Tribal Transportation: Better Data Could Improve Road Management and Inform Indian Student Attendance Strategies
Published: 2017-05-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Roads on tribal lands are of particular importance for connecting people to essential services, such as schools, because of the remote location of some tribes. These roads are often unpaved and may not be well maintained. The federal government funds two programs to improve and maintain roads on tribal lands. BIA maintains the NTTFI and DMR databases to support these programs.
GAO was asked to review condition and school-access issues related to roads on tribal lands. This report examines: (1) the extent to which the NTTFI and DMR systems provide useful data on these roads; (2) any challenges to improving and maintaining these roads; and (3) what is known about the connection between road condition and school attendance as well as other aspects of school transportation. GAO reviewed documents and relevant literature; analyzed road-inventory and student- attendance data; and interviewed federal, state, local, and tribal transportation and education officials. GAO visited three selected tribes, based on road mileage and presence of BIE schools, among other factors.
section_title: What GAO Found
paragraphs: The two databases maintained by the Department of the Interior's (Interior) Bureau of Indian Affairs (BIA) include some data fields useful for identifying tribal roads eligible for federal funding, but other fields may be too inaccurate to be useful for performance reporting and oversight. Specifically, the National Tribal Transportation Facility Inventory (NTTFI) provides useful data for identifying the roughly 161,000 miles of roads on tribal lands that are eligible for federal funding. However, the purpose for which these data are used has changed, and GAO found incomplete and inconsistent road-description and condition data, raising questions about the continued value of collecting these data. Similarly, BIA's Deferred Maintenance Reporting (DMR) system provides useful data on roughly 29,000 miles of BIA-owned roads eligible for federal funding, but GAO found inaccuracies in fields related to road-condition and road-maintenance needs. BIA does not document its road-maintenance cost estimates, and some tribes under-report performed maintenance. As a result, budget justification and performance reporting using these fields may not accurately reflect maintenance costs and needs. Federal standards for internal control suggest agencies design information systems and use quality information to achieve objectives.
Funding constraints, overlapping jurisdictions, and adverse weather make improving and maintaining roads on tribal lands challenging. However, intergovernmental partnerships have helped mitigate challenges in some cases. For example, in 2013, federal, state, and tribal agencies partnered on a $35- million project to pave a BIA earth road on the Navajo Nation when the main U.S. highway was closed due to a landslide. By partnering, the agencies completed the project in about 3 months and prior to the start of the school year, eliminating a 45-mile detour.
GAO's literature review and interviews with education officials indicate that road conditions can be a barrier to attendance, and Department of Education data show that Indian students have a higher chronic absence rate than other students (see fig.). At Interior, the Bureau of Indian Education's (BIE) schools generally do not collect data on transportation-related causes for absences, despite broader federal guidance that recommends doing so. BIE's attendance system lists causes, but transportation-related causes are currently not among them. Thus, BIE cannot quantify the effect of road conditions and target appropriate interventions. Rough road conditions in some areas also contribute to greater wear on school vehicles and associated higher maintenance costs.
School Bus on the Navajo Nation (Utah) and the National Rate of Students Chronically Absent, School Year 2013–14
section_title: What GAO Recommends
paragraphs: GAO is making eight recommendations including that BIA, in coordination with stakeholders, reexamine the need for NTTFI data and improve the quality of DMR data, and that BIE provide guidance to collect transportation-related absence data. Interior agreed with five of the recommendations, did not take a position on two, and disagreed with one. GAO continues to believe its recommendations are valid, as discussed further in this report.

section_title: Letter
paragraphs: Roads are a vital link connecting people to education, employment, health  care, and other essential services, and are of particular importance on  tribal lands because of the remote location of some tribes.  However,  roads on tribal lands are often unpaved and may not be well maintained.  These factors can create transportation challenges for tribal communities.  Several tribes and tribal associations have raised concerns about the  inability of Indian students on tribal lands to get to school on roads that  are in poor condition.
The federal government provides funding for road improvement and  maintenance to tribes through two key programs: the Tribal  Transportation Program (TTP) and the Road Maintenance Program  (RMP).  The TTP is jointly administered by the Department of the  Interior’s (Interior) Bureau of Indian Affairs (BIA) and the Department of  Transportation’s (DOT) Federal Highway Administration (FHWA). The  TTP provides funds to over 560 federally recognized tribes for the  planning, design, construction, and maintenance of transportation  facilities—such as roads, bridges, bus shelters, and parking lots— identified in the National Tribal Transportation Facility Inventory (NTTFI).  The NTTFI is a database maintained by BIA. While BIA is responsible for  ensuring the accuracy of data in the system, data are entered and owned  by individual tribes. NTTFI data includes transportation facilities eligible for assistance under the TTP. In fiscal year 2016, the TTP received an  authorization of $465 million in federal funding from the Fixing America’s  Surface Transportation Act, with the authorized amount increasing by  $10-million per year until the funding level reaches $505 million in fiscal  year 2020.  The RMP is administered by BIA and funds the maintenance  of only BIA roads on tribal lands. BIA has received about $25 million  annually in RMP funding since the 1990s, according to agency officials.  BIA uses a Deferred Maintenance Reporting (DMR) system to track,  among other things, the amount of maintenance conducted and deferred  on the BIA road system. You asked us to review issues concerning road  conditions on tribal lands and how these conditions relate to students’  school attendance. This report examines:  1.  the extent to which the NTTFI and the DMR system provide useful  data about road conditions on tribal lands;  2.  any challenges stakeholders face in improving and maintaining roads  on tribal lands; and  3.  what is known about the connection between road conditions on tribal  lands and school attendance as well as other aspects of school  transportation.
To determine the extent to which the NTTFI and DMR systems provide  useful data on road conditions on tribal lands, we reviewed agency  guidance, policies, and system documentation; conducted electronic data  testing, such as for completeness, out-of-range values, and logical  inconsistencies; attended a training workshop on NTTFI data entry; and  interviewed FHWA, BIA, and tribal officials about each system. We  compared information about each data system’s design, monitoring, edit  checks, and other processes for promoting data accuracy, consistency,  and completeness to federal standards for internal control. We analyzed  the NTTFI data as of September 2015—the most recent data available at  the time of our review—and the quarterly DMR system inventory and  road-condition data for fiscal years 2009 through 2015—the most recent  full year of data available matching the NTTFI file year. Based on the  steps we took, we determined that these data were sufficiently reliable for  some purposes, but not others, as described later in the report.
To identify any challenges stakeholders face in improving and maintaining  roads on tribal lands, we reviewed (1) relevant federal laws, regulations,  guidance, and funding processes for the TTP and RMP; (2) program  documentation such as FHWA budget justifications and BIA’s RMP  funding information for fiscal years 2009 through 2016; and (3)  documents related to conducting road improvement and maintenance,  such as selected tribes’ program agreements and lists of tribal  transportation projects. We conducted three site visits to 10 selected  schools and 7 transportation offices within the Navajo, Pine Ridge, and  Rosebud Indian reservations. While all 567 federally recognized tribes  were considered for site visit selection, these three sites were chosen  because they reflect factors such as different BIA regions; considerable  tribal and BIA road mileage; presence of Bureau of Indian Education  (BIE) schools; and different program agreements. During our site visits, in  addition to meeting with school, tribal, and transportation officials, we  observed road conditions first-hand, including riding on school busses  along their delivery routes. As part of one site visit, we conducted a  facilitated group discussion with 10 tribes from the BIA Great Plains and  Rocky Mountain Regions. Our site visits provide information and  illustrative examples on a range of road condition and student attendance  issues on tribal lands but are not generalizable to all tribal nations. We  obtained geospatial data from the Navajo Nation on road ownership, road  surface type, and road maintenance partnerships for two school districts  within the Nation. We also attended four tribal transportation-related  conferences and interviewed various officials and stakeholders, including  FHWA and BIA headquarters and regional officials about their  coordination with tribes. During the course of our review, we met with  various federal, state, local, and tribal transportation and education  officials including tribal technical assistance experts and representatives  from national associations.
To determine what is known about the connection between road  conditions on tribal lands and school attendance and other aspects of  school transportation, we took several steps. To describe attendance  including for Indian students in general, we analyzed national data from  two data sets collected by the Department of Education (Education). We  assessed the reliability of attendance data by reviewing related  documentation and interviewing knowledgeable agency officials, among  other steps, and determined that these data were sufficiently reliable for  our purposes. To identify studies concerning the connection between  road conditions and school attendance, we searched for academic  studies published since 2000, and we reviewed a list of studies compiled  by Education’s National Library of Education. We used a data collection  instrument to consistently record information about key findings related to  the connection between road condition and attendance from each  relevant source. As part of our site visits to the three tribes noted above,  we selected 10 schools and districts to visit that had similar student  demographics (e.g., mostly Indian and mostly low-income) and school  bus routes of varying road surface types. For these schools and districts,  we analyzed available documentation and information on student  attendance and school bus routes; directly observed bus routes; and  interviewed school and district officials on the effects of road conditions  on attendance as well as other school transportation issues. We also  interviewed officials from Education, Interior’s Bureau of Indian Education  (BIE), and other national-level stakeholders from tribal organizations. We  compared information on BIE’s efforts in this area with guidance from an  education forum and federal standards for internal control. Additional  details on our scope and methodology, including a list of tribal and other  entities from whom we obtained information for this review are contained  in appendix I.
