantees, mostly school districts (88 percent). School districts include both singleapplicant local education agencies (LEAs) (i.e., traditional school districts or charter schools) and LEA 

consortia (i.e., two or more school districts that coordinated their grant activities). Schools funded or 

operated by the BIE accounted for 10 percent of grantees; 6 percent were BIE funded but operated by a 

tribe, and 4 percent were operated by the BIE. The remaining 2 percent of grantees included tribes 

applying in lieu of one or more LEAs and two Indian community-based organizations. 

In 2017–18, more than half the Title VI grant awards were under $40,000, with a median size of $36,608. 

The average amount per pupil was $216. Grant award sizes ranged from the minimum award of $4,000 

to a high of $3.3 million. 

Study Design 

The study had four components: an extant data analysis, a review of the literature, a survey of all 2017– 

18 Title VI grantees, and case studies of nine Title VI grantees. The analysis of extant data was designed 

to characterize the universe of grantees, inform case study site selection, and guide survey and 

interview protocol development. To further inform survey and interview protocol development, the 

literature review focused on efforts to provide culturally responsive education, identify eligible 

American Indian and Alaska Native students, and involve parents, tribes, and communities in planning 

services. The survey of grant coordinators associated with all 1,304 Title VI grantees was designed to 

provide information on the full population of 2017–18 grantees; 92 percent of grantees completed the 

survey. The grantee survey covered the following topics: Title VI-funded services, coordination of Title 

VI-funded services with other programs and service providers, methods for identifying and counting 

eligible students, planning services for eligible students, and measuring progress toward project 

objectives. Case studies of nine Title VI grantees allowed for an in-depth exploration of program 

2 A requirement that school districts meaningfully collaborate with local Indian tribes, and that all grantees engage in open 

consultation with local tribes and tribal organizations, was added in the 2015 reauthorization of the Elementary and Secondary 

Education Act, Every Student Succeeds Act (ESSA) (see ESEA § 6114(b)(7) and (c)(3)(C)). 3 In this report, the terms “local education agencies” (LEAs) and “school districts” are used interchangeably. 

Implementation of the Title VI Indian Education Formula Grants Program vi 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

planning and implementation in a subset of sites. The case study sites were selected to include variation 

across three dimensions: grant award size, grantee type, and geographic region. The interview protocols 

were designed to generate concrete, detailed examples to illustrate and provide context for the survey 

findings, so the topics covered in the protocols paralleled those in the survey. 

Summary of Findings 

Title VI-Funded Services 

As reported by coordinators, grantees used Title VI grants to supplement funding for an array of 

academic support and cultural enrichment activities and services intended to bolster American Indian 

and Alaska Native children’s educational outcomes. 

The most common Title VI-funded services were academic support such as homework 

and study skills assistance (87 percent), cultural enrichment such as field trips and 

special events (74 percent), and parent involvement (62 percent). 

Less common services supported through Title VI funds included college and career preparation, 

including college preparation (45 percent) and career preparation (37 percent); school readiness, 

including family literacy (26 percent) and early childhood programs (26 percent), and various prevention 

programs, including dropout prevention (42 percent) and substance abuse prevention (24 percent). 

More than two thirds of grantees supported culturally responsive education by 

incorporating American Indian and Alaska Native history and culture into the 

curriculum (70 percent) and using American Indian and Alaska Native teachers and 

support staff (68 percent). 

Less frequently, Title VI grantees connected students with mentors or counselors from the tribal 

community (48 percent) and delivered instruction in American Indian or Alaska Native languages (32 

percent). 

The greatest challenge in Title VI grantees’ delivery of services using culturally 

responsive practices was the availability of school staff with relevant knowledge of 

and expertise in native languages, culturally responsive education, and students’ 

cultural background. 

Despite the requirement to deliver Title VI-funded services using culturally responsive practices, about 

three-fifths of grantees (58 percent) reported that it was somewhat challenging or very challenging to 

do so. Of these, most reported challenges with the availability of school staff knowledgeable about 

American Indian or Alaska Native languages (87 percent) or with expertise in culturally responsive 

education (80 percent). Other factors were the availability of school staff knowledgeable about 

students’ cultural backgrounds (72 percent) or the availability of staff within their organization (e.g., 

school district, BIE, or tribe) with expertise in culturally responsive education (72 percent). 

The vast majority of grantees (89 percent) reported coordinating Title VI-funded 

services with at least one other program. The most common programs were Title I, 

Part A programs (67 percent), Individuals with Educational Disabilities Act programs 

(57 percent), and the BIE-funded Johnson-O’Malley programs (45 percent). 

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Other programs with which Title VI-funded services were coordinated included the Education for 

Homeless Children and Youth program (authorized under the McKinney-Vento Homeless Assistance Act) 

(43 percent), programs delivered by local service providers (35 percent), and Impact Aid (34 percent). 

The strategies that grantees most commonly adopted to facilitate coordination with 

other programs included sharing data on students (76 percent) and sharing 

information on programs and services they believed to be effective (70 percent). 

Additional but less commonly reported coordination strategies included sharing costs associated with 

providing services (61 percent) and building programmatic linkages among programs, agencies, and 

organizations (53 percent). 

Identifying Program-Eligible Children and Planning Services to Meet Their Needs 

Title VI funding is calculated with a formula based on the number of students who have submitted an 

Office of Indian Education Title VI ED 506 Indian Student Eligibility Certification Form (ED 506 form) 

documenting their American Indian or Alaska Native status. 

Most grantees reported relying on three strategies to identify eligible students: (1) 

including questions about students’ American Indian and Alaska Native status in the 

school registration process (76 percent), (2) including ED 506 forms in enrollment 

packets (75 percent), and (3) generating reports for students who were identified as 

American Indian and Alaska Native on enrollment forms (66 percent). 

Grantees less frequently conducted awareness-raising activities (e.g., trainings, presentations, meetings) 

(39 percent), coordinated with organizations that work with American Indian and Alaska Native families 

to notify them about available Title VI-funded services (35 percent), or included common tribal 

affiliations on the ED 506 form (24 percent). 

To confirm the accuracy and completeness of information collected on ED 506 forms, 

most grantees collected physical copies of the forms and conducted annual reviews of 

the forms to update information on eligible students. 

Nearly all grantees (95 percent) collected physical copies of ED 506 forms from families to confirm that 

the information provided was accurate and complete. Most grantees conducted an annual review of the 

ED 506 forms to update information on eligible students by removing students who had left the district 

and removing any duplicate student entries (85 percent), and the majority reported linking data 

collected through ED 506 forms to district student enrollment systems (66 percent). Fewer grantees 

reported linking data collected through the ED 506 form to state student enrollment systems (27 

percent) or collecting electronic ED 506 forms from newly registered American Indian and Alaska Native 

families (17 percent). 

More than two in five grantees reported that helping parents and guardians collect 

and submit acceptable information to confirm their child’s eligibility was somewhat or 

very challenging. 

Grantees had mixed experiences in their efforts to identify eligible children. While fewer than half 

(45 percent) reported that helping parents and guardians collect and submit acceptable information 

(e.g., tribal membership or enrollment number, letter from tribe) to confirm their child’s eligibility to 

Implementation of the Title VI Indian Education Formula Grants Program viii 
 

 

 

 

 

 

 

 

 

 

receive Title VI-funded services was somewhat or very challenging, more than half (55 percent) found 

that helping parents collect and submit information was minimally challenging or not challenging. 

Most grantees collected information about students’ needs from a Title VI Parent 

Advisory Committee and other stakeholder groups, commonly through public 

hearings, convenings with stakeholder groups, and surveys. 

In conducting the needs assessment, grantees most commonly collected information from Title VI 

Parent Advisory Committees, educators (i.e., schools administrators, teachers), students, school boards 

and/or district administrators, and school- or tribe-based parent committees. They used a variety of 

strategies to collect information from key stakeholders. They tended to rely on face-to-face 

communication such as public hearings (70 percent) and convenings (64 percent), although many also 

used surveys (62 percent). 

Most grantees reported using multiple data sources for project planning, including 

administrative data and information from parents, teachers, and administrators and 

from public hearings. 

In planning grant-funded services, most grantees used the information gathered through their needs 

assessments, including administrative data such as course grades, test scores, and attendance data 

(94 percent) and ideas and recommendations from parents (86 percent), from teachers and 

administrators (82 percent), and from public hearings (73 percent). 

Measuring Progress Toward Title VI Project Objectives 

All grantees are required to identify the data sources they will use to measure progress toward meeting 

their projects’ objectives, which could include, for example, increasing American Indian and Alaska 

Native students' academic achievement, knowledge of cultural identity and awareness, and school 

attendance. 

Most grantees used state standardized assessment scores (83 percent), attendance 

data (80 percent), and graduation/dropout data (66 percent) to measure progress 

toward Title VI project objectives. 

Less commonly used data sources for measuring progress toward Title VI project objectives included 

survey or focus group data collected from parents, guardians, or families (46 percent), from students 

themselves (43 percent), or from school staff (39 percent). School districts were more likely than BIE 

schools and tribes to use standardized assessment scores, graduation rates, and college acceptance data 

to measure progress; BIE schools and tribes were more likely than school districts to rely on culturally 

relevant measures. 

Implementation of the Title VI Indian Education Formula Grants Program ix 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 1. Introduction 

The Title VI Indian Education Formula Grants1 program is the U.S. Department of Education’s largest 

investment in addressing the unique academic and cultural needs of American Indian and Alaska Native 

children. Grantees are charged with planning and delivering services that (1) are responsive to the 

unique cultural, language, and educational needs of American Indian and Alaska Native students and 

(2) help these students meet academic standards. There is some evidence suggesting that culturally 

responsive schooling may help Indigenous students meet challenging academic standards (Castagno and 

Brayboy 2008; Lomawaima and McCarty 2006). The importance of the charge to Title VI grantees is 

magnified by the challenges that Indigenous communities in the United States may face (e.g., poverty, 

unemployment) (DeVoe and Darling-Churchill 2008). 

Title VI Program Description 

The authorizing legislation calls for grantees to provide culturally responsive teaching and learning 

services that supplement and enrich the regular school program. The program requires that grantees 

identify project objectives and services that are (1) based on a needs assessment and (2) developed in 

consultation with community stakeholders, including parents, teachers, students (if appropriate), and 

local tribes and tribal organizations. Local project objectives could include, for example, increasing 

American Indian and Alaska Native students’ academic achievement, knowledge of cultural identity and 

awareness, and school attendance. Grantee services should support these objectives and may include, 

for example, culturally responsive academic support, mentoring, and educator professional 

development; native language instruction; and parent involvement. Grantees are expected to assess 

progress toward project objectives. 

Prospective grantees submit a two-part application. In the first part, they select their “applicant type” as 

grantees may be school districts,2 tribes, Indian organizations, Indian community-based organizations, 

and Bureau of Indian Education (BIE) schools and submit their “Indian student count.”3 The second part 

of the application enables grantees to identify objectives, services, and data sources for measuring 

progress towards objectives, as described above.4 

Most Title VI grants were allocated to school districts. In 2017–18, 88 percent of the 1,304 grantees 

were school districts, both single-applicant LEAs (i.e., traditional school districts or charter schools) and 

LEA consortia (i.e., two or more school districts that coordinate their grant activities). Schools that 

received BIE funding constituted 10 percent of the grantees; these included BIE-operated elementary 

and secondary schools as well as BIE grant or contract schools (i.e., BIE-funded but operated by a tribe). 

The remaining 2 percent of grantees were 23 tribes applying in lieu of one or more LEAs and two Indian 

1 The Indian Education Formula Grants to Local Educational Agencies program is authorized under Title VI, Part A, of the 

Elementary and Secondary Education Act of 1965 (ESEA) as reauthorized under the Every Student Succeeds Act of 2015 (ESSA), 

Pub. L. No. 114-95 (2015). 2 In this report, the terms “local education agencies” (LEAs) and “school districts” are used interchangeably. 

3 The “Indian student count” is based on the number of eligible students served by the grantee. Most grantees must maintain 

completed Office of Indian Education Title VI ED 506 Indian Student Eligibility Certification Forms (ED 506 forms) for each 

student. BIE schools may use an alternate form. The process for identifying eligible students is described in detail in Chapter 3. 4 Additional information about the two-part application process and program requirements is available through the 

Department’s Frequently Asked Questions page. 

Implementation of the Title VI Indian Education Formula Grants Program 1 
 

 

 

 

 

 

 

 

 

 

community-based organizations (Exhibit 1). Tribes and Indian organizations may apply in lieu of an 

otherwise eligible LEA if the LEA does not establish the required Parent Advisory Committee and the 

tribe or Indian organization represents at least half the eligible children served by the LEA. Indian 

community-based organizations may apply under the same circumstances, if neither a tribe nor an 

Indian organization applies. 

Exhibit 1. Distribution of Title VI grantees, by type, 2017–18 

School districts 

(N = 1,152) 

88% 

BIE schools 

(N = 127) 

10% 

Tribes and Indian 

community-based 

organizations 

(N = 25) 

2% 

Exhibit reads: In 2017–18, 88 percent of grantees were school districts (including both single-applicant school 

districts and consortia of school districts), 10 percent were BIE schools (including schools run under a contract with 

the BIE and schools operated by the BIE), and 2 percent were tribes and Indian community-based organizations. 

Source: Data provided to this study by the Office of Indian Education, U.S. Department of Education (n = 1,304; see Exhibit A-1 in the Technical 

Appendix). 

In 2017–18, more than half the Title VI grant awards were under $40,000, with a median size of $36,608. 

The average amount per pupil was $216. Title VI grant awards ranged from a statutory minimum of 

$4,000 to a maximum of $3,254,999. Of the 1,304 grants awarded in 2017–18, 54 percent were under 

$40,000, 29 percent were under $20,000, and 4 percent were $5,000 or less (Exhibit 2). At the high end 

of the spectrum, 19 percent of grantees received $100,000 or more, and the seven largest grant awards 

were over $1 million. Except for one BIE-operated school that received just over $4,000, the largest and 

the smallest grants were awarded to districts. 

Implementation of the Title VI Indian Education Formula Grants Program 2 
 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 2. Distribution of Title VI grantees, by grant award size, 2017–18 

≤$5K

$5,001–$20,000 

$20,001–$40,000 

$40,001–$60,000 

$60,001–$100,000 

$100,001–$200,000 

$200,001–$400,000 5% 

12% 

14% 

13% 

25% 

25% 

4% 

>$400K 2% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Exhibit reads: In 2017–18, 4 percent of Title VI grantees were awarded $5,000 or less. 