We conducted this performance audit from December 2015 to May 2017  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on the audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: Tribal Transportation Program
paragraphs: BIA and FHWA (through its Office of Federal Lands Highway) jointly  administer the TTP, to address transportation needs of tribes. The TTP is  funded through the highway account of the Highway Trust Fund and is  designed to address eligible transportation-related activities on tribal  lands.   Activities eligible for program funding include planning, design,  construction, and maintenance of roads listed in the NTTFI.  Program  funding is distributed to tribes by formula after “set-asides”—funding  amounts that the Secretary of Transportation may or must deduct from  the funding for various purposes—are determined.  Program funds can  also be used for the state and local matching share of apportioned  federal-aid highway funds. Tribes may select from various federal  contracts and agreements to implement their transportation programs.   BIA maintains the NTTFI data system, which includes transportation  facilities—existing and proposed—on Indian reservations and within tribal  communities and all public roads on tribal lands.
section_title: Road Maintenance Program
paragraphs: The purpose of the BIA RMP is to preserve, repair, and restore the BIA  system of bridges and roadways and to ensure that TTP-eligible highway  structures are maintained.  The RMP is designed to address the  maintenance needs of roads owned by the BIA. RMP activities include  routine and emergency road maintenance, bridge maintenance, and snow  and ice removal, among other things. Road maintenance does not include  new construction, improvement, or reconstruction.  BIA has 12 regions,  two of which do not have any BIA roads—the Alaska and Eastern  Oklahoma BIA Regions. The BIA Division of Transportation operates and  maintains the BIA road system through the remaining 10 regional  offices.  BIA roads—which are also in the NTTFI—are open to the public and are often major access corridors for tribal communities and the  public. The road system consists of more than 930 BIA-owned bridges,  one ferry system, and approximately 29,000 miles of proposed and  existing roads. About 75 percent of the existing roads are not paved. Five  of the 10 BIA regions that have BIA roads—the Western, Navajo,  Southwestern, Northwestern, and Rocky Mountain BIA Regions—have  about 80 percent of the total BIA road miles.
section_title: Indian School Attendance
paragraphs: About 550,000 Indian students are enrolled in public elementary and  secondary (kindergarten to grade 12) schools in the United States, not  counting BIE schools. In addition, BIE funds 185 schools serving about  41,000 students living on or near tribal lands.  (See fig. 1.) BIE operates  about one-third of its schools directly and tribes operate the other two- thirds mostly through federal grants. Unlike public schools, BIE schools  receive nearly all of their funding from the federal government, including  about $50 million annually to transport students. We recently placed  federal programs serving tribes, including BIE’s administration of  education programs, on our High-Risk Series.
On tribal lands, Indian elementary and secondary students generally  attend either public or BIE schools.  The majority of Indian students on  tribal lands are enrolled in public school districts. In some cases, students  may have a choice to attend either public or BIE schools, and they do not  necessarily enroll in the school closest to their home.  On certain tribal  lands, there may only be one school.
section_title: Inaccuracies Limit the Usefulness of Some BIA Data on the Condition of Roads on Tribal Lands
paragraphs: Data fields pertaining to road inventory in BIA’s NTTFI and DMR  databases are useful for the purpose of identifying roads eligible for  federal tribal funding. However, we found that data fields pertaining to the  description and condition of roads in the NTTFI are not complete,  accurate, or consistently collected.  As a result, road-description and  condition data may lack the accuracy needed for reporting and agency  oversight efforts, calling into question the usefulness of maintaining these  NTTFI data fields.  Similarly, we found that the DMR system, which BIA  uses to report information on maintenance of BIA-owned roads, contains  data that are not accurate.  These data issues compromise FHWA’s and  BIA’s ability to support efforts to oversee the TTP and RMP which fund  roads on tribal lands, including maintaining and improving the federally  owned roads for which BIA is responsible.
subsections: section_title: NTTFI Data Identifies Roads Eligible for Funding, but Inaccuracies Limit the Usefulness of Road-Description and Condition Data
subsections: section_title: NTTFI Useful for Identifying Roads Eligible for Federal Tribal Transportation Program Funding
paragraphs: We found that NTTFI inventory data—such as road location, length, and  ownership—are reasonably complete and accurate, and therefore useful,  for identifying roads eligible for TTP funding. This assessment is based  on our electronic testing and review of BIA’s process for entering new  data for these fields.  For example, we found that inventory data were  complete, in that fields associated with roads in the inventory were  reasonably complete and within expected ranges. In addition, controls are  in place to ensure accuracy such as when new road segments are  proposed for TTP eligibility or are updated by tribes, BIA reviews those  submissions, including road survey information, to verify the road before it  is made official in the system. The NTTFI road inventory identifies about  161,000 miles of existing and proposed roads on tribal lands that are  eligible for TTP funding. The inventory spans 12 BIA regions and includes  roads of various surface types and owners (see app. II). According to  our analysis, BIA owns 20 percent (29,456 miles) of the existing road  miles on tribal lands and the tribes own almost 12 percent (17,029 miles),  leaving about 68 percent (100,796 miles) of the existing road miles under  the control of state, local, and other entities. (See fig. 2.)
In contrast, our electronic testing of NTTFI data on road-description and  condition data, such as surface type, surface condition, and daily traffic  count, found missing, inaccurate, and out-of-date entries. Despite these  issues, FHWA—the agency responsible for the TTP budget—uses the  NTTFI data for reporting and oversight purposes. For example, FHWA  uses these data to report on the condition and use of tribal roads in its  performance reports and annual budget justifications.  In addition, BIA  uses these data to generate information for its internal use, such as  estimating construction costs to improve TTP roads.  BIA officials said  that these data were originally included in NTTFI to support TTP-funding  allocations but are no longer used for this purpose. Nevertheless, BIA  continues to collect these data fields from tribes and maintain existing  data on these fields in the NTTFI. Federal standards for internal control  state that to achieve agency objectives, management should (1) design  information systems and related control activities including continuing to  evaluate those activities for continued relevance and effectiveness and  (2) use quality information.   Given the data quality limitations we  identified in our electronic testing and changes in program requirements,  this  raises questions about the continued need to collect these road- condition and description data because they are of limited use for  reporting and oversight efforts. Several factors, described below, have  affected the quality and usefulness of road-description and condition data.  These factors include: (1) changes in the role these data fields play in  funding decisions, (2) lack of clarity in BIA’s guidance to tribes for  reporting these data fields, and (3) limited data-monitoring activities.
section_title: Change in Need for Road- Description and Condition Data Leads to Data Quality Issues
paragraphs: According to BIA officials, road-description and condition data were  originally collected to support TTP-funding allocations, but acknowledged  that these data fields are no longer used for that purpose. This is in  contrast to inventory data, described above, which continues to be used  to identify roads eligible for TTP-funding.  Specifically, prior to 2012, road-  description and condition data fields were used in the funding formula to  determine the distribution of tribal-funding shares.   When road- description and condition data were used for funding purposes, missing,  out-of-date, or erroneous data could pose a risk to funding decisions.   Road-description and condition data collected after 2012 are no longer  needed for this purpose, thus eliminating a key incentive for tribes—which  are responsible for entering the data—to ensure the data are complete,  accurate, and up-to-date.  Federal standards for internal control state  that management should design its information systems and related  control activities to achieve the entity’s objectives including continuing to  evaluate those activities for continued relevance and effectiveness.    Although BIA officials acknowledged that changes in a regulation  affecting how the data are used have contributed to the problem of  outdated and unreliable data, they have not made changes to NTTFI data  collection since its use in the funding formula was discontinued in 2012.   BIA officials also noted that while they generally do not use NTTFI road- description and condition data for system-wide reporting, they do make  this information available to FHWA, which has used it to report on road  condition in its annual budget justification and its Conditions and  Performance Report to Congress. While NTTFI road-description data are  relevant for this purpose, it is unclear how useful the current data are for  such a purpose given the results of our electronic testing. Collecting and  maintaining road-description and condition data involves both tribal and  BIA resources; however, until BIA can clearly define a relevant purpose  for collecting these data, it is difficult to justify the continued collection of  data that are not current, complete, or accurate.
section_title: Unclear BIA Guidance Contributes to Outdated and Inaccurate Data
paragraphs: BIA’s guidance to tribes on how to “code” the data when entering it into  NTTFI is unclear.  This can result in inconsistent collection and outdated  data, both of which can lead to inaccuracies when these fields are used  for budget justification and performance reporting.  For example,  required NTTFI data fields pertaining to traffic counts (average daily traffic  on major arterial roads) and surface condition (surface condition index)  are outdated and may not be comparable across tribes. BIA’s guidance  does not require data to be updated on a routine basis, and condition  data is not required to be collected in the same manner by all tribes. In  particular:  Average daily traffic (ADT):  ADT is a measurement of the  amount of traffic that is using the road and, among other things, is  intended to be used to: (1) determine the design standards to  which a road should be built (such as whether the road surface  should be gravel or paved); (2) manage road maintenance (such  as determining which roads to maintain and what treatments to  use); and (3) report on the number of vehicle miles being traveled  (such as for analyzing road usage trends). Research and  guidance on industry practices indicate that ADT on major roads is  typically counted every 2 to 6 years.  We found that BIA does not  provide direction in its coding guide on how often to take traffic  counts and most of NTTFI’s traffic counts for major arterial roads  are between 6 and 12 years old.  In particular, of the existing  major arterial road sections in NTTFI—totaling 1,872 miles—none  have had their ADT counted in the last 3 years, 0.3 percent (6  miles) have been counted in the last 4 years, 3.8 percent (72  miles) have been counted in the last 6 years, and 81 percent  (1,517 miles) have been counted in the last 12 years.  As a result,  ADT information contained in NTTFI likely does not reflect current  road usage and cannot reliably inform reporting or decisions  related to design standards or maintenance management.
Surface condition index (SCI): SCI is a measurement of road  surface condition that can be used to identify and prioritize  maintenance needs. According to industry guidance, road  conditions are typically evaluated every 1 to 4 years because  conditions deteriorate over time. There is no requirement in  BIA’s coding guide to specify how often SCI should be updated,  and we found that the SCI for about 85 percent (81,080 of the  95,510 miles) of existing paved and gravel roads (those which are  required to be evaluated for SCI) could not have been updated in  at least the last 4 years, and almost 50 percent could not have  been updated in at least the last 8 years.   Further, because the  coding guide allows tribes to use any nationally acceptable  method to rate a road, data may not be collected consistently from  those evaluating the roads.  As a result of outdated SCI data that  is inconsistently collected, NTTFI lacks reliability for use in  prioritizing TTP projects and making the most efficient use of  resources. Further, FHWA’s use of SCI data may contribute to  inaccuracy in its reporting on the overall condition of the system  and whether it is improving or worsening.
In addition to these specific limitations, the BIA coding guide—which  provides guidance for those collecting and inputting data into the NTTFI— was last updated as a draft released in 2007 and contains outdated  references. For example, the guide refers to the Indian Reservation  Roads (IRR) Program—the program prior to the TTP. Moreover, in 2008,  FHWA issued a review of the then-IRR Program. The FHWA’s review,  among other things, found that the coding guide had conflicting,  confusing, and ambiguous instructions or definitions.   In its review,  FHWA recommended that the BIA revise the guide to remove subjective  interpretations and ambiguous directions to improve data consistency and  accuracy. BIA has not updated the coding guide to address FHWA’s  review and recommendations, but BIA officials stated that they have  taken some efforts to improve the data.
BIA officials acknowledged that outdated and inaccurate data exist within  the NTTFI but noted that it is the tribes that are responsible for entering  this information.  BIA officials noted that tribes may have less incentive to  update data fields such as ADT, SCI, and other road-description and  condition data because, as noted above, this information is no longer  used as a factor in determining the allocation of TTP funds to tribes.  Federal standards for internal control state that management should use  quality information. Moreover, these standards recommend that  management design control activities, such as providing clear guidance to  achieve their objectives.  If BIA determines that it needs to collect these  data to achieve the agencies’ objectives, it will not have assurance that  the tribes can provide quality information on road use and surface  condition until it can provide more clear guidance to them.
section_title: Lack of Monitoring Contributes to Missing and Conflicting Data
paragraphs: While the NTTFI has some automated data entry checks for road- description and condition information, BIA does not monitor these fields  for missing or conflicting data, resulting in persistently incomplete and  inaccurate data. For example, we found that road-description and  condition data associated with about 14 percent (22,000 miles) of existing  and proposed road miles have not been updated since they were  imported into NTTFI in 2004. In our analysis we identified conflicting data,  indicating inaccurate information, as well as missing data for required  fields. We found, for example:
About 6 percent (8,630 miles) of entries pertaining to the 147,281  miles of existing roads are missing their required “functional class”  code, which is used to determine the construction standard for the  road, such as identifying the appropriate pavement type.  Without  complete functional class information on existing roads, it is not  possible to know if the road is adequately constructed or needs to be  improved when making funding estimates.  Without this information on  proposed roads, planning estimates of system-wide funding to  construct these roads may be in error.
Approximately 6 percent (9,553 miles) of entries pertaining to all roads  have the “construction need” coded as “proposed,” but the required  “existing surface type” is blank (i.e., not coded as “proposed”) making  it unclear whether these roads are existing or proposed. Also, about  70 percent (9,553 miles) of the 13,380 miles of proposed roads are  missing their required “existing surface type” code which should show  them to be “proposed.” Accurate information in these fields helps  ensure that agencies clearly know which roads are proposed and  which are existing, knowledge that is essential for planning  maintenance and construction and developing the costs for those  plans.
BIA officials told us that they are aware of these data errors, which they  believe are primarily from data that were imported into NTTFI from the  previous inventory system in 2004. These officials also noted that there is  not a systematic reporting function to identify these errors and generate  an error report to support correction efforts.  While there are some  automated checks on the system that tribes use to enter and update data  in the NTTFI, they do not apply to data already in the system. With  respect to data entry checks, for example, certain fields only accept a  specific range of values for data entry, and some fields require  documentation for entries that require BIA’s review before official  inclusion into the NTTFI.  These checks are intended to eliminate the  possibility of entering incorrectly coded data or the inclusion of erroneous  data. No similar error reporting or checks for compliance with expected  values are applied to existing data. According to BIA officials, this is  because they do not own the tribal data that is in the system they manage  and therefore cannot make changes to the data once it has been  accepted into the system. Tribes are required to update their data  annually.   Nevertheless, BIA has a stewardship responsibility to ensure  the NTTFI’s data accuracy. Federal internal control standards state that  information systems and related control activities, such as monitoring to  identify missing or erroneous data, should be designed to facilitate timely  and targeted corrections.  Without complete and accurate road- description and condition data, BIA and tribes will be limited in their ability  to assess the needs for the entire road system within their scope and  identify TTP priorities. Having more complete and accurate data would  also better support FHWA’s budget-justification and performance  reporting.
New TTP regulations recently went into effect that may mitigate some of  the data errors we identified.  These regulations require the tribes to,  among other things, submit specified documentation by November 7,  2017 to BIA and FHWA for approval for all proposed NTTFI roads that  currently exist in the NTTFI in order to remain in the inventory.   According to BIA officials, this review and verification may correct some of  the problems with the proposed road data in NTTFI. BIA officials told us  that they are in the process of developing the details of how the review  will work and what options they may be able to take to ensure the  proposed road data are accurate, including possibly removing proposed  road sections containing data errors from the inventory.
section_title: Quality of Some DMR Data May Affect Reporting on Performance and Deferred Maintenance
subsections: section_title: DMR Identifies BIA Roads Eligible for Federal Road Maintenance Program Funding
paragraphs: The DMR system provides an inventory of BIA roads by location, length,  and route that may be maintained with RMP funds. Separate from the  NTTFI, BIA maintains the DMR system containing the inventory of BIA- owned roads eligible for maintenance funded by the RMP.  DMR records  consist of data on individual road sections with fields pertaining to the  description, such as surface type, level of service, and maintenance  needed, performed, and deferred of each section. We found the DMR  data to be useful for identifying roads in the BIA inventory. Table 1 shows  the distribution of these roads across the 10 BIA regions in which they are  located; two BIA regions have no BIA roads.  While the BIA roads are  also in the NTTFI, the DMR database includes additional data, such as  deferred maintenance, which is not in the NTTFI.