Source: Data provided to this study by the Office of Indian Education, U.S. Department of Education (n = 1,304; see Exhibit A-2 in the Technical 

Appendix). 

Study Design 

The purpose of this study was to learn about nationwide operations of the Title VI Indian Education 

Formula Grants program to inform the U.S. Department of Education’s Office of Indian Education (OIE) 

and its grantees about the strategies grantees used to implement the grant. Specifically, the study 

addressed the following questions: 

1. What services do Title VI grants fund? 

2. How do grantees work with stakeholders to identify program-eligible children and plan 

services to meet the needs of those children? 

3. How do grantees measure progress toward their project objectives? 

The study had four components: an extant data analysis, a review of the literature, a survey of all 2017– 

18 Title VI grantees, and case studies of nine Title VI grantees. This section describes the role of each 

study component and, where relevant, the sample. 

Extant Data Analysis 

The analysis of extant data was designed to characterize the universe of grantees, inform case study site 

selection, and guide survey and interview protocol development. We analyzed 2017–18 data from 

grantee applications drawn from the U.S. Department of Education’s Electronic Application System for 

Indian Education (EASIE), the Indian Education Formula Grant EASIE Budget Report, and Annual 

Performance Reports. The applications contained information on grantee type and project objectives, 

Implementation of the Title VI Indian Education Formula Grants Program 3 
 

 

 

 

 

 

 

 

 

 

 

 

the EASIE Budget Report contained information on grant award size, and the Annual Performance 

Reports provided information on the types of grant-funded services and the data sources used to 

measure project outcomes. 

Literature Review 

To situate the study in the context of existing programs, services, partnerships, and initiatives that 

promote education for American Indian and Alaska Native students, we reviewed the research literature 

with a focus on efforts to provide culturally responsive education, identify eligible American Indian and 

Alaska Native students, and involve parents, tribes, and communities in planning and developing 

programming. The information gained from the review was used in the development of data collection 

instruments, including the grantee survey and interview protocols. 

Grantee Survey 

The study-administered survey of grant coordinators associated with all 1,304 Title VI grantees was 

designed to provide information on the full population of 2017–18 grantees. Surveying the entire 

population rather than a sample was feasible because of the relatively small grantee population size. 

Moreover, surveying the entire population was more cost-efficient than designing a sampling frame that 

would be representative of key grantee characteristics (e.g., grantee type and award size), and it yielded 

the smallest margin of measurement error. 

Designed to align with the study questions, the grantee survey covered the following topics: Title VIfunded services, coordination of Title VI-funded services with other programs and service providers, 

methods for identifying and counting eligible students, planning services for eligible students, and 

assessing the outcomes and impact of Title VI-funded services on participating American Indian and 

Alaska Native students. The survey was tailored slightly to reflect the differences between the three 

main types of grantees—school districts, BIE-funded schools, and tribes. 

Case Studies 

Case studies of nine grantees were conducted to provide a more in-depth exploration of program 

planning and implementation in a subset of sites. The case study sites were selected to include variation 

across three dimensions: grant award size (as defined by quartiles), grantee type, and geographic region 

(Exhibit 3). Additionally, case study sites varied in the number and concentration of program-eligible 

students, grade levels targeted (i.e., pre-K, elementary, middle, and high), and project objectives and 

services. 

Implementation of the Title VI Indian Education Formula Grants Program 4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 3. Case study sample, by grantee type, geographic region, and award size 

LEA 

(single) 

LEA 

(consortium) 

BIE grant or 

contract school 

BIE-operated 

school 

Tribe in lieu 

of LEA(s) Total 

Pacific 1 large award 1 large award 3 

1 medium award 

Mountain 1 medium award 1 large award 2 

North 1 medium award 1 

Central 

South 1 large award 2 

Central 1 very small award 

Atlantic 1 small award 1 

Total 5 1 1 1 1 9 

Exhibit reads: In the Pacific region, the case study sample comprised three LEA grantees, including two single LEA 

grantees (one with a large award and one with a medium-size award) and one LEA consortium with a large award. 

The interview protocols were designed to elicit concrete, detailed examples to illustrate and provide 

context for the survey findings; the topics covered in the protocols paralleled those in the survey. The 

quantitative survey data and qualitative case study data were integrated to provide a fuller picture of 

the context in which grantees operated; how they supported ED 506 form completion and engaged with 

key stakeholders; how they developed, implemented, and refined programs (including supports and 

challenges); and how they measured progress toward project objectives. 

Data Collection Activities and Analysis Methods 

Grantee Survey Administration and Analysis 

Data collection started in early March and ended in early May 2018. The survey was administered to 

Title VI grant coordinators through an online platform. To promote high participation, the U.S. 

Department of Education sent letters notifying the grant coordinators about the study before the survey 

launch. The grant coordinators then received emails with unique links to the survey. Follow-up with 

nonrespondents occurred first by email and then by telephone. The final survey response rate was 92 

percent. 

Stata software was used to generate descriptive statistics (frequencies, means, counts, and standard 

deviations), including disaggregation of the data by grantee type and grant award size. In comparing 

grantees by type of organization, we combined tribes, Indian community-based organizations, and BIE 

schools because they were small in number5 and compared them as a group with district grantees. In 

comparing grantees by award size, we compared grantees above and below the median. References in 

the text to differences between groups of grantees only discuss differences that are statistically 

significant using a significance level of p < .05.6 

5 Because there were just two Indian community-based organizations, this group is referred to as “BIE schools and tribal 

grantees.” 6 When the p level is less than .05, there is less than a 5 percent chance that the observed difference between the two groups 

was simply due to chance. 

Implementation of the Title VI Indian Education Formula Grants Program 5 
 

 

 

 

 

 

 

 

Case Study Site Visits and Analysis 

Prior to the site visits, site visitors gathered and reviewed background information on their sites, 

including grant applications, Annual Performance Reports, the EASIE Budget Report, the grantee’s 

survey responses, and publicly available information about the community and the tribe or tribes it 

serves. In addition, site visitors received training on the data collection protocols and procedures. At this 

training, study team members based at the Center for Indian Education at Arizona State University led a 

workshop on culturally responsive practices when working with American Indian and Alaska Native 

respondents and gathering information in Indigenous communities. This workshop conveyed 

information about how to think of research as a relational rather than a transactional process, including 

the importance of responsibility, respect, and reciprocity when working with Indigenous communities. 

Seven site visits were conducted in April and May 2018 and two in August 2018, for a total of nine. For 

each site, a pair of researchers spent approximately two days on site, conducting interviews with the 

Title VI grant coordinators and other grantee staff members including program administrators, leaders, 

instructional personnel, and counselors; an education leader such as a superintendent, board member, 

or tribal education leader; and tribal leaders. Focus groups were held with parents. All site visit 

interviews were audio recorded and the recordings transcribed. 

After completing a visit, the two site visitors collaborated to complete a prestructured debrief guide, 

which closely aligned with the study questions. The site visitors coded the interview transcripts for their 

site according to the debrief guide topics and then summarized findings across multiple interviews and 

parent focus group(s). Interview data were labeled by respondent type to support drawing on the 

perspectives of diverse respondent types as well as to track the consistency and discrepancies of 

interviewee responses. Site visitors also participated in large-group briefings to share lessons learned 

from their data collection experiences and to discuss findings across all sites. 

Study Limitations 

The nine case study sites are not nationally representative; data collected through site visits were 

intended to be illustrative and did not represent the full range of views of grantee personnel, parents, or 

tribal leaders at the case study sites or at the 1,295 sites not visited. Interviewees’ statements about 

program processes, challenges, and successes represented the perspectives of the individuals making 

them. 

Technical Appendices 

This report is accompanied by a separate volume containing the following technical appendices: 

• Appendix A: Supplemental Exhibits 

• Appendix B: Data Collection Instruments 

• Appendix C: Title VI Student Eligibility Certification Form 

Implementation of the Title VI Indian Education Formula Grants Program 6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2. Providing Title VI-Funded Services to 

Eligible American Indian and Alaska Native Students 

The Title VI Indian Education Formula Grants program seeks to improve the education opportunities and 

outcomes of American Indian and Alaska Native children by supporting services responsive to their 

unique cultural, language, and educational needs and by helping them meet state academic standards. 

While definitions vary, culturally responsive education aims to build a bridge between children’s 

identities and cultures and their schools (Castagno and Brayboy 2008). Title VI grants are to be used to 

supplement and enrich the regular school program and must not supplant existing funding sources. 

Specific activities may include native language programs and culturally related activities; early childhood 

and family programs that emphasize school readiness; academic and enrichment programs that directly 

support the attainment of state standards; college and career preparation activities; dropout prevention 

strategies and programs preventing violence, suicide, and substance abuse; and strategies to meet the 

educational needs of students in correctional facilities. Additionally, the statute requires all grantees to 

offer professional development “as needed,” to ensure that new teachers and other professionals are 

prepared to work with Indian children, and that all teachers involved have been properly trained to 

carry out the project (ESEA § 6114(b)(5)). 

This chapter describes the types of academic, cultural, readiness, preparation, and prevention services 

Title VI grantees provided American Indian and Alaska Native students and their families in 2017–18. It 

also describes practices that grantees reported using to support a culturally responsive education and 

the challenges they faced. Finally, this chapter describes the types of federal, state, and local programs 

with which grantees coordinated Title VI-funded services and activities. 

Title VI-Funded Services 

As reported by coordinators, grantees used Title VI grants to supplement funding for an array of 

academic support and cultural enrichment activities and services to bolster American Indian and Alaska 

Native children’s educational outcomes. 

The most common Title VI-funded services were academic support such as homework 

and study skills assistance (87 percent), cultural enrichment such as field trips and 

special events (74 percent), and parent involvement (62 percent). 

Less common services supported through Title VI grant funds included college and career preparation, 

including college preparation (45%) and career preparation (37%); school readiness, including family 

literacy (26%) and early childhood programs (25%); and various prevention programs, including dropout 

prevention (42%) and substance abuse prevention (24%) (Exhibit 4). 

Implementation of the Title VI Indian Education Formula Grants Program 7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 4. Services and activities provided through Title VI grants, by service category, 2017–18 

 

 l 

l 

] 

] 

Academic support 87% Academic support 

Academic enrichment 57% and enrichment 

Gifted and talented program 17% 

Cultural enrichment 74% Language and 

Indian education 56% culture 

Native language instruction 35% 

Parent involvement 

Parent involvement 62% 

College preparation 45% 

Mentoring 41% 

College and career Student advocacy/leadership 40% 

Career preparation 37% 

Counseling 35% 

Dropout prevention strategies 42% 

Substance abuse prevention 24% Prevention 

Suicide prevention 23% 

Violence prevention 21% 

Family literacy 26% School readiness 

Early childhood programs 26% 

Correctional 

Programs for students in correctional facilities 4% facilities programs 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Exhibit reads: In 2017–18, 87 percent of grantees used Title VI funds to provide academic support. 

Source: Survey of Title VI Grant Coordinators, Item 14 (n = 1,152; see Exhibit A-3 in the Technical Appendix). 

Case study interviewees provided examples of the services and activities Title VI grants supported. A 

Title VI grant coordinator at one site described using grant funds to provide students with a range of 

services they would not otherwise receive. 

Our kids get to participate in so much more than the school can provide for them. There 

would be no more college campus tours. Our K–5 and middle school groups plan field 

trips where they go to museums and aquariums and things like that. The career and 

college readiness stuff would go away.... The resources that are purchased for cultural 

instruction would go away, because there would be nobody here to help when you have 

the majority of teachers [who are] nonnative. 

At another site, the grant coordinator described targeting the Title VI resources at the high school by 

funding the coordinator’s salary, a portion of a para-educator’s time, and school supplies for students. 

“It’s a small program,” he explained, “a small grant spread out.... We pull in that population of native 

students and then try to apply services where we can. It’s a challenge.” 

BIE-funded schools and tribes were more likely than school districts to use Title VI funds to support 

American Indian and Alaska Native students’ language and culture, including native language instruction 

Implementation of the Title VI Indian Education Formula Grants Program 8 
 

 

 

 

 

 

 

 

 

 

 

and Indian education (e.g., language and history). School districts, however, were more likely than BIE 

and tribal grantees to fund services related to academic support and enrichment (e.g., college 

preparation and academic support) and dropout prevention (Exhibit 5). 

Exhibit 5. Title VI grant-funded services and activities provided, by grantee type, 2017–18 

School 

districts 

BIE schools 

and tribes 

Percentage 

point difference 

More commonly used by BIE schools and tribal grantees 

Native language instruction 31% 75% 44 

Indian education 53 84 31 

More commonly used by district grantees 

College preparation 47 23 24 

Academic support 89 67 22 

Career preparation 39 24 15 

Dropout prevention strategies 43 28 15 

Exhibit reads: In 2017–18, 47 percent of district grantees and 23 percent of BIE and tribal grantees used grant 

funds to provide college preparation services, a 24 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. 

Source: Survey of Title VI Grant Coordinators, Item 14 (school districts n = 1,032; BIE schools and tribes n = 120; see Exhibit A-4 in the Technical 

Appendix). 

On average, Title VI grantees reported providing eligible students with approximately 7.5 types of 

services and activities. The menu of service types varied, but most grantees (65 percent) provided both 

academic support (e.g., help with homework and developing study skills) and cultural enrichment (such 

as field trips and special events). However, grantees with larger awards (above the median) provided 

more services and activities (an average of 8.3 services and activities) than grantees with smaller awards 

(an average of 6.7 services and activities) (see Exhibit A-5 in the Technical Appendix). Accordingly, 

grantees with larger awards were more likely than grantees with smaller awards to provide many 

specific services (Exhibit 6). 

Implementation of the Title VI Indian Education Formula Grants Program 9 
 

 

 

 

 

 

 

 

 

Exhibit 6. Title VI grant-funded services and activities provided, by grant award size, 2017–18 

Larger awards 

(above median) 

Smaller awards 

(below median) 

Percentage 

point difference 

Indian education (e.g., language and history) 65% 47% 18 

Dropout prevention 50 33 17 

Native language instruction 43 28 15 

Career preparation 44 30 14 

College preparation 51 38 13 

Student advocacy/leadership 46 33 13 

Cultural enrichment 80 68 12 

Parent involvement 68 57 11 

Family literacy 31 20 11 

Academic enrichment 61 52 9 

Mentoring 45 37 8 

Suicide prevention 26 19 7 

Exhibit reads: In 2017–18, 65 percent of grantees with larger awards and 47 percent of grantees with smaller 

awards used grant funds for Indian education, an 18 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. 