In management of the RMP, BIA sets goals and reports on its  performance; however, we found that some data in the DMR system— specifically, data on the current level of service (overall condition of the  road), cost of needed maintenance, and amount of maintenance  performed—may not be sufficiently accurate for BIA’s use in this  reporting.  This reporting includes assessing the amount of deferred  maintenance for the BIA road system and reporting how BIA has met its  performance targets for the RMP. BIA uses deferred maintenance to (1)  quantify the amount of maintenance needed (in dollars) on BIA roads in  Interior’s annual budget justification and (2) report on maintenance  performance targets to the Indian Affairs Performance Management  System, information that is found in BIA’s annual budget justification and  performance information. BIA uses level of service data from DMR to  calculate and report the percentage of miles of BIA roads in acceptable  condition in the performance report. If the level of service data is in error,  then the resulting performance reporting will also be inaccurate. As noted  previously, according to federal internal control standards, management  should use quality information to make informed decisions and in  communicating both internally and externally.  Controls to ensure that  quality information is used include: obtaining relevant data (that are  reasonably free from error) from reliable sources, obtaining that  information on a timely basis, and processing that data into quality  information that faithfully represents what it purports to represent.
To determine the amount of deferred maintenance on BIA roads, BIA first  calculates the maintenance needed by multiplying a unit cost of  maintenance per mile, based on a road section’s level of service, by the  length of the road section. However, we found that two of the factors— level of service and unit cost of maintenance—that BIA uses in its  maintenance cost calculations may be unreliable, resulting in inaccurate  estimates of maintenance needs. In particular:  Level of service (LOS): LOS is a qualitative road condition rating  (on a 1 to 5 scale) based on road surface, drainage, pavement  marking, and other characteristics which change over time. BIA  officials stated that every BIA road is evaluated on an annual  basis. However, it is not possible to determine specifically when  each road section’s LOS was last updated because the DMR  system does not record this information. Without knowing when  the LOS information was last updated, BIA does not have  reasonable assurance that LOS data represent actual road  conditions, or whether BIA is meeting its performance measures  for the RMP.
Unit cost of maintenance: Unit maintenance costs are used to  identify the estimated annual costs of maintaining a particular road  section. BIA develops unit costs per mile based on a road’s  geographic location, surface type, and level of service to estimate  the amount of maintenance needed for the entire road section.   However, BIA officials told us that they had no formal  documentation showing how the unit cost estimates were  prepared.  According to leading practices for cost estimation, one  key step for ensuring high-quality cost estimates is to document  the estimate that includes auditable and traceable data sources  for each cost element. Because BIA does not document unit  cost estimates, it cannot determine the reliability of the estimates’  sources or the quality of the estimate of maintenance needs  based on their use.
After determining the amount of maintenance needed, BIA subtracts the  amount of maintenance performed as reported by BIA and tribes in the  DMR from the needed maintenance to determine the amount of deferred  maintenance. However, BIA officials stated that there is under-reporting  of performed maintenance by some tribes.  In particular, BIA officials  noted that approximately 172 tribes have an agreement with BIA to  administer the RMP and maintain BIA roads in their area, but only about  40 percent of those tribes report on their road maintenance activities  which results in the DMR system having incomplete data on maintenance  performed.  BIA officials stated that they continue their educational  efforts to stress the value of the collection and reporting of performed  maintenance. However, these officials told us the reporting of  maintenance performed at the road section level can be difficult because  the maintenance work is not always performed at one specific road  section, and it is challenging to allocate maintenance activities over  multiple sections. BIA officials told us that they are considering alternative  means of reporting the maintenance performed amounts to increase the  completeness of the maintenance performed measure; however, they do  not have a specific plan in place to address this issue at this time.
Because BIA’s estimates of needed maintenance may be inaccurate and  tribes’ reporting on performed maintenance is incomplete, calculations of  deferred maintenance—the difference between estimated maintenance  needed and actual maintenance performed—that support BIA’s budget  submission and performance reporting may be similarly inaccurate. This  lack of quality information can preclude Congress and agency officials  from having a clear understanding of BIA road conditions and from  making informed decisions about RMP priorities and funding levels.
section_title: Stakeholders Face Various Challenges to Improving Roads on Tribal Lands, Although Partnerships Have Helped to Mitigate
paragraphs: Based on our review of various planning and funding documents as well  as interviews with selected stakeholders—including federal, state, local,  and tribal officials—we identified funding constraints, overlapping  jurisdictions, and adverse weather as some of the challenges faced in  improving and maintaining roads on tribal lands.  However, we found  examples of collaboration among different stakeholders to improve  coordination and resource sharing that helped mitigate some of these  challenges.
subsections: section_title: Funding Constraints, Jurisdictional Issues, and Adverse Weather Complicate Road Improvements and Maintenance on Tribal Lands Funding Constraints
paragraphs: TTP annual appropriations fluctuated between about $424 and $441  million from fiscal years 2013 to 2016, and were less than FHWA’s  budget request each year.  (See fig. 3.) Federal, tribal, and other  stakeholders we interviewed noted that constrained funding has limited  the ability of tribes to improve and maintain roads on tribal lands and  contributed to the deterioration of these roads.  In addition, current  funding levels have led to less frequent maintenance and improvement  activities than desired, according to some tribal officials.  For example, a  transportation official from a Great Plains region tribe said that annual  TTP funding allows for resurfacing their reservation’s 54-mile paved road  network every 73 years, when the existing roadway network needs to be  resurfaced at least every 20 years to maintain the roads in an acceptable  condition.
RMP funding has also remained relatively flat, at about $25 million per  year from fiscal years 2009 through 2015, while the number of BIA roads  eligible for these funds increased over this time period, from 26,868 to  28,859 miles.  Over 85 percent of these BIA road miles are located on  the lands of 59 tribes within six BIA regions. According to BIA and tribal  transportation officials, RMP funding levels have not kept pace with the  growing road maintenance requirements due to the addition of new roads,  the need to address existing roads’ maintenance backlogs, and  emergency operational requirements.  For example, according to BIA and  tribal officials, as much as 90 percent of some tribes’ annual RMP funds  can be expended during the winter for snow and ice removal, leaving little  for other road maintenance activities the remainder of the year. Also,  according to these officials, the remoteness, rugged environment, and  unavailability of materials on some tribal lands leads to comparatively  higher costs for maintaining roads located in these areas, which further  exacerbate funding constraints. Also, as roads fall into disrepair through  the delay of or inability to fund road maintenance, the more expensive  roads become to maintain.  Deferring maintenance may result in greater  future reconstruction expenditures. Most state and local transportation  officials we spoke with said their agencies also face funding constraints  that inhibit their road-improvement and maintenance efforts on tribal  lands. Moreover, the amount of road maintenance funding expended on  tribal lands has generally been less than the amount expended on similar  roads in neighboring jurisdictions, according to BIA and tribal officials.   For example, according to a 2008 analysis completed by a BIA Navajo  Region official, counties bordering the Navajo Nation’s reservation  receive about two times more road maintenance funding per mile to  maintain county-owned roads compared to the road maintenance funding  BIA receives to maintain its roads on the Navajo Nation.
Over the past several years, BIA and tribal officials have tried to address  road maintenance funding concerns by requesting additional RMP  funding. In March 2016, Interior and tribal officials created a workgroup to  analyze, record, and develop data for road maintenance budget needs.  This group recently held discussions with BIA officials about establishing  a new budget category for roads and transportation so that requirements  such as road maintenance receive greater visibility in the budget.  At the  time of our review, discussions pertaining to this initiative were ongoing.
subsections: section_title: Overlapping Jurisdictions
paragraphs: Overlapping jurisdictions on tribal roads may create confusion and access  issues that can delay or prevent road maintenance and improvement  activities. Tribal lands may be owned by a tribe, an individual Indian, or a  non-Indian. This varied ownership creates interspersed parcels or a  checkerboard pattern of ownership on some tribal lands. According to  federal, state, county, and tribal transportation officials, documentation of  road ownership and rights-of-way do not always exist or are not always  known, a lack that further complicates the ability of stakeholders to  conduct road maintenance and improvement activities. Also, different,  changing, or uncertain management responsibilities pertaining to roads  on tribal lands that are owned by different stakeholders can make  collaboration challenging as the decision-making on road priorities and  funding sources are also dispersed. For example, two adjacent school  districts within the Navajo Nation use many of the same roads for their  school bus routes.  These roads not only have multiple road owners but  they also have different types of road surfaces—paved, gravel, and  earth—which require different types of maintenance. (See fig. 4.)  Because of differences in priorities among road owners, the amount of  maintenance performed on the roads varies, leading to differences in  road condition and potential impediments to transportation.
Other challenges stem from changing roles and responsibilities, liability  concerns, and differing approaches to meeting regulatory requirements,  for example:
Some challenges can occur as roles and responsibilities shift from federal to tribal control. For example, in 2013, the Navajo Nation signed a TTP Agreement with FHWA that changed the roles and responsibilities for both the BIA Navajo Region and the Navajo Nation.   Under the agreement, the Navajo Nation assumed responsibility for conducting TTP work that used to be managed by BIA. However, according to federal and tribal transportation officials, it will take time for the Navajo Nation to build its capacity to assume the roles and responsibilities previously performed by BIA. According to a BIA Navajo Region official, they have been adjusting their capacity as their functions and duties diminish over time. As of December 2016, the BIA Navajo Region and the Navajo Nation were still in the process of transitioning operational roles and responsibilities, according to BIA officials.
According to some federal and tribal transportation officials, tribal councils’ preferences or officials’ decisions may not always align with previously established plans and priorities.  For example, in April 2016, an Oglala Sioux tribal official halted the development of a new gravel quarry location that was believed to be a sacred site. As a result, tribal transportation officials used the next nearest quarry, approximately 50 miles away, thus increasing road maintenance costs.
Liability issues can halt or delay maintenance work.  For example, the La Jolla Band of Luiseño Indians is located in a mountainous region of northern San Diego County, California, where rock falls are prone to occur.  When rocks fall on a remote section of a state highway that runs through tribal lands, according to a tribal transportation official, the tribe must wait for state authorities to respond, even though the tribe has equipment that can remove the fallen rocks.  According to this official, the state prohibits the tribe from conducting emergency  maintenance work to avoid potential liability issues. As a result, local  traffic can be blocked for extended time periods while waiting for state  workers to respond.
Differing approaches to compliance with the National Environmental Policy Act can affect delivery of maintenance and improvement projects.  For example, according to a 2013 Department of Transportation’s Inspector General report, existing agreements between FHWA and BIA do not reconcile the two agencies’ different processes and requirements for National Environmental Policy Act approvals on TTP projects. According to some federal and tribal officials we spoke to, differences exist, in particular, in the process for acquiring a right-of-way for project construction.  FHWA grants categorical exclusions in certain cases where tribes need to establish or amend an existing right-of-way while BIA requires tribes to prepare an environmental assessment for these cases, which is resource- intensive, according to federal and tribal officials.  According to tribal officials, BIA retains right-of-way approval authority for projects on land it owns or holds in trust for tribes, and completing TTP projects at these locations results in additional time and cost.  In November 2016, a final rulemaking included clarification that is expected to minimize or eliminate conflicts that involve differences in federal processes.  The final rule specifies that FHWA’s categorical exclusions will apply to all qualifying TTP projects involving construction or maintenance of roads regardless of whether BIA or FHWA is responsible for overseeing the tribe’s TTP.
section_title: Adverse Weather
paragraphs: According to various transportation and education officials we met with,  adverse weather can exacerbate maintenance challenges on roads  located on tribal lands. While adverse weather—such as drought, heavy  rain, high winds, and snow—can negatively affect all areas, communities  that are located in more geographically dispersed areas and have more  variations in land topography along a vast road network can experience  particularly difficult challenges. Further these officials said that these  challenges can be more severe on larger reservations that have more  earth and gravel roads. According to federal and tribal transportation and  education officials we spoke with:  prolonged droughts can result in nearly impassable roads due to sand dunes, rocky surfaces, and deep holes that non-4-wheel drive vehicles cannot traverse; heavy rains can lead to flash flooding and washing out of earth roads, cutting off communities from important access points; high winds can lead to dust storms causing traffic accidents and blockage of the only accessible road; and snowfall can lead to icy and muddy road conditions, creating deep ruts along a road and preventing access by rescue and other vehicles.
According to federal and tribal transportation officials, after most adverse  weather events, road maintenance workers are unable to quickly deliver  assistance to some remote locations because unpaved roads may be  impassible. In addition, workers are often unable to conduct necessary  maintenance activities during and immediately after some weather events  because they must wait to use the equipment until the adverse weather  ends and the ground dries. Also, although federal and tribal transportation  officials may have maintenance equipment located at different  maintenance yards or prepositioned in strategic locations around tribal  lands to address normal and emergency road maintenance needs, they  said that the remote distances may still prevent immediate responses.  These situations can isolate some people within their communities and  away from essential services until emergency road maintenance can be  conducted, according to officials.  Compounding this challenge, officials  said, is the lack of or limited access to telecommunications on tribal lands,  limitations that can prevent tribal residents and public users from even  communicating routine and emergency maintenance situations while they  are in remote tribal lands.
section_title: Partnerships Have Helped to Overcome Some Challenges
paragraphs: According to federal and tribal officials we spoke to, tribes that have  collaborated in partnerships with federal, state, and local governments to  complete road maintenance and improvement projects had overcome  some funding, material, labor, and equipment challenges.  Based on our  site visits and interviews with various transportation officials, we identified  selected examples of federal, state, local, and tribal collaboration. (See  app. IV, table 5.) Below are three examples of larger coordinated, multi- partner road improvement and maintenance projects that we identified.
In 2013, FHWA, BIA, Arizona Department of Transportation, and the  Navajo Nation partnered on a $35 million emergency relief project to pave  about 27 miles of BIA Route 20, which was an earth road, during the  closure of a 23-mile stretch of U.S. Highway 89 after a landslide damaged  a portion of the highway. (See fig. 5.) The highway closure caused the  Arizona Department of Transportation to set-up a detour affecting travel  to Page, Arizona, from points south. The detour (along Arizona State  Highway 98 and U.S. Highway 160) affected hundreds of Navajo school  students and was 45 miles longer than the direct route into Page along  U.S. Highway 89.  According to federal, state, and tribal officials through  effective coordination, BIA Route 20 was paved in about three months  and completed prior to the start of the school year so that students could  benefit from a shorter drive on a better road surface.
In 2014, the Navajo Nation Division of Transportation and Coconino  County (Arizona) established a matching fund program whereby the  county and the Navajo Nation each contributed $200,000 to maintain  school bus routes in the area, among other projects.  (See fig. 6.) The  goal of the program was to implement minor drainage and surfacing  projects on the roads maintained by the county.  According to Coconino  County officials, in addition to the increased road maintenance, the plan  for this funding was to improve school bus route conditions, reduce road  maintenance costs, and increase safety. Transportation officials also said  the partnering enabled the Navajo Nation and the county to use  maintenance funds more efficiently and focus on blading roads versus  having to constantly repair roads damaged by winter and summer storm  events.
While partnerships have been effective in two cases described above,  collaboration among stakeholders can be difficult and achieving beneficial  outcomes can take time. For example, in the third case, the Hopi Tribe,  Navajo Nation, BIA Hopi Agency, and Navajo County (Arizona) have  been working together since 2009 to obtain funding for the Hopi 60 (Low  Mountain Road) project. According to transportation officials, the road  construction project would pave about 14 miles of BIA Route 60 of which  about 11 miles are located on Hopi tribal lands and about 3 miles are  located on the Navajo Nation. This BIA route is an earth road that is the  primary school-bus route for multiple school districts. According to  transportation officials, during adverse weather conditions, BIA Route 60  becomes impassible and causes drivers on Hopi lands to take a 106-mile  detour along Arizona State Highway 264. These stakeholders partnered  to submit federal discretionary grant applications in 2009 to obtain about  $22 million and in 2015 to obtain about $29 million needed for this project  but were not successful.   Stakeholders continued to pursue funding and  were recently awarded $1.5 million from the State of Arizona. According  to county transportation officials, stakeholders plan to submit another  federal discretionary grant application in 2017 to secure funding for the  remainder of the project’s cost.
section_title: Indian Students Have Higher Absence Rates, and Road Conditions Can Be a Barrier to School Attendance on Tribal Lands, Although Data Are Limited
subsections: section_title: Indian Students Nationwide Have Higher Absence Rates than Non- Indian Students, but Research about the Effect of Road Conditions Is Limited
subsections: section_title: Higher Absence Rates
paragraphs: Nationwide, Indian elementary and secondary school students are absent  more than non-Indian students, according to our analysis of national data  from two Department of Education (Education) surveys. Education  administers one survey to all public school districts but not BIE schools,  and the other survey goes to a generalizable sample of schools and  students, including BIE schools and students. We found that Indian  students’ higher rates of absences are evident at public schools serving  mostly Indian students and at BIE schools, which would likely be on or  near tribal lands.
In a census of public school districts and schools taken during the school  year 2013–14, the national chronic absence rate for Indian students was  23 percent per year as compared to the national average of 14 percent  per year for non-Indian students, according to our analysis of one  Education measurement of absenteeism.  Education asked for the  number of students in schools who were absent 15 or more days in the  school year.  Our analysis showed that this rate was higher at schools  across the country where Indian students represented at least 90 percent  of the students. In particular, we found that 28 percent of Indian students  were absent 15 or more days at schools where most students were  Indian, such as schools in districts we visited.