Source: Survey of Title VI Grant Coordinators, Item 14 (grantees with larger awards n = 594; grantees with smaller awards n = 558; see Exhibit 

A-7 in the Technical Appendix). 

More than half the grantees offered professional development to teachers and 

support staff to support academics (62 percent) and cultural enrichment (57 percent). 

Slightly less than half the grantees offered professional development in support of academic enrichment 

(45 percent), Indian education (44 percent), and parent involvement (44 percent) (Exhibit 7). 

Approximately one in five grant coordinators reported planning to offer professional development on 

these topics. 

Implementation of the Title VI Indian Education Formula Grants Program 10 
 

 

 

 

 

 

 

 

 

 

Exhibit 7. Grantees reporting offering teachers and support staff professional development on 

Title VI-funded services and activities, 2017–18 

 

■ 

~-- l 

■ 

l 

] 

] 

] 

-------.----------.---------, ] 

Academic support 

Academic enrichment 

Gifted and talented program 

Cultural enrichment 

Indian education 

Native language instruction 

Parent involvement 

Student advocacy/leadership 

Counseling 

Career preparation 

Mentoring 

College preparation 

Dropout prevention strategies 

Suicide prevention 

Substance abuse prevention 

Violence prevention 

Early childhood programs 

Family literacy 

Programs for students in correctional facilities facilities 

programs 0% 20% 40% 60% 80% 100% 

Percent of grantees 

Offer professional development in this area Plan to offer professional development in this area 

22% 

23% 

22% 

24% 

26% 

29% 

28% 

28% 

29% 

29% 

31% 

44% 

21% 

44% 

57% 

14% 

45% 

62% 

25% 

22% 

26% 

25% 

26% 

24% 

23% 

23% 

23% 

21% 

22% 

19% 

23% 

21% 

16% 

27% 

20% 

14% 

26% 

Academic 

support and 

enrichment 

Language 

and culture 

Parent 

involvement 

College 

and career 

Prevention 

School 

readiness 

Correctional 

Exhibit reads: In 2017–18, 62 percent of grantees offered teachers and support staff professional development for 

academic support, and 14 percent planned to offer professional development in this area. 

Source: Survey of Title VI Grant Coordinators, Item 15 (n = 1,146; see Exhibit A-8 in the Technical Appendix). 

In the case study interviews, teachers in one school district described having received some professional 

development to address the culturally specific needs of American Indian and Alaska Native students. The 

teachers participated in professional development the local tribe provided to help school staff learn 

about American Indian and Alaska Native cultures. As one school staff member explained, 

[The tribe] actually did a kind of mini-camp for us. It was a day when they went over 

different types of cultural taboos and things that for me as a teacher were very helpful to 

understand more about... [their] beliefs about animals and beliefs about family members 

Implementation of the Title VI Indian Education Formula Grants Program 11 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

and why every female family member is called an aunt or a grandma, even though 

they’re not related. Several things like that. 

In another case study site, teachers had direct experiences to help them incorporate culturally 

responsive education into their professional practice. The superintendent described how the district 

inducted new teachers as follows. 

We will have all new teachers come here first, in [town], and then...they are going to 

become familiar with the expectations for the state standards and the state cultural 

standards, overall district perspectives on the cultural piece of our program, and then go 

[to area villages to] become more engaged in how it is actually applied in our different 

villages. 

School districts and BIE-funded schools and tribes differed in the areas they provided professional 

development to support the delivery of Title VI-funded services and activities (Exhibit 8). School districts, 

for example, were more likely than BIE-funded schools and tribes to report offering (or planning to 

offer) professional development to teachers and support staff on dropout prevention, mentoring, career 

preparation, and college preparation. Grantees from BIE-funded schools and tribes were significantly 

more likely than those from school districts to report offering (or planning to offer) professional 

development for teachers and support staff on Indian education (e.g., language, history) and native 

language instruction. 

Exhibit 8. Title VI-funded services and activities for which professional development was offered 

or planned, by grantee type, 2017–18 

School 

districts 

BIE schools 

and tribes 

Percentage 

point difference 

Programs for students in correctional facilities 27% 69% 42 

Native language instruction 39 77 38 

Indian education 64 85 21 

Gifted and talented program 40 58 18 

Substance abuse prevention 47 64 17 

Suicide prevention 50 64 14 

Family literacy 45 59 14 

Student advocacy/leadership 52 64 12 

Violence prevention 50 61 11 

Exhibit reads: In 2017–18, 27 percent of district grantees and 69 percent of BIE and tribal grantees offered or 

planned to offer professional development in programs for students in correctional facilities, a 42 percentage point 

difference. 

Note: All differences between groups are statistically significant at p < .05. 

Source: Survey of Title VI Grant Coordinators, Item 15 (school districts n = 1,027; BIE schools and tribes n = 119; see Exhibit A-9 in the Technical 

Appendix). 

Finally, grantees with larger awards were more likely than grantees with smaller awards to report 

offering (or planning to offer) professional development to teachers and support staff to support the 

delivery of the services and activities they funded (Exhibit 9). 

Implementation of the Title VI Indian Education Formula Grants Program 12 
 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 9. Title VI-funded services and activities for which professional development was offered 

or planned, by grant award size, 2017–18 

Larger awards 

(above median) 

Smaller awards 

(below median) 

Percentage 

point difference 

Indian education 73% 58% 15 

Cultural enrichment 79 67 12 

Dropout prevention strategies 58 47 11 

Career preparation 57 46 11 

College preparation 56 47 9 

Native language instruction 47 39 8 

Exhibit reads: In 2017–18, 73 percent of grantees with larger awards and 58 percent of grantees with smaller 

awards offered or planned to offer professional development in Indian education, a 15 percentage point 

difference. 

Note: All differences between groups are statistically significant at p < .05. 

Source: Survey of Title VI Grant Coordinators, Item 15 (grantees with larger awards n = 590; grantees with smaller awards n = 556; see Exhibit 

A-10 in the Technical Appendix). 

Supporting Culturally Responsive Education 

Title VI grantees relied on several strategies to provide activities and services using culturally responsive 

educational practices. 

More than two thirds of grantees supported culturally responsive education by 

incorporating American Indian and Alaska Native history and culture into the 

curriculum (70 percent) and using American Indian and Alaska Native teachers and 

support staff (68 percent). 

Less frequently, Title VI grantees connected students with mentors or counselors from the tribal 

community (48%) and delivered instruction in students’ heritage language (32%) (Exhibit 10). 

Implementation of the Title VI Indian Education Formula Grants Program 13 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 10. Title VI grantee practices to support culturally responsive education for American Indian 

and Alaska Native (AI/AN) students, 2017–18 

 

Incorporate AI/AN history and culture into the 

curriculum 

Use AI/AN teachers and/or support staff 

Connect students with mentors or counselors 

from tribal community 

Deliver instruction in students' heritage language 

Administer assessments in AI/AN languages 15% 

32% 

48% 

68% 

70% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Exhibit reads: In 2017–18, 70 percent of grantees reported that they supported culturally responsive education by 

incorporating American Indian and Alaska Native history and culture into the curriculum. 

Note: Analyses excluded respondents selecting “Not applicable” or “Don’t know.” 

Source: Survey of Title VI Grant Coordinators, Item 16 (n = 1,150; see Exhibit A-11 in the Technical Appendix). 

In case study interviews, respondents described the strategies they implemented to support a culturally 

responsive education for students, such as by using American Indian and Alaska Native teachers and 

support staff to teach native languages, providing guidance and support to nonnative staff, and 

strengthening school-parent relationships. One case study grantee used Title VI funding to fund a parttime coordinator as well as part-time afterschool staff. The coordinator served as a cultural resource 

teacher who also supported culturally responsive education throughout the school day. For example, 

the coordinator visited classrooms to lead activities in American Indian culture, stories, and arts and 

crafts. At another site, Title VI funds supported a culture class in which students learned tribal history 

and customs as well as the native language. 

Another Title VI grantee described having elders and community members engage students in activities 

related to tribal traditions and cultural knowledge. The superintendent explained, 

In [one of the villages], they have a fish camp and... they go up there and do all the 

traditional activities, the hunting and the fishing, [and] how to survive in this 

environment. We just try to integrate those essential subsistence activities that [the 

tribes] do. 

Grantees also explained how they incorporated American Indian and Alaska Native history and culture 

into their curricula. One grantee had students do project-based learning that included culturally relevant 

Implementation of the Title VI Indian Education Formula Grants Program 14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

hands-on math, science, and career-tech while ensuring that they stayed active and outdoors in the 

winter. A grantee staff member described the program as follows. 

Starting this year, [we did] a high school mushing program. We’re building in carpentry. The kids 

made doghouses....They put up the fish, and in science we take that fish and look under a microscope 

for bacterial growth, depending on how we cure that fish and compare different brines to see how 

the process was done, to see what’s going to grow mold, what’s not going to grow mold.... We also 

had the [name] native veterinarian come out and they allowed our kids to be sitting in on the process 

of spaying and neutering [mushing dogs]... [They are also developing the] life skill of how to keep 

yourself busy...and really just getting out and enjoying the sound of the sled and the tug that it 

always gives you. 

A middle school counselor encouraged the teachers to assign academic work that acknowledged tribes 

in the area so that students could see themselves and their culture as connected to academic work. She 

explained her rationale: 

A lot of the [American Indian and Alaska Native] kids...are just trying to figure out who 

they are, and it's a hard time for them. A lot of them are just trying to blend in with 

everybody else. It's really hard to own that native identity. It’s important to show them 

that it’s OK. We’re still here. 

The principal of a Title VI-funded school provided a specific example of how he looked for connections 

between the native culture and the curriculum. He described how he would weave American Indian 

studies into American history by drawing on the parallels between the two experiences: 

If I was looking at the strategies of General Patton, who had tanks, [I would compare 

them to the Battle of Little Big Horn], where the Indians had horses and they had 

scouts.... They all had to have a battle plan. They all used terrain and maps... [Y]ou have 

to do scenarios like that to show that the strategies are the same; it’s just that the 

instruments of war are different because of technology and time. 

BIE schools and tribes were more likely than school districts to support a culturally responsive education 

through a variety of practices. BIE and tribal grantees were more likely than district grantees to deliver 

instruction in students’ native languages (68 percent vs. 28 percent), administer assessments in 

students’ languages (38 percent vs. 12 percent), use American Indian and Alaska Native teachers and 

support staff (83 percent vs. 66 percent), and incorporate American Indian and Alaska Native history and 

culture into the curriculum (83 percent vs. 69 percent) (Exhibit 11). 

Implementation of the Title VI Indian Education Formula Grants Program 15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 11. Title VI grantee practices to support culturally responsive education, by grantee type, 

2017–18 

School 

districts 

BIE schools 

and tribes 

Percentage 

point difference 

Deliver instruction in AI/AN students’ heritage language 28% 68% 40 

Administer assessments in AI/AN languages 12 38 26 

Use AI/AN teachers and support staff 66 83 17 

Incorporate AI/AN history and culture into the curriculum 69 83 14 

Exhibit reads: In 2017–18, 28 percent of district grantees and 68 percent of BIE schools and tribal grantees 

supported a culturally responsive education by delivering instruction in students’ heritage language, a 

40 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. Analyses excluded respondents selecting “Not applicable” or “Don’t 

know.” 

Source: Survey of Title VI Grant Coordinators, Item 16 (school districts n = 1,030; BIE schools and tribes n = 120; see Exhibit A-12 in the Technical 

Appendix). 

Finally, grantees with larger awards were more likely than grantees with smaller awards to use multiple 

strategies to support culturally responsive education (Exhibit 12). 

Exhibit 12. Title VI grantee practices to support culturally responsive education, 

by grant award size, 2017–18 

Larger awards 

(above median) 

Smaller awards 

(below median) 

Percentage 

point difference 

Use AI/AN teachers and support staff 79% 55% 24 

Connect students with mentors or counselors from the 

tribal community 

58 38 20 

Incorporate AI/AN history and culture into the curriculum 77 64 16 

Deliver instruction in AI/AN students’ heritage language 40 24 16 

Administer assessments in AI/AN languages 19 10 9 

Exhibit reads: In 2017–18, 79 percent of grantees with larger awards and 55 percent of grantees with smaller 

awards supported a culturally responsive education by using American Indian and Alaska Native teachers and 

support staff, a 24 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. Analyses excluded respondents selecting “Not applicable” or “Don’t 

know.” 

Source: Survey of Title VI Grant Coordinators, Item 16 (larger awards n = 592; smaller awards n = 558; see Exhibit A-13 in the Technical 

Appendix). 

The majority of grantees reported minimal or no challenges delivering their Title VI 

services using culturally responsive practices; yet, a sizable minority did report 

challenges in certain areas. 

Services that grant coordinators most often reported as somewhat challenging or very challenging to 

deliver using culturally responsive practices included parent involvement and programs for students in 

correctional facilities. Specifically, 51 percent of grantees who used grant funding to provide parent 

involvement services reported that using culturally responsive practices to do so was somewhat 

challenging (33%) or very challenging (18%); 48 percent of grantees who used grant funding to deliver 

Implementation of the Title VI Indian Education Formula Grants Program 16 
 

 

 

 

 

 

 

 

 

 

programs for students in correctional facilities reported that it was somewhat challenging (37%) or very 

challenging (11%) to use culturally responsive practices. 

Exhibit 13. Grantees reporting challenges to using culturally responsive practices to deliver Title VIfunded services, 2017–18 

■ ■ ■ 

Academic enrichment 

Academic support 

Gifted and talented program 

Native language instruction 

Indian education 

Cultural enrichment 

Parent involvement 

Career preparation 

Mentoring 

Student advocacy/leadership 

College preparation 

Counseling 

Dropout prevention strategies 

Suicide prevention 

Substance abuse prevention 

Violence prevention 

Family literacy 

Early childhood programs 

Programs for students in correctional facilities 

5% 18% 

4% 19% 

4% 13% 

14% 24% 

7% 25% 

4% 21% 

18% 33% 

4% 26% 

5% 21% 

4% 21% 

6% 20% 

4% 18% 

8% 28% 

6% 25% 

4% 26% 

4% 26% 

7% 24% 

4% 18% 

11% 37% 

76% 

77% 

83% 

62% 

68% 

76% 

50% 

70% 

74% 

75% 

74% 

77% 

64% 

69% 

70% 

70% 

69% 

78% 

52% 

Academic 

support and 

enrichment 

Language and 

culture 

Parent 

involvement 

College and 

career 

Prevention 

School 

readiness 

Correctional 

facilities 

programs 0% 20% 40% 60% 80% 100% 

Percent of grantees 

Very challenging Somewhat challenging Minimally/not challenging 

Exhibit reads: In 2017–18, among grantees that provided academic enrichment, 5 percent reported that using 

culturally responsive practices to deliver academic enrichment was very challenging, 18 percent reported that it 

was somewhat challenging, and 76 percent reported that it was minimally challenging or not challenging. 