According to a 2015 Education survey of students intended to measure  academic achievement, Indian students in grade 8 self-reported being  absent more than non-Indian students. (See fig. 7.) Likewise, this pattern  applied to Indian and non-Indian students in grade 4. The survey asked  students in grades 4 and 8 for the number of days they were absent in the  last month.
Grade 8 Indian students at BIE schools—which are generally located on  reservations—at times reported being absent more than Indian students  not at BIE schools. Specifically, the self-reported absences in grade 8 for  “three or four days” in the last month and “more than ten days” in the last  month were higher for BIE students, as compared to Indian students at  other schools.
section_title: Limited Research on Effect of Road Conditions
paragraphs: In our literature review, we did not identify any studies on the role that  road conditions have on student attendance in the United States,  including for Indian students living on tribal lands.  However, we found  studies about developing countries that identified road conditions as one  of several factors influencing student attendance. While these studies  were not specifically about the United States or Indian students living on  tribal lands, they indicate that poor road conditions can decrease school  attendance and road improvements can increase attendance in certain  contexts. For example, a 2010 study of Trinidad and Tobago found that  road improvement increased student attendance by 16 to 18 percent,  among other educational outcomes.   In addition, a 2006 study of a  program in Bangladesh to improve and maintain rural roads and markets  reported that school participation, measured as the average percentage  of school-age children in school, increased about 20 percent for boys and  girls whose villages participated.  A third study of rural Pakistan found  that higher levels of community development were associated with  significantly reduced likelihood of dropout in certain scenarios; the level of  development included seven indicators, such as two indicators of whether  a community had paved roads.
According to literature we reviewed, there are many factors connected  with student attendance. The factors that may be connected with school  attendance and absences in the United States and other countries  generally fall into four categories: individual, family, school, and  environmental or community. Literature we reviewed has identified  numerous examples of factors in these categories. (See fig. 8.) Road  conditions are an example of an environmental or community factor that  may be connected with school attendance.
section_title: Selected School Officials Identified Road Conditions as a Factor That Can Affect Attendance, but Data Are Limited
subsections: section_title: School Officials Noted Road Conditions Are among the Factors Affecting Student Absences
paragraphs: Attendance Rates and Earth Roads in One  Navajo Nation School District   At one district on the Navajo Nation,  attendance rates in school year 2015-16 were  lower for certain students on a few particularly  challenging bus routes on earth roads.  These  routes are altered and truncated during  adverse weather. District data showed these  students’ attendance rate was about 91  percent, compared to the district’s 95 percent  overall attendance rate. This difference in  attendance rate—some of which may relate to  road conditions—would be equivalent to  about seven additional days of absences,  according to district officials.
Road conditions are one of the factors leading to absences for Indian  youth on tribal lands, according to officials at all 10 local schools and  districts we visited serving three tribes. Road conditions reflect the  surface type and level of maintenance, among other things. On large  reservations as with the three we visited, students may live far from  school, and in many cases their residences and schools are only  accessible by earth and gravel roads. At these 10 schools and districts,  officials told us that adverse weather worsens road conditions on tribal  lands and sometimes affects student attendance. Officials said that  school-provided transportation—buses and sport-utility vehicles (SUVs)— are the most common means of student transportation. A few school and  district officials said that certain students may not have alternatives to  school-provided transportation to get to school, such as a ride from  family, or that weather or road conditions may preclude students from  getting to school on their own. Thus, when the school vehicle or the  student cannot access the pick-up location due to road conditions, the  student may miss part or all of the school day. For example, at one school  we visited, the principal noted that students who lived far from the bus  route (at least 12 to 20 miles away) have at times missed school, as  families said they could not reach the bus stop due to impassable roads  with mud or snow. Additionally, occasional bus breakdowns, such as  getting stuck in the mud, can affect student attendance, such as arriving  late to school, according to officials in one district on Navajo Nation.
School and district officials also mentioned that school attendance was  lower when they altered or halted school bus routes because of adverse  weather conditions that compounded the already poor road conditions.  Eight of 10 schools and districts we visited said that during adverse  weather they sometimes kept schools open but altered or did not serve  certain bus routes. School and district officials said that these changes to  bus routes resulted in some students missing school that lived along  those routes. When a bus route is truncated from its original route,  students or their families often have to travel even farther than their  regular bus stop to meet the bus, such as at a main road, travel that can  affect attendance, because families have no way to reach the farther bus  stops, for example. On the Pine Ridge Reservation, one school  superintendent told us that certain families who live in remote locations  along earth roads do not have 4-wheel drive vehicles to reach the farther  bus stop when roads become muddy or snow-covered.
Student absences can also result when school officials decide not to  serve a bus route on a particular day. At a school in the central part of the  Pine Ridge Reservation, school officials said that the school did not serve  certain routes a few times in a year due to weather and safety concerns,  such as heavy snowfall and icy road conditions. School officials told us  that students on these routes could not get to school, and the school  recorded their absences as excused. In addition to the three tribes we  visited, officials we interviewed from BIE, Education, and other tribes told  us that they heard similar concerns about challenging or impassable road  conditions that affect student attendance. One tribal transportation expert  said that the problem is particularly problematic for tribes with larger  reservations due to the longer distances that people must travel and  typically poor road conditions.
Officials at schools and districts we visited mentioned a few strategies  they sometimes used to try to mitigate the challenging road conditions  and promote students’ access to school. However, at times, even these  strategies did not allow students to get to school. For example, one  school superintendent on the Pine Ridge Reservation in South Dakota  noted that the school used SUVs on certain routes, but even its SUVs  were unable to reach students due to the excessive snow or mud on  earth roads for a total of about three to four days over the course of the  school year. Additionally, as noted above, telecommunication challenges,  such as limited or no internet access on tribal lands, affects the potential  to use technology for virtual education. (See app. V for additional details  on strategies used by officials of the three tribes we visited.)
section_title: Schools Have Limited Data on Reasons for Absences
paragraphs: Guidance from the National Forum on Education Statistics, a body  commissioned by Education, and other sources have stated that public  school districts’ data collection on reasons for student absences is  important  to understand these reasons in order to take actions to  ultimately increase attendance.  The Education Department does not  require school districts to collect particular data about reasons for  absences, according to Education officials. Public school districts develop  their own attendance systems, which may vary across districts, including  reasons for absences. Nonetheless, the education forum provided non- binding guidance in 2009 on how school districts should develop  attendance systems and document reasons for absences. Among other  things, the guidance stated the importance of a comprehensive and  manageable classification of student attendance, including reasons for  absences. It suggested a series of reasons for absences for states and  districts to consider, including transportation issues. Data on reasons for  absences would then be helpful to inform interventions to increase  attendance. Similarly, guidance jointly issued in 2015 by four  departments—Education, Health and Human Services, Housing and  Urban Development, and Justice—emphasized the importance of  collecting and using absence data to improve attendance for those  students who miss many days of school, including understanding reasons  for absences.
Three of the 10 schools and districts we visited—one BIE school and two  public school districts— collected data on the number of student  absences related to road and weather conditions.  According to officials  at these locations, road conditions leading to student absences typically  were accompanied by adverse weather, such as heavy rainfall, snowfall,  or strong winds. The percentage of absences at these three locations due  to adverse weather and road conditions ranged from a fraction of 1  percent to 4 percent, according to the data. However, because parents  did not provide a reason for the absence in many cases, the actual  percentage of absences due to roads and weather may be higher. For the  one BIE school that collected data on reasons for absences due to road  and weather conditions, it decided on its own initiative to create a  category for these absences. A school official said that weather-related  absences generally were more likely to involve students who lived along  earth or gravel roads. For example, due to snow, buses may not be able  to reach students living along certain earth or gravel roads, or families  may not be able to bring students to the bus stop. The official noted it is  important for the school to know why students are absent in general, and  how often students are absent, specifically, due to road and weather  conditions in order to understand the extent that these conditions affect  students’ ability to get to school. This information can help schools set  priorities and target interventions depending on the extent of such  absences.
The other five BIE schools we visited did not collect data in a way that  would capture absences due to road and weather conditions.  Officials at  two schools said that they recorded absences due to difficult road  conditions as more general excused absences. For example, such  absences were due to truncated bus routes or snowbound students who  lived in remote areas accessible only by earth roads. At another school,  officials did not seem aware of the ability to count and track a specific  category of absences due to road and weather conditions, on a school- wide basis.