Note: The number of respondents for this exhibit varies because the question was asked only of those respondents that reported providing 

each type of practice (see Exhibit 4). Analyses excluded respondents selecting “Not applicable” or “Don’t know.” Numbers may not add to 100% 

due to rounding. 

Source: Survey of Title VI Grant Coordinators, Item 18 (n = 27–943; see Exhibit A-14 in the Technical Appendix). 

In addition, 38 percent of grantees providing native language instruction found this somewhat or very 

challenging to do using culturally responsive practices, as did 32 percent of those providing Indian 

Implementation of the Title VI Indian Education Formula Grants Program 17 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

education (e.g., language and history). Case study grantees that served multiple tribes noted that they 

did not have the capacity to provide language instruction in all of the students’ native languages so, 

while they did provide native language instruction, they were not able to do so in a way that is culturally 

responsive for all students. Among grantees who reported delivering other types of services, more than 

30 percent or more found it somewhat or very challenging to use culturally responsive practices for 

dropout prevention (36 percent), family literacy (31 percent), and suicide prevention (31 percent) 

(Exhibit 13). 

The greatest challenge in Title VI grantees’ delivery of services using culturally 

responsive practices was the availability of school staff with relevant knowledge of 

and expertise in native languages, culturally responsive education, and students’ 

cultural background. 

Of those grantees that found it somewhat or very challenging to deliver Title VI grant-funded services 

using culturally responsive practices (58 percent), most reported challenges with the availability of 

school staff knowledgeable about heritage languages (87 percent) or with expertise in culturally 

responsive education (80 percent) (Exhibit 14). Other factors were the availability of school staff 

knowledgeable about students’ cultural backgrounds (72 percent) or the availability of staff within their 

organization (e.g., school district, BIE, or tribe) with expertise in culturally responsive education 

(72 percent). 

Exhibit 14. Factors challenging grantees’ efforts to deliver Title VI-funded services using culturally 

responsive practices, 2017–18 

■ ■ ■ 

Availability of school staff knowledgeable about heritage 

languages 

Availability of school staff with expertise 

Availability of staff within our organization with expertise 

Availability of school staff knowledgeable about students’ 

cultural backgrounds 

Availability of professional development or training 

Access to instructional materials 

Aligning state and local policy with goals of culturally 

responsive education 

Multiple tribal cultures represented 20% 

24% 

28% 

31% 

31% 

35% 

39% 

63% 

35% 

40% 

35% 

40% 

41% 

37% 

41% 

24% 

45% 

36% 

38% 

29% 

28% 

28% 

21% 

13% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Very challenging Somewhat challenging Minimally/not challenging 

Exhibit reads: In 2017–18, among grantees who found using culturally responsive practices to deliver grant-funded 

services somewhat or very challenging, 63 percent reported that the availability of school staff knowledgeable 

about heritage languages was very challenging, 24 percent found it somewhat challenging, and 13 percent found it 

minimally challenging or not challenging. 

Note: Only grantees that considered it “somewhat” or “very” challenging to deliver services using culturally responsive practices on Item 18 

responded to this question. Analyses excluded respondents selecting “Not applicable” or “Don’t know.” Numbers may not add to 100% due to 

rounding. 

Source: Survey of Title VI Grant Coordinators, Item 19 (n = 653; see Exhibit A-18 in the Technical Appendix). 

Implementation of the Title VI Indian Education Formula Grants Program 18 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

A teacher interviewed at a case study site offered some insight into the specialized skills and investment 

of time required to provide a culturally responsive education. She explained that integrating native 

culture into a teacher’s regular curriculum is difficult in terms of finding appropriate cultural materials, 

weaving the materials effectively into the instructional plan, and then striking a good balance between 

academics and culture. In another site, the Title VI grant coordinator said that the physical distance 

between the school and the tribe hindered the site’s efforts to offer language classes at the school; the 

travel time between the tribe and the school meant that project staff members coming from the 

reservation were unable to visit the school frequently. 

The types of challenges Title VI grantees confronted in delivering grant-funded services using culturally 

responsive practices varied by grantee type, with school districts reporting more significant challenges 

than BIE schools or tribes with the availability of staff with expertise within their organizations 

(74 percent of school districts and 54 percent of BIE schools and tribes identified this as somewhat or 

very challenging) and with the availability of school-based staff with knowledge of students cultural 

backgrounds (74 percent vs. 58 percent) (see Exhibit A-19 in the Technical Appendix). 

Coordinating with Other Programs 

Many federal, state, and local programs share the goal of improving academic outcomes for 

disadvantaged students. Title VI grants program funds must be supplemental, thus grantees are 

required to coordinate with other federal programs so as to create coherence and alignment across 

programs that serve many of the same students. 

The vast majority of grantees (89 percent) reported coordinating Title VI-funded 

services with at least one other program. The most common programs were Title I, 

Part A programs (67 percent), Individuals with Educational Disabilities Act programs 

(57 percent), and the BIE-funded Johnson-O’Malley programs (45 percent). 

Other programs with which the Title VI-funded services were commonly coordinated included the 

Education for Homeless Children and Youth program (43 percent), programs delivered by local social 

service providers (35 percent), and Impact Aid (34 percent) (Exhibit 15). Grantees less frequently 

coordinated Title VI-funded services with Title IV (student support and enrichment) (29 percent), Title III 

Language Instruction for English Learners (29 percent), and Title I, Part D Neglected and Delinquent 

Programs (27 percent). 

Implementation of the Title VI Indian Education Formula Grants Program 19 
Exhibit 15. Federal, state, and local programs with which Title VI grantees coordinated grantfunded services and activities, 2017–18 

Title I, Part A 

IDEA programs 

Johnson-O’Malley programs 

Education for Homeless Children and Youth Program 

Programs delivered by local social service providers 

Impact Aid 

Title III, Language Instruction for English Learners 

Title IV (student support, enrichment grants, 

family engagement) 

Title I, Part D, Neglected and Delinquent Programs 

State-funded programs 

Other federally funded programs 

Other BIE programs 

Other programs serving at-risk students and families 

Title I, Part C, Migrant Education Program 

Locally funded programs 

 

67% 

57% 

45% 

43% 

35% 

34% 

29% 

29% 

27% 

21% 

20% 

16% 

15% 

14% 

12% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

 

 

 

 

 

 

 

 

 

 

Exhibit reads: In 2017–18, 67 percent of grantees reported coordinating services and activities with Title I, Part A. 

Note: The five programs referenced by their Title number (e.g., Title I, Part A) are authorized under the Elementary and Secondary Education 

Act (ESEA). The Title IV programs covered in the survey questionnaire specifically included Student Support and Academic Enrichment Grants 

(Part A) and 21st Century Community Learning Centers (Part B). 

Source: Survey of Title VI Grant Coordinators, Item 23 (n = 1,146; see Exhibit A-21 in the Technical Appendix). 

The size of the grant award was associated with differences in coordination with some federal programs. 

Grantees with larger awards were more likely than grantees with smaller awards to coordinate with 

programs such as Johnson-O’Malley (63 percent vs. 46 percent), the Education for Homeless Children 

and Youth Program (59 percent vs. 43 percent), and Title VI, Part D (43 percent vs. 29 percent) 

(Exhibit 16). 

Implementation of the Title VI Indian Education Formula Grants Program 20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 16. Programs with which grantees coordinated Title VI-funded services and activities, by 

grant award size, 2017–18 

Larger awards 

(above median)

Smaller awards 

(below median) 

Percentage 

point difference 

Johnson-O’Malley programs 63% 46% 17 

Education for Homeless Children and Youth Program 59 43 16 

Title I, Part D, Neglected and Delinquent Programs 43 29 14 

Impact Aid 49 36 13 

Title III, Language Instruction for English Learners 42 30 12 

Title I, Part C, Migrant Education Program 23 15 8 

Exhibit reads: In 2017–18, 63 percent of grantees with larger awards and 46 percent of grantees with smaller 

awards reported coordinating services and activities with Johnson-O’Malley programs, a 17 percentage point 

difference. 

Note: All differences between groups are statistically significant at p < .05. Analyses excluded respondents selecting “Not applicable” or “Don’t 

know.” The three programs referenced by their Title number (e.g., Title I, Part D, Neglected and Delinquent Programs) are authorized under 

ESEA. 

Source: Survey of Title VI Grant Coordinators, Item 23 (grantees with larger awards n = 545; grantees with smaller awards n = 495; see Exhibit 

A-22 in the Technical Appendix). 

There were also differences by grantee type in the frequency with which Title VI projects were 

coordinated with other programs. BIE and tribes coordinated more frequently with some programs (e.g., 

Title I, Part D, Neglected and Delinquent Programs and IDEA programs), and school districts coordinated 

more frequently with others (e.g., Johnson-O’Malley programs and Impact Aid) (Exhibit 17). 

Exhibit 17. Programs with which grantees coordinated Title VI-funded services and activities, by 

grantee type, 2017–18 

School 

districts 

BIE schools 

and tribes 

Percentage 

point difference 

More commonly done by BIE schools and tribes 

Title I, Part D, Neglected and Delinquent Programs 34% 57% 23 

IDEA programs 63 84 21 

Title IV (student support, enrichment) 36 55 19 

Programs delivered by local service providers 41 54 13 

Title III, Language Instruction for English Learners 35 47 12 

More commonly done by districts 

Johnson-O’Malley programs 57 40 17 

Impact Aid 44 27 17 

Exhibit reads: In 2017–18, 34 percent of district grantees and 57 percent of BIE and tribal grantees reported 

coordinating services and activities with Title I, Part D programs, a 23 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. Analyses excluded respondents selecting “Not applicable” or “Don’t 

know.” The three programs referenced by their Title number (e.g., Title I, Part D, Neglected and Delinquent Programs) are authorized under 

ESEA. The Title IV programs covered in the survey questionnaire specifically included Student Support and Academic Enrichment Grants (Part A) 

and 21st Century Community Learning Centers (Part B). 

Source: Survey of Title VI Grant Coordinators, Item 23 (school districts n = 940; BIE schools and tribes n = 100; see Exhibit A-23 in the Technical 

Appendix). 

Implementation of the Title VI Indian Education Formula Grants Program 21 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The strategies grantees most commonly adopted to facilitate coordination with other 

programs included sharing data on students (76 percent) and sharing information on 

programs and services they believed to be effective (70 percent). 

Additional but slightly less commonly reported coordination strategies included sharing costs associated 

with providing services (61 percent) and building programmatic linkages among programs, agencies, and 

organizations (53 percent). Title VI grantees did not distinguish among programs when employing 

strategies to facilitate coordination of Title VI-funded services and activities. For example, more than 

half the grantees reported sharing data with each of 15 programs, including state-funded programs, 

Johnson-O’Malley programs, Title I Part A, and IDEA programs (see Exhibit A-24 in the Technical 

Appendix). Similarly, approximately half the grantees reported sharing information on programs and 

services they believed to be effective with most other programs, including state-funded programs, 

programs serving at-risk students and families, and Johnson-O’Malley programs. 

In case study interviews, Title VI grant coordinators described coordinating funding with Title I, IDEA 

special education programs, Title III programs serving English learners, and Carl D. Perkins Career and 

Technical Education Improvement grants. One grantee coordinated Title III dollars and state dollars for 

English learners to support its native language program. Another grantee shared the cost of—and 

provided—professional development for paraprofessionals with the district’s multilingual and special 

education departments. A principal in a third site described coordinating Title VI programming with 

funding from the Perkins program. 

It's not always a perfect fit, but if you’re learning building skills and stuff like that, then that can 

apply to making the [culturally relevant product]. It’s not exactly home construction or anything, 

but it's certainly vocational in the sense that there is money to be made in making the [culturally 

relevant product] and just life skills. 

Limited staff time and capacity were the greatest challenges to coordinating services 

across programs. 

Grantees faced challenges coordinating services across programs. Nearly a third (31 percent) of grantees 

reported that limited staff time or capacity to coordinate services was among the very challenging 

aspects of coordinating Title VI-funded services with other programs, while another third (32 percent) 

identified limited staff time or capacity as somewhat challenging (Exhibit 18). 

In an interview, a grant coordinator described a challenge in coordinating Title VI-funded services with 

Johnson-O’Malley services. Even though they both serve American Indian and Alaska Native students, 

not all students are eligible for or enrolled in both programs and it can be a challenge to communicate 

to students and families why students may not eligible for certain services. The grant coordinator 

explained: 

[Johnson-O’Malley has] a school clothing program and things like that, but if you are not 

a tribal member, you don’t get help with that.... I deal with it all the time. I’ve got some 

girls [who] are enrolled [in a tribe] and some who aren’t. Some of them get help with 

this, and then the others don’t. 

Implementation of the Title VI Indian Education Formula Grants Program 22 
 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 18. Grantees reporting challenges to coordinating Title VI-funded services with other 

programs, 2017–18 

 

 

■ ■ ■ 

Limited staff time or capacity to coordinate services 

Physical distance between programs, agencies, and 

organizations serving AI/AN students 

Blending funding/sharing costs across programs and 

services 

Sharing or linking data on AI/AN students across 

programs, agencies, and organizations 

Identifying areas for programmatic linkages among 

programs, agencies, and organizations 

Competing priorities across programs, agencies, and 

organizations serving AI/AN students 

31% 32% 38% 

16% 21% 63% 

12% 26% 62% 

9% 27% 64% 

7% 33% 60% 

7% 29% 64% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Very challenging Somewhat challenging Minimally/not challenging 

Exhibit reads: In 2017–18, 31 percent of grantees reported that limited staff time or capacity was very challenging, 

32 percent reported it was somewhat challenging, and 38 percent reported that limited staff time or capacity was 

either minimally challenging or not challenging to their efforts to coordinate with other federal, state, and 

local programs. 

Note: Analyses excluded respondents selecting “Not applicable” or “Don’t know.” Numbers may not add to 100% due to rounding. 

Source: Survey of Title VI Grant Coordinators, Item 25 (n = 1039; see Exhibit A-28 in the Technical Appendix). 

Chapter Summary 

Title VI grantees reported using the funding to support an array of activities and services intended to 

support American Indian and Alaska Native students’ education. Common Title VI-funded services 

included academic support such as homework and study skills assistance, cultural enrichment such as 

field trips and special events, and parent involvement. In their delivery of funded activities and services, 

grantees most frequently said they incorporated culturally responsive education practices by 

incorporating American Indian and Alaska Native history and culture into the curriculum and using 

American Indian and Alaska Native teachers and support staff. Efforts to deliver culturally responsive 

education were not without challenges, the most common being the availability of school staff 

knowledgeable about native language, with expertise in culturally responsive education, or 

knowledgeable about students’ cultural backgrounds. Finally, to improve coherence and alignment of 

services and activities, grantees reported coordinating their Title VI-funded services with other federal, 

state, and local programs. Coordination strategies included sharing information across services to 

address the needs of American Indian and Alaska Native students. Limited staff time or capacity to 

coordinate services was among the somewhat or very challenging aspects of coordinating Title VIfunded services with other programs. 

Implementation of the Title VI Indian Education Formula Grants Program 23 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3. Identifying Program-Eligible Children and 

Planning Services to Meet Their Needs 

School districts, BIE-funded schools, tribes, Indian organizations, and Indian community-based 

organizations may apply for Title VI grants if they serve or represent a minimum number of eligible 

American Indian and Alaska Native children. Grant award amounts are based on the number of eligible 

children the grantee serves, so timely, accurate, and complete identification and counting of eligible 

children are critical. 

In addition to the identification of program-eligible children, the Title VI Indian Education Formula 

Grants program requires school districts to plan services with the participation and approval of a 

committee of parents and family members of the children, tribal representatives, teachers, and students 

(ESEA § 6114(c)(4)) and to develop the program through meaningful collaboration with Indian tribes 

(ESEA § 6114(b)(7)). All grantees must base those services on a comprehensive assessment of “the 

unique educational and culturally related academic needs of the Indian students for whom the local 

educational agency is providing an education” (ESEA § 6114(c)(3)(A)) and plan services through “open 

consultation with parents of Indian children and teachers, representatives of Indian tribes..., and, if 

appropriate, Indian students from secondary schools, including through public hearings” (ESEA § 

6114(c)(3)(C)). 

This chapter describes grantees’ practices for identifying and counting program-eligible children and 

planning services in collaboration with stakeholders and based on an assessment of student needs. Also 

discussed are the challenges grantees reported in these endeavors. 

Identifying Program-Eligible Children 

As Title VI funding is calculated with a formula based on the number of eligible students, the 

identification of eligible students directly influences the amount of a Title VI grantee’s funding. The 

Office of Indian Education has issued an OMB-approved form entitled “Title VI ED 506 Student Eligibility 

Certification Form” (ED 506 form) which school districts must use for this purpose (the form is available 

in Appendix C of Volume II of this report). This form includes the statutory definition of Indian: 

[A]n individual who is (1) A member of an Indian tribe or band, as membership is defined 

by the Indian tribe or band, including any tribe or band terminated since 1940, and any 

tribe or band recognized by the State in which the tribe or band resides; (2) A descendant 

of a parent or grandparent who meets the requirements described in paragraph (1) of 

this definition; (3) Considered by the Secretary of the Interior to be an Indian for any 

purpose; or (4) An Eskimo or Aleut or other Alaska Native; or (5) A member of an 

organized Indian group that received a grant under the Indian Education Act of 1988 as 

it was in effect October 19, 1994. 

The form requires families to provide the name of the tribe or band for which their child (or child’s 

parent or grandparent) claims membership and to provide proof of enrollment through either a 

Implementation of the Title VI Indian Education Formula Grants Program 24 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

membership or enrollment number “if readily available” or “other evidence of membership.”7 Grantees 

must maintain on file a form for each eligible student that contains the elements required by the 

statute, though the form only needs to be completed once and can stay on file for the duration of the 

student’s education as part of their education record. 

All Title VI grantees except for BIE-funded schools are required to use the ED 506 form to document 

eligible students. BIE-funded schools have the option of using either the Indian Education School 

Equalization Program (ISEP) count (using the most current BIE-certified Indian student count) or ED 506 

form. Of the BIE schools that participated in the survey, 89 percent used the ISEP count and 11 percent 

used the ED 506 form. 

Strategies Used to Identify Eligible Students 

Most grantees reported relying on three strategies to identify eligible students: 

(1) including questions about students’ American Indian and Alaska Native status in 

the school registration process, (2) including ED 506 forms in enrollment packets, and 

(3) generating reports for students who were identified as American Indian and Alaska 

Native on enrollment forms. 

Three fourths of grantees reported including questions about students’ American Indian and Alaska 

Native status in the school registration process (76 percent) and including the ED 506 form in school 

enrollment packets (75 percent) (Exhibit 19). In case study interviews, a school administrator 

commented that asking about student status in the school registration process was a more systematic 

process to identify students that did not depend on staff judgment or knowledge. Another district 

administrator explained that they used an online registration system that automatically directed people 

to the ED 506 form if they selected American Indian or Alaska Native (either on its own or in 

combination with other race/ethnicities). 

7 The Office of Indian Education provide the following guidance for cases in which a student’s tribal enrollment membership 

number: “Tribal enrollment criteria are set forth in tribal constitutions, articles of incorporation or ordinances. The criterion 

varies from tribe to tribe, so uniform membership requirements do not exist. Each tribe determines whether an individual is 

eligible for membership and maintains its own enrollment records and records about past members. Some tribes require 

conditions such as tribal blood quantum, tribal residency, or continued contact with the tribe. To obtain information about 

tribal enrollment documentation, you must contact the tribe. More information can be found at 

https://www.doi.gov/tribes/enrollment” (U.S. Department of Education 2019). 

Implementation of the Title VI Indian Education Formula Grants Program 25 
 

 

 

 

 

 

 

 

 

Exhibit 19. Strategies grantees used to identify students eligible to receive Title VI-funded services, 

2017–18 

 

 

 

 

 

 

 

 

 

 

 

Include questions about students’ AI/AN status 

as part of school registration 

Include ED 506 form in school enrollment packets 

Generate reports on students who identified their 

secondary ethnicity as AI/AN 

Conduct targeted outreach to notify families about 

Title VI-funded services 

Coordinate with local tribes and tribal organizations 

to determine AI/AN student eligibility 

Disseminate eligibility information to schools 

Conduct awareness-raising activities with staff 

Coordinate with Title VI Parent Advisory Committee 

to notify families about available services 

Coordinate with local tribes and tribal organizations 

to notify families about available services 

Include common tribal affiliations on the 

ED 506 form 24% 

27% 

31% 

39% 

45% 

47% 

53% 

66% 

75% 

76% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Exhibit reads: In 2017–18, 76 percent of grantees included questions about students’ American Indian and Alaska 

Native status as part of the school registration process. 

Note: BIE schools that used the ISEP count in place of the ED 506 form did not respond to this question. 

Source: Survey of Title VI Grant Coordinators, Item 2 (n = 1,071; see Exhibit A-31 in the Technical Appendix). 

The third most commonly reported strategy was to generate reports on students who identify as 

American Indian and Alaska Native (66 percent of grantees). For example, in case study interviews a 

grantee staff member from a district consortium reported searching the data system to see which 

students identified as American Indian or Alaska Native on enrollment forms and then mailing and 

emailing an ED 506 form to their families. In another district, the online enrollment system collected 

demographic information about students, which grantee staff used to identify families who should 

complete the ED 506 form. 

Other common strategies included conducting targeted outreach to families (53 percent) and 

collaboration between school districts and local tribes and tribal organizations (47 percent). For 

example, in case study interviews, a grantee staff member commented that parents sometimes did not 

know about the Title VI program and explained the importance of having someone they trust reach out 

to them. A Title VI-funded teacher at another site noted that relying on staff known to the community 

helped with these outreach efforts: “It goes back to being somebody from the community, somebody 

that they trust.... Somebody who is looking out for their child and is trying to do what’s best to help 

them.” Case study participants also provided examples of how collaboration between school districts 

Implementation of the Title VI Indian Education Formula Grants Program 26 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

and local tribes to build positive relationships with families can ease the process of identifying students 

and getting completed ED 506 forms. For example, a staff member from a tribe grantee described how 

they had worked with school district staff during the past three years to build trust and relationships 

with families, participating in enrollment activities at the various school districts that serve the tribe’s 

students and explaining to parents the need for the ED 506 form. However, the interviewee commented 

that this strategy was not feasible for collaborating with districts that serve small numbers of eligible 

students and are located too far from the tribe to use this in-person approach to build relationships. 

The strategies grantees used to identify eligible students also varied by grant award size. For example, 

grantees with larger awards were more likely than those with smaller awards to report coordinating 

with local tribes and tribal organizations to notify families about available services (35 vs. 19 percent) 

and determine student eligibility for services (54 percent vs. 40 percent); conducting awareness-raising 

activities such as trainings, presentations, or meetings (46 percent vs. 32 percent); and coordinating with 

the Title VI Parent Advisory Committee to notify families about available Title VI-funded services (37 

percent vs. 24 percent) (Exhibit 20). 

Exhibit 20. Strategies grantees used to identify students eligible to receive Title VI-funded services, 

by grant award size, 2017–18 

Larger awards 

(above median) 

Smaller awards 

(below median) 

Percentage 

point 

difference 

Coordinate with local tribes and tribal organizations to 

notify families about available services 

35% 19% 16 

Collaborate and coordinate with local tribes and tribal 

organizations to determine AI/AN student eligibility 

54 40 14 

Conduct awareness-raising activities 46 32 14 

Coordinate with Title VI Parent Advisory Committee to 

notify families about available services 

37 24 13 

Disseminate eligibility information to schools 50 40 10 

Include ED 506 form in school enrollment packets 80 71 9 

Coordinate with school or tribal-based committees to 

notify families about available services 

26 18 8 

Exhibit reads: In 2017–18, 35 percent of grantees with larger grant awards (above the median) and 19 percent 

with smaller awards coordinated with local tribes and tribal organizations to notify families about available 

services, a 16 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. BIE schools that used the ISEP count in place of the ED 506 form did 

not respond to this question. 

Source: Survey of Title VI Grant Coordinators, Item Q2 (n = 1,071; see Exhibit A-32 in the Technical Appendix). 

The majority of grantees indicated that they did not experience significant challenges 

with the strategies they used to identify eligible children. However, challenges remain 

for some. 

Among Title VI grantees that conducted targeted outreach (e.g., by phone or email) to notify families 

about grant-funded services for eligible children, 44 percent reported that it was somewhat challenging 

(33 percent) or very challenging (11 percent) (Exhibit 21). In interviews, several grantees also said that 

conducting targeted outreach required significant staff time and resources. One grant coordinator noted 

that reaching out to families to collect ED 506 forms was time intensive, commenting, “All of my staff 

Implementation of the Title VI Indian Education Formula Grants Program 27 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

have to chase forms. My office staff is chasing forms. Our school district personnel are chasing forms. All 

of that time and effort is [spent] away from our students.” A teacher at this site explained how she built 

at least one hour a week into her schedule—and a lot more time at the beginning of the school year—to 

collect ED 506 forms. 

Exhibit 21. Title VI grantees reporting challenges with strategies to identify eligible children, 

2017–18 

 

■ ■ ■ 

Conduct targeted outreach to notify families about 

Title VI-funded services 

Coordinate with local tribes and tribal organizations to 

determine AI/AN student eligibility 

Coordinate with the Title VI Parent Advisory Committee to 

notify families about available services 

Conduct awareness-raising activities 

Coordinate with local tribes and tribal organizations to 

notify families about available services 

Generate reports for students who identified their 

secondary ethnicity as AI/AN 

Include questions about students’ AI/AN status as part of 

school registration 

Disseminate eligibility information to schools 

Include ED 506 form in school enrollment packets 

Include common tribal affiliations on the ED 506 form 

33% 56% 

72% 

11% 

6% 22% 

5% 20% 76%

26% 70% 

18% 79%

9% 89% 

90% 

91% 

94% 

8% 

8% 

5% 

6% 94% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Very challenging Somewhat challenging Not or minimally challenging 

Exhibit reads: In 2017–18, among Title VI grantees that conducted targeted outreach to notify American Indian 

and Alaska Native families about available grant-funded services for eligible students, 11 percent reported that 

conducting targeted outreach was very challenging, 33 percent reported it was somewhat challenging, and 56 

percent reported it was minimally challenging or not challenging. 

Note: BIE schools that used the ISEP count in place of the ED 506 form did not respond to this question. The number of respondents for this 

exhibit varies because the question was asked only of those respondents that reported using each strategy to identify Title VI-eligible children 

(see Exhibit 19). Numbers may not add to 100% due to rounding. 

Source: Survey of Title VI Grant Coordinators, Item 3 (n = 114–808; see Exhibit A-34 in the Technical Appendix). 

Targeted outreach could also be challenging in cases where families did not trust public officials, 

including school staff. For example, one interviewee explained that some parents lacked trust in the 

government and were cautious about providing the information requested on the ED 506 form: “I have 

had parents that say...’What is this form?’ It’s very intimidating to them. It’s a government form. They 

look at it and say, ‘I am not signing anything.’ Because they do not want to divulge...[their] tribal ID 

number...because that’s like your Social Security number.” 

Implementation of the Title VI Indian Education Formula Grants Program 28 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Title VI grant coordinators reported varied experiences in collaborating and coordinating with local 

tribes and tribal organizations to determine student eligibility for services. Although about a quarter of 

coordinators reported that this type of collaboration was somewhat challenging (22 percent) or very 

challenging (6 percent), 72 percent indicated that it was not challenging or minimally challenging. Some 

examples from the case study interviews shed light on how the degree of challenge was associated with 

relationship building. A staff member at one case study site noted that where they had existing 

relationships with tribal administrators, they could probably receive help with the ED 506 forms, but 

establishing new relationships took effort. She commented, “A lot of it is just taking the time to do it. 

That’s really what it is, planning and making it happen.” In contrast, a tribal education department staff 

member at a case study site said that such collaboration and coordination were not at all challenging, 

citing a high level of trust and a positive relationship between the tribe and schools. The staff member 

noted: 

It hasn’t been a challenge because the secretaries and the administrators [at the 

schools] that we work with, they already know what the process is and they are not 

hesitant to give us that information. We just call them up or I’ll email them and say, “I 

need the numbers. I am doing the Title VI application.” Then, either they do it that day or 

the next day, but it’s really easy. I haven’t seen a challenge in trying to get the numbers. 