According to BIE officials we spoke to, some schools may not collect  absence data for road and weather conditions due to various  circumstances such as school staff turnover, competing priorities among  school attendance staff, or limited emphasis from BIE to collect data on  these reasons for absences. Further, BIE has not provided guidance to its  schools regarding capturing reasons for absences related to roads and  weather. Documentation for the system used to collect absence data  states that each absence should have a reason entered by the school.   However, BIE has not provided instructions or suggestions to the 185  schools it funds to consider including road and weather conditions in their  attendance system. For example, it has not issued a sample list of  reasons that schools can use or tailor for local circumstances. According  to BIE officials, BIE has not done so because it wants to give schools  flexibility on which reasons they should collect on absences. However,  BIE has not taken basic steps to facilitate optional data collection by  schools that may be inclined to do so, such as those that are more  affected by poor roads. For example, BIE’s existing attendance system  currently provides a list from which schools can select reasons, or  schools can create other reasons on their own. Road and weather  conditions are not included as reasons on the existing list, and thus a  school would have to create these reasons as causes for absences. In  the capacity to provide technical support to schools, BIE could provide  guidance to collect these data. Without such guidance, affected BIE  schools as well as the Bureau itself will continue to lack insight into the  effect of roads and weather on absences and the ability to target  interventions accordingly. In addition, BIE and its schools do not have  detailed information on this connection to identify patterns or trends or for  discussion with federal, tribal, and other stakeholders, including on  funding levels or road priorities.
section_title: Road Conditions Affect Vehicle Maintenance Costs, Which May Not Be Fully Addressed in BIE’s Transportation-Funding Formula
paragraphs: Road conditions, along with distances on large tribal lands and choices to  enroll in farther schools, may contribute to increased transportation time  and safety risks for students, and increased costs for schools and tribes.  Officials from two schools expressed concern about the time of students’  bus rides and the long school days for children, including young children  in elementary school. For example, on one of our site visits, we followed  an afternoon bus route in dry weather that covered about 30 miles on  mostly earth roads to drop off about 30 students, including elementary  school students. The route’s duration was about 90 minutes. At times, the  school bus drove about 5 miles per hour on the earth roads, such as  when ascending inclines without guard rails or traveling on earth roads  with large rocks or ruts. The school principal said that the earth roads  take more time to travel and lengthen students’ time on the bus. At  another district we visited, several routes were at least 100 miles one- way, according to a list of bus routes from the district.
Road conditions on tribal lands may also present various safety risks to  students and transportation staff. Some roads may have few or no  sidewalks, shoulders, or guardrails, among other features, according to  our observations and a tribal organization. For example, on the Pine  Ridge Reservation, we rode on a school bus route with a gravel road that  led to a wooden bridge, and both sides did not have guardrails. (See fig.  9.) The wooden bridge’s weight limit was nearly reached by the weight of  the bus with students on it, according to a bus driver at the school.
Further, school and district officials told us about challenges with vehicle  maintenance due to road conditions, as described in further detail below.  For example, a BIE school we visited in the Navajo Nation reported that  about 43 percent of its bus miles were on earth roads. The school  principal stated that additional vehicle maintenance—such as replacing  tires, shocks, and other bus parts—resulted from the rough conditions on  poorly maintained earth roads.
Road conditions on tribal lands, including the surface type such as earth  and gravel roads and the level of road maintenance, contribute to the  wear and tear on vehicles, such as the school buses and SUVs that  transport students daily. Although road conditions affect vehicle  maintenance and thus overall transportation costs, BIE—which supplies  federal funding for transportation to BIE schools—has not reviewed its  formula in a decade to consider costs of vehicle maintenance or other  possible factors.
Poor road conditions can increase costs for vehicle maintenance and  transportation overall.   Research suggests that rougher road surfaces,  such as unpaved roads as compared to paved roads, tend to increase the  maintenance and operational costs for vehicles, including buses,  depending on the levels of road maintenance and the design of the road  among other things.  According to information from a school  transportation organization, road and weather conditions can have an  impact on the frequency and cost of school bus maintenance. For  example, in one school district we visited in the Navajo Nation, officials  said that the school buses serving the part of the district with more earth  roads accounted for the majority of the costs for vehicle maintenance,  compared to the rest of the district, which had more total miles but fewer  miles of earth roads.
These increased transportation costs are consistent with our prior work  on BIE school spending. Specifically, we noted the geographically  dispersed locations and poor road conditions, including the vehicle- related maintenance, contributed to schools’ higher transportation costs  per student, on average, for those on tribal lands, such as BIE schools,  than the national average. In contrast to schools on tribal lands, we noted  that slightly more than half of public schools nationwide are located in  cities or suburbs, and therefore may be unlikely to face similarly poor road  conditions or long bus routes.
Officials from 7 of the 10 schools and school districts we visited told us  about or showed us examples of wear and tear on school vehicles  resulting from poor road conditions. For example, officials at two BIE  schools on the Pine Ridge Reservation and a public school district on the  Rosebud Reservation described how vehicles experience prolonged  vibration caused by riding over the grooved surfaces that tend to form on  earth and gravel roads (known as “washboard” roads). Vehicles traveling  these roads require more frequent maintenance than those traveling on  paved roads, according to these officials.  Such safety-related  maintenance work can include brake or oil changes, replacements of side  mirrors or door and window parts, and repairs of windshields. (See fig.  10.) During rides on school buses or SUVs, we observed bumpy road  conditions and the vehicle’s vibrating when driving over rough earth and  gravel surfaces. According to district officials at one public school district  that we visited on the Rosebud Reservation, their buses generally travel  on gravel roads and typically have a life expectancy of about a decade. In  contrast, school buses that operate under normal conditions which are  generally on paved roads have a life expectancy of about 12 to 15 years,  according to a report by a school transportation organization.
BIE’s formula for determining amounts to allocate to BIE schools for  transportation, which was formalized in 2005, does not distinguish  between gravel and paved roads. The formula generally considers both  gravel and paved roads as “improved” roads for funding purposes.  The  mileage on these “improved” roads plus an adjusted mileage (increased  by 20 percent) on “unimproved” roads, which generally includes earth  roads, determines a school’s transportation funding amount, subject to  the available appropriation.  When we asked BIE officials about the  rationale for treating gravel and paved roads similarly from a funding  perspective, they responded that the gravel helps to make the roads more  passable in adverse weather, compared to other roads that do not have  gravel or other materials applied.  However, because BIE’s school  transportation funding formula does not consider the likely higher  maintenance costs for vehicles traveling on rough gravel roads, its  allocation of resources may be misaligned with needs.
Federal standards for internal control state that federal agencies should  periodically review policies and related control activities for continued  relevance and effectiveness in achieving objectives and addressing  risks. However, BIE has not reviewed its transportation funding formula  since 2005 nor has it implemented a recommendation we made in 2003  pertaining to the formula.   Further, BIE and BIA officials said that they  have not communicated in recent years about BIE’s transportation  formula. For example, BIA transportation officials told us that they did not  know that BIE was classifying roads using the terms “improved” and  “unimproved,” which BIA officials said they no longer use. Further, BIE has not formally worked with tribes on its transportation formula since  2005. According to federal internal control standards, agencies should  communicate with external parties when needed in order to achieve  objectives. As a result of not communicating with BIA or tribes, BIE has  not benefitted from technical expertise and experiences of BIA or tribes  and does not know whether transportation funding is distributed in a way  that reflects disparate maintenance needs. BIE officials said they  understood the importance of aligning funding with transportation costs  and said that funding formulas used by states may provide a good model  for BIE to consider.
section_title: Conclusions
paragraphs: Road conditions on tribal lands pose challenges in connecting people to  education, employment, health care, and other essential services. These  challenges are especially magnified during adverse weather because of  the remote location of some tribes and the prevalence of unpaved roads  that are prone to weather-related damage. Useful, accurate, and  consistent data in the NTTFI and DMR system can support road  management and program oversight efforts. However, the purpose for  which NTTFI data are used has changed, in that, since 2012 updates to  NTTFI, data have not been used as a determinant in allocating TTP  funding to tribes. In addition, guidance to tribes for entering data into  NTTFI is dated, and limited monitoring of data that are entered has  resulted in missing or conflicting entries that affect the accuracy and  completeness of these data.  These conditions lead to NTTFI data on  road descriptions and conditions that provide limited usefulness for  management and program oversight purposes and raise questions about  the value of maintaining the NTTFI as it is currently constructed.   Similarly, DMR may contain potentially outdated level of service data  describing road conditions.  In addition, DMR may contain inaccurate data  on maintenance needs because BIA does not document how it develops  maintenance cost estimates and tribes under-report maintenance  performed.  As a result, reports and budget submissions that rely on  these data may not accurately reflect road conditions or maintenance  needs and associated costs. This can inhibit the ability of Congress and  BIA management to make informed decisions about RMP priorities and  funding levels for the BIA road system.