It’s been very easy to get everything. 

Strategies Used to Confirm the Accuracy and Completeness of ED 506 Forms 

As described, the ED 506 form is required for each student to receive Title VI-funded services (except at 

BIE-funded schools). Two items of information required on the ED 506 form are the name of the 

student’s tribe and proof of tribal membership. 

To confirm the accuracy and completeness of the information collected on the ED 506 

forms, most grantees collected physical copies of eligibility forms and conducted 

annual reviews to update information on eligible students. 

Nearly all grantees (95 percent) collected physical copies of ED 506 forms from families to confirm that 

the forms were accurate and complete. Most grantees conducted an annual review of information 

collected on the ED 506 forms to remove students who had left the district and any duplicate entries 

(85 percent), and the majority reported linking data collected through ED 506 forms to district student 

enrollment systems (66 percent) to verify the data (e.g., to confirm continued enrollment). Fewer Title 

VI grantees reported linking data collected through the ED 506 form to state student enrollment 

systems (27 percent) or collecting electronic copies of the ED 506 form from new American Indian or 

Alaska Native families (17 percent) (Exhibit 22). 

Implementation of the Title VI Indian Education Formula Grants Program 29 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 22. Strategies grantees used to confirm accuracy and completeness of the data collected on 

the ED 506 forms, 2017–18 

 

 

 

 

 

Collect physical copies of completed ED 506 forms 

from new families 

Conduct an annual review of information collected 

through the ED 506 form 

Link data collected through the ED 506 form to 

district enrollment systems 

Link data collected through the ED 506 form to state 

enrollment systems 

Collect electronic copies of ED 506 forms from new 

AI/AN families 17% 

27% 

66% 

85% 

0% 20% 40% 60% 80% 100% 

95% 

Percent of grantees 

Exhibit reads: In 2017–18, 95 percent of grantees collected physical copies of completed ED 506 forms from new 

American Indian and Alaska Native families to promote that the data collected from the forms were accurate and 

complete. 

Note: BIE schools that used the ISEP count in place of the ED 506 form did not respond to this question. 

Source: Survey of Title VI Grant Coordinators, Item 5 (n = 1,039; see Exhibit A-37 in the Technical Appendix). 

In interviews, grantees attributed the low incidence of using online forms to parents and guardians not 

having computer or Internet access, parents and guardians being less familiar and comfortable using 

technology, and less opportunity for in-person contact and relationship-building, which can be 

important for obtaining completed ED 506 forms. One grantee staff member who described entering 

paper ED 506 forms into an online system noted that the community was not ready to adopt a fully 

online system. This respondent explained, “Probably 20 percent of our district has Internet access at 

home and has the tech savvy ability to actually do this, and then it falls apart.... I think we are going to 

be at the paper form stage for a while yet.” 

Grantee staff members at another site described some of the challenges associated with using an online 

registration system and ED 506 forms, which were linked to an initial decline in the number of 

completed 506 forms. A teacher explained, “Most of the time, when you are rural and high poverty, a 

computer scares the devil out of you. Especially if you’re 30 and older.... When they have to register on a 

computer, already it’s intimidating to them.” In response to this challenge, the grant coordinator 

attached a letter to a physical copy of the 506 form that explained the form and addressed some 

frequently asked questions, such as “What if I’m only part Indian?” The grant coordinator at this site also 

explained that before moving to an online system, “When the individuals came into the school and you 

were seeing them face-to-face, you could say, ‘Don’t forget to complete this 506 or don’t forget to check 

here,’” which was not the case when using an online form. Although this grantee experienced challenges 

during the initial transition to an online system, within a year they were able to address some of the 

concerns and began to see the benefits of using an online ED 506 form. 

This grantee refined their approach for communicating with parents about the electronic ED 506 form 

via school websites, newsletters, and Facebook, which helped them reach more parents. This grantee 

also attached the electronic ED 506 form to the electronic version of registration documents, which 

Implementation of the Title VI Indian Education Formula Grants Program 30 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

improved dissemination of the form. The grant coordinator explained how use of the electronic ED 506 

form eventually led to greater benefits including increased identification of eligible students, an 

increased number of collected applications, and improved efficiency collecting and storing this 

information. For example, after improving strategies for disseminating the electronic ED 506 form, this 

grantee identified 300 additional students. With respect to improved efficiencies, parents could more 

easily complete the form without having to travel to the school, which was often difficult for parents 

who did not have the time or access to transportation. In some cases, it was easier for parents to 

complete the online application at a tribal office versus at the school. The grant coordinator explained 

that the electronic ED 506 form and its associated online database also made it easier to compile and 

track information. The computer system could count the number of identified students who were 

eligible for the Title VI program. Further, it could track when children eligible for Title VI services 

changed schools. Parents could also upload the documents used to substantiate tribal membership, so 

that district and school personnel did not have to keep track of paper forms that might get lost. 

Grantees with larger awards were more likely than those with smaller awards to link data through the 

ED 506 forms to district enrollment systems (73 percent vs. 59 percent) and collect electronic ED 506 

forms from new families (23 percent vs. 10) (Exhibit 23). 

Exhibit 23. Title VI grantee strategies to promote accuracy and completeness of the data collected 

through the ED 506 forms, by grant award size, 2017–18 

Larger awards 

(above median) 

Smaller awards 

(below median) 

Percentage 

point difference 

Link data collected through ED 506 form to district 

enrollment system 

73% 59% 14 

Collect electronic copies of ED 506 forms 23 10 13 

Conduct an annual review of information collected 

through the ED 506 form 

88 81 7 

Collect physical copies of completed ED 506 forms 97 93 4 

Exhibit reads: In 2017–18, 73 percent of grantees with larger awards and 59 percent of grantees with smaller 

awards linked data collected through the ED 506 form to the district student enrollment system, a 14 percentage 

point difference. 

Note: All differences between groups are statistically significance at p < .05. BIE schools that used the ISEP count in place of the ED 506 form did 

not respond to this question. 

Source: Survey of Title VI Grant Coordinators, Item 5 (grantees with larger awards n = 541; grantees with smaller awards n = 498; see Exhibit 

A-38 in the Technical Appendix). 

More than two in five grantees reported that helping parents and guardians collect 

and submit acceptable information to confirm their child’s eligibility was somewhat or 

very challenging. 

Grantees had mixed experiences in their efforts to identify eligible children. For example, while fewer 

than half (45 percent) reported that helping parents and guardians collect and submit acceptable 

information (e.g., tribal membership or enrollment number, letter from tribe) to confirm their child’s 

eligibility to receive Title VI-funded services was somewhat or very challenging, more than half 

(55 percent) found that helping parents collect and submit information was minimally challenging or not 

challenging (Exhibit 24). 

Implementation of the Title VI Indian Education Formula Grants Program 31 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 24. Title VI grantees reporting challenges using strategies to promote accuracy and 

completeness of the data collected through the ED 506 forms, 2017–18 

 

 

■ ■ ■ 

Helping parents/guardians collect and submit 

acceptable information to confirm eligibility 

Collecting completed ED 506 forms from 

parents/guardians 

Comparing information on the ED 506 form with 

district records on students’ race/ethnicity 

11% 34% 55% 

11% 31% 57% 

6% 20% 75% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Very challenging Somewhat challenging Minimally/not challenging 

Exhibit reads: In 2017–18, 11 percent of grantees reported that helping parents/guardians collect and submit 

acceptable information to confirm their child’s eligibility to receive grant-funded services was very challenging, 

34 percent reported that this was somewhat challenging, and 55 percent reported that this was minimally 

challenging or not challenging. 

Note: Analyses excluded respondents selecting “Not applicable” or “Don’t know.” Numbers may not add to 100% due to rounding. 

Source: Survey of Title VI Grant Coordinators, Item 6 (n = 1,024; see Exhibit A-40 in the Technical Appendix). 

In interviews, grantee staff members at two sites said that obtaining the information that they 

understood to be required to provide proof of tribal membership (in this case, tribal enrollment card or 

documentation of native blood)8 made it difficult for parents/guardians to acquire documentation to 

confirm their child’s eligibility to receive Title VI-funded services and collect complete ED 506 forms. For 

instance, school counselors at one case study site stated that students often are not able to locate their 

Certificate of Indian Blood and that if parents no longer have it, they do not always see the value in 

putting in the effort to obtain a new one. One counselor at this site said that gathering the 

documentation (for example, a birth certificate) to complete the ED 506 form requires time and money. 

Parents at two case study sites described similar challenges with obtaining completed forms. One parent 

said, “Some people probably got a roll card when they were kids and don’t know what their roll 

numbers are. They don’t know where the card is. It’s a matter of going over there and either getting a 

new card or asking what your roll number is.” 

Grantee staff at one case study site explained that enrolling children who are in foster care can pose 

particular challenges with documentation. These staff said that because children in foster care often 

have no contact with parents, they may not have their Certificate of Indian Blood or tribal enrollment 

information, and foster parents who try to get services to benefit these children may struggle to obtain 

the necessary documentation. 

8 Note that these specific documents are not required under the Title VI statute. Under the Title VI statute, the ED 506 form for 

a child may use alternative evidence of tribal membership. 

Implementation of the Title VI Indian Education Formula Grants Program 32 
 

 

 

 

 

 

 

 

 

 

 

Planning Services 

The Title VI program has required engaging parents and the community in planning grant-funded 

services since its inception in 1972. In the 1994 reauthorization of Elementary and Secondary Education 

Act (ESEA), grant requirements were amended to include “a comprehensive plan to meet the academic 

and culturally related academic needs of American Indian and Alaska Native students.” School district 

grantees must provide assurances that these plans were developed based on a needs assessment and 

approved by an advisory committee. Because at least half (a majority) of the members must be parents, 

these advisory committees are often referred to as “Parent Committees.”9 The Title VI legislation also 

calls for teachers as well as students (if appropriate) to serve on the committees. Under the 2015 

reauthorization of ESEA, the Every Student Succeeds Act (ESSA), grantees are also required to include 

tribal representatives on these advisory committees. 

ESSA further sought to increase collaboration between school districts and local tribes, requiring that 

the district’s comprehensive plans describe “the process the local educational agency used to 

meaningfully collaborate with Indian tribes located in the community in a timely, active, and ongoing 

manner in the development of the comprehensive program and the actions taken as a result of such 

collaboration” (ESEA § 6114(b)(7)) and that all grantees provide assurance that the plan was developed 

in open consultation with representatives of Indian tribes or Indian organizations in addition to other 

stakeholders (ESEA § 6114(c)(3)(C)). 

Assessing Students’ Needs 

Title VI-funded services are to be based on a “comprehensive local assessment and prioritization of the 

unique educational and culturally related academic needs of the Indian students” (ESEA § 6114(c)(3)(A)). 

Both the needs assessment and the planning process involve gathering information and input from 

stakeholders. 

More than two thirds of grantees reported collecting information about students’ 

needs from parent committees, educators, students, and tribes. 

In conducting the needs assessment, grantees most commonly collected information from a Title VI 

Parent Advisory Committee, educators (i.e., schools administrators, teachers), students, school boards 

and/or district administrators, school- or tribe-based parent committees, and tribes and tribal 

organizations (Exhibit 25). 

9 The study survey referred to the required advisory committee as the Title VI Parent Advisory Committee. 

Implementation of the Title VI Indian Education Formula Grants Program 33 
 

 

 

 

 

 

 

 

Exhibit 25. Stakeholder groups from which Title VI grantees collected information, 2017–18 

 

 

Title VI Parent Advisory Committee 

Educators 

Students 

School boards and/or district administrators 

School- or tribal-based parent committees 

Tribes/tribal organizations 

Community-based organizations 

Institutions of higher education 32% 

50% 

68% 

73% 

79% 

85% 

86% 

90% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Exhibit reads: In 2017–18, among grantees that collected information from stakeholder groups, 90 percent 

collected information from the Title VI Parent Advisory Committee. 

Note: Grantees that indicated on Item 9 that they did not consult with any stakeholders to identify American Indian and Alaska Native students’ 

needs did not answer this question. 

Source: Survey of Title VI Grant Coordinators, Item 9 (n = 972; see Exhibit A-43 in the Technical Appendix). 

Grantees with larger awards were more likely than grantees with smaller awards to collect information 

from tribes/tribal organizations (77 percent vs. 57 percent) and institutes of higher education 

(40 percent vs. 25 percent) (see Exhibit A-44 in the Technical Appendix). School district grantees were 

more likely than BIE schools and tribes to collect information from Parent Advisory Committees (94 

percent vs. 62 percent) and tribes/tribal organizations (71 percent vs. 31 percent) (see Exhibit A-45 in 

the Technical Appendix). It is expected that school districts are more likely to collect information from 

Parent Advisory Committees because BIE schools and tribes do not have the same requirement to 

collaborate with the advisory committees. 

Common methods for collecting information from stakeholders were public hearings, 

convenings with stakeholder groups, and surveys. 

In conducting their needs assessments, grantees used a variety of strategies to collect information from 

key stakeholders (Exhibit 26). They tended to rely on face-to-face communication such as public 

hearings (70 percent) and convenings (64 percent), although many also used surveys (62 percent). 

Implementation of the Title VI Indian Education Formula Grants Program 34 
 

 

 

 

 

 

 

 

 

 

 

Exhibit 26. Strategies Title VI grantees used to collect information from stakeholder groups, 

2017–18 

 

 

Public hearings 

Convenings with stakeholder groups 

Surveys 

Interviews/focus groups 

Title VI-sponsored events/activities 

Listservs of other online forums 

Percent of grantees 

10% 

42% 

46% 

62% 

64% 

70% 

0% 20% 40% 60% 80% 100% 

Exhibit reads: In 2017–18, among grantees that collected information from stakeholder groups, 70 percent 

collected information from stakeholder groups through public hearings. 

Note: Grantees that indicated on Item 9 that they did not consult with any stakeholders to identify American Indian and Alaska Native students’ 

needs did not answer this question. 

Source: Survey of Title VI Grant Coordinators, Item 9 (n = 945; see Exhibit A-46 in the Technical Appendix). 

Grantees with larger awards were more likely than grantees with smaller awards to administer surveys, 

hold public hearings, and gather information at Title VI-sponsored events (Exhibit 27). 

Exhibit 27. Strategies Title VI grantees used to collect information from stakeholder groups, by 

grant award size, 2017–18 

Larger awards 

(above median) 

Smaller awards 

(below median) 

Percentage 

point difference 

Surveys 70% 52% 18 

Public hearings 76 62 14 

Title VI-sponsored events or activities 51 32 19 

Exhibit reads: In 2017–18, among grantees that collected information from stakeholder groups, 70 percent of 

grantees with larger awards and 52 percent of grantees with smaller awards collected information from 

stakeholder groups through surveys, an 18 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. Grantees that indicated on Item 9 that they did not consult with any 

stakeholders to identify American Indian and Alaska Native students’ needs did not answer this question. 

Source: Survey of Title VI Grant Coordinators, Item 9 (grantees with larger awards n = 496; grantees with smaller awards n = 449; see Exhibit 

A-47 in the Technical Appendix). 

Implementation of the Title VI Indian Education Formula Grants Program 35 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

School district grantees were more likely than BIE schools and tribes to convene stakeholder groups, 

hold public hearings, and gather information at Title VI-sponsored events (Exhibit 28). 

Exhibit 28. Strategies Title VI grantees used to collect information from stakeholder groups, by 

grantee type, 2017–18 

School 

districts 

BIE schools 

and tribes 

Percentage 

point difference 

Public hearings 73% 41% 32 

Convenings with stakeholder groups 66 51 15 

Title VI-sponsored events or activities 43 30 13 

Exhibit reads: In 2017–18, 73 percent of district grantees and 41 percent of BIE and tribal grantees held public 

hearings, a 32 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. Grantees that indicated on Item 9 that they did not consult with any 

stakeholders to identify American Indian and Alaska Native students’ needs did not answer this question. 

Source: Survey of Title VI Grant Coordinators, Item 9 (school districts n = 852; BIE schools and tribes n = 93; see Exhibit A-48 in the Technical 

Appendix). 

Parent Advisory Committees: Composition and Role 

All school district grantees are required to have a Parent Advisory Committee that is made up of parents 

or family members, who must represent a majority, as well as representatives of Indian tribes, teachers, 

and, if appropriate, secondary school students. 

Most Parent Advisory Committees included parents, teachers, and students, while 

fewer than two in five included tribal representatives; they convened with varying 

frequency, from annually to monthly. 

As required by law, most grantee districts’ Title VI Parent Advisory Committees included multiple 

stakeholders: 98 percent of grantee districts reported that parents were represented, 83 percent 

reported that teachers served on the committee, 74 percent said they had student representation, and 

37 percent included tribal leaders/representatives (Exhibit 29). 

Grantees with larger awards were more likely than grantees with smaller awards to include students and 

tribal representatives on their Parent Advisory Committee (see Exhibit A-50 in the Technical Appendix). 

One case study site with a large award had a specific number of representatives for each group: six 

parents, two teachers, and three students. 

Implementation of the Title VI Indian Education Formula Grants Program 36 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 29. Groups represented on Title VI Parent Advisory Committees, 2017–18 

 

Parents/guardians of AI/AN students 

eligible to receive Title VI-funded services 

Teachers 

Students eligible for Title VI-funded services 

Tribal leaders/representatives 37% 

74% 

83% 

98% 

0% 20% 40% 60% 80% 100% 

Percent of district grantees 

Exhibit reads: In 2017–18, 98 percent of district grantees reported that the parents/guardians of American Indian 

and Alaska Native students eligible for grant-funded services were represented on their Title VI Parent Advisory 

Committee. 

Source: Survey of Title VI Grant Coordinators, Item 20 (n = 1,028; see Exhibit A-49 in the Technical Appendix). 

Overall, 30 percent of grantees reported that their Parent Advisory Committees met annually, 19 

percent met once per semester, 21 percent met quarterly, and 21 percent met monthly (see Exhibit A51 in the Technical Appendix). Case study sites provided examples of grantees that convened and 

collected input from Parent Advisory Committees and of those that did not. For instance, one district 

grantee’s Parent Advisory Committee held regular formal public hearings that community members 

attended to provide suggestions and raise concerns. Other grantees did not have functioning 

committees. One Title VI grant coordinator explained that they struggled to engage parents: 

We have trouble getting parents...coming to anything. [Grantee staff member] performs 

a Herculean task in contacting parents. There’s just not a lot of follow-up. Over the 

years, we’ve had a few individual parents that have been involved and very helpful, but 

as a committee itself, nope. We had a parent meeting a week or two ago, and no one 

showed up. 

Another grantee experienced similar struggles with parent attendance, and staff members noted that 

parents face many obstacles to participation, including long distances between home and school and a 

lack of transportation. Staff from this site noted that parent participation increased when they provided 

meals or other incentives (e.g., raffles for bookstore gift cards). 

Implementation of the Title VI Indian Education Formula Grants Program 37 
 

 

 

 

 

 

 

 

 

Most Parent Advisory Committees reviewed and approved grant applications and set 

project objectives. 

In 2017–18, most Title VI Parent Advisory Committees reviewed and approved grant applications 

(89 percent) and set grant objectives (84 percent); a majority also helped to plan school activities 

(62 percent) and identify partners (55 percent) (Exhibit 30). One case study grantee held an annual 

parent committee meeting to review the grant application. The grant coordinator used an electronic 

whiteboard to examine the application as a group and described the parents as the “driving force” 

behind the application. 

Exhibit 30. Title VI Parent Advisory Committee support for planning, 2017–18 

 

Reviewing and approving application components 

Setting objectives 

Planning school-level non-academic services and 

activities 

Identifying local partners to support services and 

activities 

89% 

84% 

62% 

55% 

0% 20% 40% 60% 80% 100% 

Percent of district grantees 

Exhibit reads: In 2017–18, 85 percent of grantees reported that their Title VI Parent Advisory Committee reviewed 

and approved components of the Title VI grant application. 

Source: Survey of Title VI Grant Coordinators, Item 22 (n = 1,146; see Exhibit A-53 in the Technical Appendix). 

Using Data and Stakeholder Input 

Title VI grantees are required to plan services and activities based on information gathered through the 

needs assessment and in open consultation with stakeholders through public hearings. 

Most grantees reported using multiple data sources for project planning, including 

administrative data and information from parents, teachers, and administrators and 

from public hearings. 

In planning grant-funded services, most grantees used the information gathered through their needs 

assessments, including administrative data such as course grades, test scores, and attendance data 

(94 percent) and ideas and recommendations from parents (86 percent), from teachers and 

administrators (82 percent), and from public hearings (73 percent) (Exhibit 31). 

Implementation of the Title VI Indian Education Formula Grants Program 38 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 31. Data sources Title VI grantees used to plan services, 2017–18 

 

 

 

 

 

 

 

Administrative data 

Information from parents about students’ needs 

Information from school teachers and 

administrators about students’ needs 

Information from public hearings 

Information about services and activities 

delivered by other organizations 

School and district equity audit data 

Published reports on issues related to AI/AN 

education 25% 

49% 

52% 

73% 

82% 

86% 

94% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Exhibit reads: In 2017–18, 94 percent of grantees used school district-collected administrative data (e.g., course 

grades, test scores, attendance rate, behavior data, graduation and/or dropout data, and college acceptance data) 

to plan grant-funded services and activities. 

Source: Survey of Title VI Grant Coordinators, Item 12 (n = 1,155; see Exhibit A-55 in the Technical Appendix). 

Case study sites included grantees that relied on multiple sources of data and grantees that depended 

more narrowly on one or two data sources. For instance, the coordinator of a large Title VI-funded 

project explained that they drew on multiple sources—advisory group, focus groups, parents, teachers, 

extant data—to inform planning. The services this site offered were designed to address the diverse 

academic and cultural needs surfaced through this information gathering. The superintendent at 

another site described relying on test scores to determine supports: 

Our area of greatest need is in the elementary and particularly with the literacy.... So, 

we’ve really focused and targeted those literacy skills. This was guided by reviewing the 

data...all the data we have that comes from our state-mandated testing. 

Another superintendent described efforts to gather input from parents and the influence of parent 

perspectives on the planning process: 

The parents are the ones who know what their kids need. When I first came into the 

district, I did a summer trip and visited each site and met with the folks at each village.... 

Those people there, they knew exactly what they wanted for their kids, so my role is to 

facilitate that. 

A teacher spoke of the importance of being responsive to multiple stakeholder groups and trying to find 

some balance between academics and culture: 

Implementation of the Title VI Indian Education Formula Grants Program 39 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The cultural aspect is what’s important to the tribe. If you talk to teachers, they are 

going to tell you the academic part is...what’s important to the school. If you talk to 

district personnel, they are going to tell you reading and math—academics—is going to 

be the most important. You’ve got to find the balance and finding that balance. Being 

the person who is teaching it, can sometimes be a little overwhelming. 

Grantees varied by both award size and grantee type in the data sources they used to plan Title VIfunded services. School districts were more likely than BIE schools and tribes to gather information from 

public hearings (76 percent vs. 47 percent) and from other organizations that serve American Indian and 

Alaska Native students (54 percent vs. 38 percent) (see Exhibit A-56 in the Technical Appendix). And 

grantees with larger awards were somewhat more likely than grantees with smaller awards to use data 

collected from other organizations that serve American Indian and Alaska Native students (59 percent 

vs. 45 percent), from public hearings (77 percent vs. 68 percent), and from parents (89 percent vs. 83 

percent) (Exhibit 32). 

Exhibit 32. Data sources Title VI grantees used to plan services, by grant award size, 2017–18 

Larger awards 

(above median) 

Smaller awards 

(below median) 

Percentage 

point difference 

Information about services and activities delivered by 

other organizations that serve American Indian and 

Alaska Native students 

59% 45% 14 

Public hearings 77 68 9 

Information from parents about students’ culturally 

relevant academic needs 

89 83 6 

Exhibit reads: In 2017–18, 59 percent of grantees with larger awards and 45 percent of grantees with smaller 

awards used information about services and activities delivered by other organizations that serve American Indian 

and Alaska Native students to plan services, a 14 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. 

Source: Survey of Title VI Grant Coordinators, Item 12 (grantees with larger awards n = 596; grantees with smaller awards n = 559; see Exhibit 

A-57 in the Technical Appendix). 

About a fourth to a third of grantees found it somewhat or very challenging to 

coordinate planned services with other organizations and obtain input from 

stakeholders in the planning process. 

Grantees had different experiences planning Title VI-funded services. Approximately a third of grantees 

reported that some efforts, such as coordinating planned services with other organizations (e.g., 

coordinating mental health services with local health organization) and obtaining input from tribes, the 

Parent Advisory Committee, and other stakeholders, were either somewhat or very challenging, while 

the remaining two thirds found the same efforts minimally challenging or not challenging (Exhibit 33). 

Nearly a third (29 percent) reported that identifying appropriate curriculum or resources was either 

somewhat or very challenging. Fewer grantees (15 percent) reported that complying with grant 

requirements was either somewhat or very challenging. 

Implementation of the Title VI Indian Education Formula Grants Program 40 
 

 

 

 

 

 

 

 

 

 

 

Exhibit 33. Grantees reporting challenges to efforts to plan Title VI-funded services and activities, 

2017–18 

 

 

■ ■ ■ 

Coordinating planned services with other organizations 

Obtaining input from tribes/tribal organizations 

Obtaining input from the Title VI Parent Advisory 

Committee 

Obtaining input from other stakeholders 

Identifying appropriate curricula/resources 

Coordinating Title VI-funding with other funding sources 

Using data to identify students’ needs 

Complying with grant requirements 

Accessing data to identify students’ needs 

7% 

10% 

11% 

11% 

12% 

12% 

16% 

19% 

25% 

27% 

19% 

23% 

28% 

86% 

86% 

81% 

77% 

71% 

66% 

71% 

66% 

61% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Very challenging Somewhat challenging Minimally/not challenging 

Exhibit reads: In 2017–18, 11 percent of grantees reported that it was very challenging to coordinate planned 

services with other organizations. 

Note: Analyses excluded respondents selecting “Not applicable” or “Don’t know.” Numbers may not add to 100% due to rounding. 

Source: Survey of Title VI Grant Coordinators, Item 13 (n = 1,116; see Exhibit A-58 in the Technical Appendix). 

Chapter Summary 

Title VI grantees reported relying on a common set of strategies to identify program-eligible students. 

They asked families directly about their affiliation with American Indian and Alaska Native tribes, and 

they included ED 506 forms in school enrollment packets. Most grantees also relied on student 

information systems to locate students who had self-identified as American Indian and Alaska Native is 

response to questions about race and ethnicity. Just over half of grantees conducted targeted outreach 

to notify American Indian and Alaska Native families about available Title VI-funded services for eligible 

children. To verify the accuracy of student counts, most grantees conducted an annual review of 

information collected on the ED 506 forms. 

To assess student needs, most Title VI grantees reported collected information from stakeholder groups. 

The grantees tended to rely on face-to-face communication such as public hearings and convenings, 

although many also used surveys. Ultimately, multiple data sources informed Title VI project planning. 

Most grantees reported relying on administrative data such as course grades, test scores, and 

attendance data; information gathered from parents, teachers, and administrators; and information 

gathered via public hearings. 

Implementation of the Title VI Indian Education Formula Grants Program 41 
 

 

 

 

 

 

 

 

 

Chapter 4. Measuring Progress Toward Title VI 

Project Objectives 

Each Title VI grantee includes in its application specific goals or “objectives” and a description of how 

the project will offer services and activities to meet those objectives. The grantees are required to assess 

progress toward their project objectives and then report the results to their Parent Advisory Committee, 

the broader community that a local school district serves, and the tribes whose children are served by 

the school district (ESEA § 6114(b)(6)). Additionally, grantees submit an Annual Performance Report 

(APR) to the Office of Indian Education to report on their progress towards these objectives. 

This chapter describes the types of objectives that grantees established for their projects and the data 

sources they used to assess progress toward achieving those objectives. Example of project objectives 

include increasing American Indian and Alaska Native students' academic achievement, knowledge of 

cultural identity and awareness, and school attendance. 

Project Objectives 

All Title VI grantees are required to conduct a community needs assessment to help them identify 

project objectives that support their school programs. 

The most common objectives of Title VI-funded projects were to increase Native 

American and Alaska Native students’ academic achievement (81 percent), knowledge 

of cultural identity and awareness (60 percent), and school attendance (44 percent). 

Slightly more than one third of grantees reported that their project’s objectives included increasing 

graduation rates (38 percent) and supporting parent engagement in schools (35 percent). Less 

commonly reported objectives were related to college enrollment and career readiness, increasing 

native language instruction programs, and increasing substance abuse prevention for American Indian 

and Alaska Native students (Exhibit 34). 

Implementation of the Title VI Indian Education Formula Grants Program 42 
 

 

 

 

 

 

 

 

 

 

 

Exhibit 34. Objectives of Title VI-funded projects, 2017–18 

 

 

Increase AI/AN students' academic achievement 

Decrease achievement gaps between AI/AN students and 

other racial/ethnic groups 

Enhance AI/AN students' problem solving and cognitive skills 

Increase AI/AN students' knowledge of cultural identity and 

awareness 

Increase Native American Language instruction programs 

Increase school attendance rate for AI/AN students 

Increase AI/AN students' school readiness 

Increase parent engagement in AI/AN students' schools 

Increase graduation rate for AI/AN students 

Increase college enrollment for AI/AN students 

Increase career readiness skills for AI/AN students 

Decrease school dropout rate for AI/AN students 

Increase substance abuse prevention for AI/AN students 10% 

27% 

25% 

26% 

38% 

35% 

35% 

44% 

20% 

60% 

25% 

27% 

81% Academic 

achievement/ 

skill 

development 

Language and 

culture 

School 

readiness and 

engagement 

College and 

career 

Prevention 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Exhibit reads: In their 2017–18 grant application, 81 percent of grantees included increasing American Indian and 

Alaska Native students’ academic achievement among their project objectives. 

Source: Survey of Title VI Grant Coordinators, Item 10 (n = 1,161; see Exhibit A-62 in the Technical Appendix). 

School district grantees were more likely than BIE schools and tribes to include 

increasing graduation rates, college enrollment, and academic achievement among 

their project objectives. BIE schools and tribes were more likely to include increasing 

Native American language instruction programs and increasing knowledge of cultural 

identity and awareness as project objectives. 

District grantees were substantially more likely than BIE and tribal grantees to report that their project 

objectives included increasing graduation rates (40 percent vs. 24 percent) and decreasing school 

dropout rates (29 percent vs. 16 percent). In addition, a small but statistically significantly higher 

proportion of district grantees reported that their project objectives included increasing college 

enrollment, decreasing achievement gaps between American Indian and Alaska Native students and 

students from other racial and ethnic groups, and increasing academic achievement (Exhibit 35). In 

contrast, BIE schools and tribes were more likely than districts to report that their project objectives 

included increasing Native American language instruction programs (42 percent vs. 18 percent) and 

students’ cultural identity and awareness (73 percent vs. 59 percent). 

Implementation of the Title VI Indian Education Formula Grants Program 43 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 35. Objectives of Title VI-funded projects for American Indian and Alaska Native students, 

by grantee type, 2017–18 

School 

districts 

BIE schools 

and tribes 

Percentage 

point difference 

More commonly used by BIE schools and tribal grantees 

Increase Native American language instruction 

programs 

18% 42% 24 

Increase AI/AN students’ knowledge and awareness of 

cultural identity 

59 73 14 

More commonly used by district grantees 

Increase graduation rate 40 24 16 

Decrease school dropout rate 29 16 13 

Increase college enrollment 27 14 13 

Decrease achievement gaps between AI/AN students 

and other racial/ethnic groups 

28 15 13 

Increase academic achievement 83 71 12 

Exhibit reads: In 2017–18, 18 percent of district grantees and 42 percent of BIE and tribal grantees included 

increasing Native American language instruction programs among their project objectives, a 24 percentage point 

difference. 

Note: All differences between groups are statistically significant at p < .05. 

Source: Survey of Title VI Grant Coordinators, Item 10 (school districts n = 1,036; BIE schools and tribes n = 125; see Exhibit A-62 in the Technical 

Appendix). 

Grantees with larger Title VI grant awards were more likely than those with smaller 

awards to include as project objectives increasing graduation rates, decreasing 

dropout rates, and increasing native language instruction programs. 

A smaller but statistically significant percentage of Title VI grantees’ project objectives included 

increasing students’ knowledge and awareness of their cultural identity and increasing college 

enrollment (Exhibit 36). 

Exhibit 36. Objectives of Title VI-funded projects, by grant award size, 2017–18 

Larger awards 

(above median) 

Smaller awards 

(below median) 

Percentage 

point difference 

Increase graduation rate 46% 30% 16 

Decrease school dropout rate 33 21 12 

Increase Native American language instruction programs 24 16 8 

Exhibit reads: In 2017–18, 46 percent of grantees with larger awards and 30 percent of grantees with smaller 

awards included increasing the graduation rate of American Indian and Alaska Native students among their project 

objectives, a 16 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. 

Source: Survey of Title VI Grant Coordinators, Item 10 (grantees with larger awards n = 600; grantees with smaller awards n = 561; see Exhibit 

A-63 in the Technical Appendix). 

Implementation of the Title VI Indian Education Formula Grants Program 44 
 

 

 

 

 

 

 

 

 

 

Measuring Progress 

In addition to identifying objectives, all grant applicants are required in their applications to identify the 

data sources they will use to measure progress toward meeting their project objectives. 

Most grantees used state standardized assessment scores (83 percent), attendance 

data (80 percent), and graduation/dropout data (66 percent) to measure progress 

toward Title VI project objectives. 

Less commonly used data sources for measuring progress toward Title VI project objectives included 

survey or focus group data collected from parents, guardians, or families (46 percent), from students 

themselves (43 percent), or from school staff (39 percent) (Exhibit 37). 

Exhibit 37. Data sources grantees used to measure progress toward Title VI project objectives, 

2017–18 

State standardized assessments 

Attendance data 

Graduation/dropout data 

Local standardized assessments 

Survey or focus group data collected from parents, 

guardians, or families 

Survey or focus group data collected from students 

School staff surveys or focus group data 

College acceptance data 

Performance portfolios, including examples of student work 

and other artifacts 

Other culturally relevant measures 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

9% 

25% 

26% 

39% 

43% 

46% 

55% 

66% 

80% 

83% 

Exhibit reads: In 2017–18, 83 percent of grantees used state standardized assessments to measure progress 

toward project objectives. 

Source: Survey of Title VI Grant Coordinators, Item 26 (n = 1,146; see Exhibit A-64 in the Technical Appendix). 

School districts were more likely than BIE schools and tribes to use assessment scores, 

graduation rates, and college acceptance data to measure progress; BIE and tribal 

grantees were more likely to use other culturally relevant measures. 

District grantees were more likely than BIE schools and tribal grantees to use graduation and dropout 

rates (69 percent vs. 41 percent), state standardized assessments (85 percent vs. 67 percent), and 

college acceptance data (27 percent vs. 15 percent) to measure progress toward their Title VI project 

Implementation of the Title VI Indian Education Formula Grants Program 45 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

objectives. In contrast, BIE and tribal grantees were more likely than district grantees to use other 

culturally relevant measures to measure progress toward their project objectives, such as native 

language assessment data or data on mastery of cultural skills or completion of cultural projects 

(Exhibit 38). 

Exhibit 38. Data sources used to measure progress toward Title VI project objectives, by grantee 

type, 2017–18 

School 

districts 

BIE schools 

and tribes 

Percentage 

point difference 

More commonly used by district grantees 

Graduation/dropout data 69% 41% 28 

State standardized assessments 85 67 18 

College acceptance data 27 15 12 

More commonly used by BIE schools and tribal grantees 

Other culturally relevant measures 8 21 13 

Exhibit reads: In 2017–18, 69 percent of district grantees and 41 percent of BIE and tribal grantees used 

graduation/dropout data to measure progress toward project objectives, a 28 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. 

Source: Survey of Title VI Grant Coordinators, Item 26 (school districts n = 1,028; BIE schools and tribes n = 118; see Exhibit A-65 in the Technical 

Appendix). 

Grantees with larger Title VI awards were more likely than grantees with smaller 

awards to use each of five sources of data to measure their progress toward project 

objectives. 

Grantees with larger awards were more likely than those with smaller awards to measure progress 

toward their Title VI project objectives using graduation and dropout data; family, student, and staff 

surveys or focus groups; and other culturally relevant measures (Exhibit 39). 

Exhibit 39. Data sources used to measure progress toward Title VI project objectives, by grant 

award size, 2017–18 

Larger awards 

(above median) 

Smaller awards 

(below median) 

Percentage 

point difference 

Graduation/dropout data 74% 58% 16 

Family surveys or focus groups 53 38 15 

Student surveys or focus groups 49 36 13 

Staff surveys or focus groups 44 34 10 

Other culturally relevant measures 13 5 8 

Exhibit reads: In 2017–18, 74 percent of Title VI grantees with larger awards and 58 percent with smaller awards 

used graduation/dropout data to measure progress toward project objectives, a 16 percentage point difference. 

Note: All differences between groups are statistically significant at p < .05. 

Source: Survey of Title VI Grant Coordinators, Item 26 (grantees with larger awards n = 592; grantees with smaller awards n = 554; see Exhibit 

A-66 in the Technical Appendix). 

Implementation of the Title VI Indian Education Formula Grants Program 46 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In interviews, Title VI grant coordinators and other staff members described the types of data they used 

to measure progress on their project objectives. For example, one grant coordinator explained that 

measuring progress requires relying on more than the standard measures of Title VI project progress 

(i.e., as reported in EDFacts) and considering state data with student experiences to paint an 

appropriately nuanced picture of their work: 

Because now we’re recognizing the unique aspects [of the work] we’re doing, but then 

how do we assess [the students] locally and validate that learning and the impact that 

we’re having, that is not going to be seen on what is populated by EDFacts. And so, a lot 

of it has been through just personal narratives, stories, surveys that we do with the kids. 

And then at times we will have the parent focus groups, too.... But...it’s been more 

informal and how we move forward to just kind of gauge what’s effective, what should 

we do again this year or not, and it’s just us coming together as a team, evaluating. 

Additional interviewees described using other measures to gauge progress on their project objectives. 

One Title VI grant coordinator described looking at student engagement as a progress indicator: “One of 

the things that I do notice [is] that a lot of our native kids, they love the afterschool program. We have 

really good attendance in that.” A counselor in another case study site described tracking American 

Indian and Alaska Native students’ test scores and participation data: 

I’m the test coordinator, so we give the [District Assessment], and I personally have 

tracked...those [Title VI grant] students that [the Title VI grant intervention teacher] 

works with, and I have seen from the beginning of the year the growth that they were 

able to make with [the Title VI grant intervention teacher] being on the campus and 

being able to work hand in hand with that teacher, not just the students, but [the Title VI 

grant intervention teacher] goes into the teacher’s classroom and sees what they need 

and then brings them in. 

Most grantees did not report significant challenges collecting or using data to measure 

progress toward Title VI project objectives. 

Most grantees reported that collecting and using most types of data to measure progress toward project 

objectives was either minimally challenging or not challenging (Exhibit 40). Still, 20 percent of grantees 

reported that collecting data from parents of American Indian and Alaska Native students was very 

challenging, and another 35 percent found it somewhat challenging. The next most common challenges 

were related to collecting data from tribes or tribal organizations (47 percent reported that this was 

somewhat or very challenging) and linking multiple student-level databases (e.g., state assessment data 

or college enrollment information) (41 percent). The least challenging data collection or data use 

strategy was accessing student-level data for eligible students (15 percent). 

Implementation of the Title VI Indian Education Formula Grants Program 47 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit 40. Title VI grantees reporting challenges to implementing data collection or data use 

strategies in 2017–18 

 

 

 

■ ■ ■ 

Linking multiple student-level databases (state 

assessment data, college enrollment information) 

Analyzing data to make decisions about project 

services and activities 

Identifying appropriate data sources 

Accessing student-level data (state assessment 

data, collect enrollment information) 

13% 28% 59% 

6% 20% 74% 

5% 19% 76% 

13% 85% 

0% 20% 40% 60% 80% 100% 

Percent of grantees 

Very challenging Somewhat challenging Minimally/not challenging 

Exhibit reads: In 2017–18, 20 percent of Title VI grantees reported that collecting data from parents of Title VIeligible students was very challenging, 35 percent reported it was somewhat challenging, and 45 percent reported 

it was minimally challenging or not challenging. 

† Only school districts responded to this item. 

Note: Analyses excluded respondents selecting “Not applicable” or “Don’t know.” Numbers may not add to 100% due to rounding. 

Source: Survey of Title VI Grant Coordinators, Item 27 (n = 1,080; see Exhibit A-67 in the Technical Appendix). 

Interviewees described some of the challenges associated with measuring progress toward 

nonacademic project objectives. For example, a teacher in a case study site noted that many of the Title 

VI grant students had experienced trauma and wondered how to measure progress on that: 

Trauma in kids’ lives, it’s so prevalent. Oftentimes, I don’t know how you measure 

[progress with] that...you know it takes years. I mean it takes a year for me to go 

through and specifically have certain kids in mind and say here’s my goal with this 

student, and it has nothing to do with academics. It has everything to do with bringing 

them to a place where they trust or are closer to trusting others. 

A Title VI-funded teacher described the challenges associated with measuring the cultural learning 

objectives of the program: “I think probably there is really no real way to measure the cultural aspect of 

it, except that kids come to school more often.” 

Chapter Summary 

All grantees are required to define their project objectives and assess progress toward achieving them. 

Among the most common objectives Title VI grantees reported were increasing Native American and 

Alaska Native students’ academic achievement, knowledge of cultural identity and awareness, and 

school attendance. The data sources that most Title VI grantees reported using to measure progress 

toward meeting their project objectives included state standardized test scores, attendance data, and 

graduation/dropout data. 

Implementation of the Title VI Indian Education Formula Grants Program 48 
 

 

 

 

References 

Castagno, Angelina, and Bryan Brayboy. 2008. “Culturally Responsive Schooling for Indigenous Youth: A 

Review of the Literature.” Review of Educational Research 78 (4): 941–93. 

DeVoe, Jill F., and Darling-Churchill, Kristen E. (2008). Status and Trends in the Education of American 

Indians and Alaska Natives: 2008 (NCES 2008-084). National Center for Education Statistics, Institute 

of Education Sciences, U.S. Department of Education. Washington, DC. 

https://nces.ed.gov/pubs2008/2008084_1.pdf 

Lomawaima, K. Tsianina, and Teresa McCarty. 2006. To Remain an Indian: Lessons in Democracy from a 

Century of Native American Education. New York: Teachers College Press. 

U.S. Department of Education, Office of Indian Education (2019). Indian Education Formula Grant 

Program, Formula Grant Electronic Application System for Indian Education, Frequently Asked 

Questions (FAQs) Part I. https://eden.ed.gov/Survey/Docs/IEFG_FAQ.pdf 

Implementation of the Title VI Indian Education Formula Grants Program 49