Many factors affect student attendance, among them the condition of  roads. BIE-funded schools vary in the data they collect and on the  reasons for student absences. Expanded guidance to schools to collect  such information would allow BIE to identify whether poor road conditions  and adverse weather affect attendance to better target interventions. Poor  road conditions also affect vehicle maintenance costs, which may not be  fully addressed in BIE’s formula for funding student transportation.  However, BIE has not recently reviewed its funding formula and does not  know whether transportation funding is distributed in a way that reflects  disparate maintenance needs.  By working with BIA and tribes to revise  the transportation-funding formula, BIE has the opportunity to consider  how varying road conditions and other factors affect maintenance costs  and best align its resource allocation in relation to current needs.
section_title: Recommendations for Executive Action
paragraphs: We are making eight recommendations to the Secretary of the Interior.
To help ensure that NTTFI is able to provide quality information to support  management and program oversight efforts, we recommend that the  Secretary of the Interior direct the Assistant Secretary-Indian Affairs to  take the following three actions:   coordinate with the FHWA and tribal stakeholders and reexamine  the need for road-description and condition data currently  collected in the NTTFI and eliminate fields that do not serve an  identified purpose,  for fields determined to have continued relevance for management  and program oversight take steps to improve the quality of these  data by clarifying guidance in the NTTFI coding guide that tribes  use to collect data and by providing additional guidance on steps  needed to ensure that data are consistently reported, and establish a process to monitor data to facilitate timely and targeted  corrections to missing or erroneous data.
To improve the DMR, we recommend that the Secretary of the Interior  direct the Assistant Secretary-Indian Affairs to take the following three  actions: develop a means to document when the level of service for each  road section was last evaluated, develop and maintain documentation supporting the unit costs of  maintenance used to estimate maintenance needs, and develop a process for more complete and accurate reporting  occurring under existing authority of RMP funds expended for  performed maintenance on BIA roads.
To improve data on reasons for student absences, we recommend that  the Secretary of the Interior direct the Assistant Secretary-Indian Affairs to  provide guidance to BIE schools to collect data on student absences  related to road and weather conditions.
To best align resources allocation decisions to needs, we recommend  that the Secretary of the Interior direct the Assistant Secretary-Indian  Affairs to review the formula to fund transportation at BIE schools and  determine, with BIA and tribal stakeholders, what adjustments, such as  distinguishing between gravel and paved roads, are needed to better  reflect transportation costs for schools.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Departments of the Interior,  Transportation, and Education for review and comment. The Departments  of Transportation and Education provided technical comments, which we  incorporated in the report, as appropriate.  Interior agreed with five of the  eight recommendations in our report and described actions under way or  planned to address them. Interior neither agreed nor disagreed with two  of our recommendations and did not agree with one of our  recommendations. Interior’s comments are reproduced in appendix VI.
Interior agreed with our three recommendations for ensuring that NTTFI  can provide quality information to support management and program  oversight efforts.  Interior said that eliminating fields that do not serve an  identified purpose will reduce the large amount of missing and erroneous  data and noted that it will take steps to improve the quality of data by  updating the NTTFI coding guide.
Interior agreed with two of our recommendations for improving DMR and  disagreed with one.
Interior agreed with our recommendation to document when the  level of service for each road section was last evaluated. Interior  noted it would take this action for roads and bridges that have  been reconstructed or improved and for roads that have been  evaluated at a condition level of fair or better since the last  reporting cycle. Interior said that it is taking this approach because  it believes improvement to level of service can only occur with  reconstruction and not solely from road maintenance. This is a  good first step towards addressing our recommendation.   However, we continue to believe that Interior also needs to know  the level of service and needs to periodically evaluate and  document the evaluation date for all roads in order to effectively  identify and prioritize road maintenance needs.
Interior agreed with our recommendation to develop and maintain  documentation supporting unit costs of maintenance used to  estimate maintenance needs. Interior noted that it intends to take  this action for tribes it directly serves, which we believe is a good  first step towards addressing this recommendation. While we  understand that tribes not directly served by BIA may not have to  report documentation of maintenance costs, BIA should continue  to obtain information from all tribes or other sources through other  means that are available and document the unit-cost estimates for  maintenance of all BIA roads. This will enable Interior to develop  complete and reliable cost estimates for all BIA roads.
Interior disagreed with our recommendation to improve the DMR  by coordinating with tribal stakeholders to develop a process for  complete and accurate reporting of Road Maintenance Program  (RMP) funds expended for maintenance performed on BIA roads.  Interior stated that this action cannot be reasonably accomplished  as it conflicts with the intent of federal law and the minimum- reporting requirements when a tribal entity takes over the day-to- day actions and tasks of a program. In response to Interior’s  concerns we have revised our recommendation to clarify that  Interior should develop a reporting process that can be  implemented with existing authority. We continue to believe that  Interior can develop a reporting process for the RMP and could  request tribes with self-determination contracts and self- governance compacts to follow such a process and could  implement such a process for tribes that it serves directly. By  coordinating with tribes and encouraging their self-reporting of  RMP funds expended for maintenance as well as improving data  collected on RMP activities that Interior administers, Interior can  improve the reporting of maintenance performed on BIA roads and  would be better positioned to provide Congress with more  accurate and complete information for funding decisions.
Interior neither agreed nor disagreed with our recommendations to  provide guidance to BIE schools to collect data on student absences  related to road and weather conditions and to review the formula to fund  transportation at BIE schools and determine what adjustments are  needed. Nevertheless, Interior stated that it will explore the addition of a  field within its Native American Student Information System to capture  whether an individual student's absence is due to inclement weather or  road conditions.  In addition, Interior noted that it does not have authority  to make changes to the rule governing its formula to fund transportation  without proper engagement in a consultation process with tribes, but said  that it will take our recommendation under advisement. We continue to  believe that these recommendations are important for BIE to implement.
As previously noted, we recently placed Indian programs, including Indian  education, serving Indian tribes and their members on our High-Risk  Series. Given past and ongoing challenges, it is critical that BIE take  action to enhance student access to school. By facilitating data collection  on student absences related to roads and weather, BIE will be in a better  position to understand the extent and consider strategies to address the  effect of road and weather conditions on student attendance. Additionally,  consultation with tribes is fully consistent with our recommendation on the  transportation funding formula. By working with tribes and BIA on the  transportation funding formula, BIE will gain critical knowledge and  experience that will provide it the information needed to adjust a formula  that has not been adjusted in a decade.
We are sending copies of this report to the appropriate congressional  committees and the Secretaries of the Interior, Transportation, and  Education. In addition, the report is available at no charge on GAO’s  website at http://www.gao.gov.
If you or members of your staff have questions about this report, please  contact me at (202) 512-2834 or shear@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made major contributions to  this report are listed in appendix VII.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: We addressed the following objectives: (1) To what extent do the National  Tribal Transportation Facility Inventory (NTTFI) and Deferred  Maintenance Reporting (DMR) system provide useful data about road  conditions on tribal lands? (2) What challenges, if any, do stakeholders  face in improving and maintaining roads on tribal lands? (3) What is  known about the connection between road conditions on tribal lands and  school attendance as well as other aspects of school transportation?
To determine the extent to which the NTTFI and DMR systems provide  useful data on road conditions on tribal lands, we reviewed federal  regulations, strategic plans, performance reports, agency reports, industry  practices, guidance, policies, and system documentation pertaining to the  collection, coding, and use of both databases; conducted electronic data  testing, such as for completeness, out-of-range values, and logical  inconsistencies; attended a training workshop on NTTFI data entry; and  interviewed Federal Highway Administration (FHWA), Bureau of Indian  Affairs (BIA), and tribal officials about the systems. We analyzed the  NTTFI data as of September 2015—which was the most recent available  data at the time of our review—and the quarterly DMR system inventory  and road condition data for federal fiscal years 2009 through 2015. The  most recent data available was the first quarter 2016 DMR data, however,  we decided not to use it because we could not get full year data and we  wanted to ensure that the date of the most recent DMR data matched the  most recent NTTFI data we were able to obtain. To assess the usability of  the data, we reviewed the results of our electronic testing, interviewed  BIA officials regarding system controls (such as data system design,  monitoring, and edit checks) and other processes (such as cost  estimating practices) in place to promote data accuracy, consistency, and  completeness. We compared the information about each data system  design, monitoring, edit checks, and other processes to federal standards  for internal control.   We determined that these data were sufficiently  reliable for some purposes, such as the road section’s location, owner,  and road surface type (existing roads only) for the NTTFI, but not others,  as described in the report.
NTTFI data are part of BIA’s Road Inventory Field Database System  (RIFDS)—a broader database of BIA managed roads. To better  understand the overall system and data entry requirements, we attended  a RIFDS training workshop that focused on the process of entering and  deleting NTTFI data. The NTTFI data includes inventory, description, and  condition data for all Tribal Transportation Program (TTP) eligible roads,  bridges, and other transportation facilities in all 12 BIA Regions. Our  review included only roads (including paths and trails). We conducted  electronic testing of the following NTTFI data fields:
Average Daily Traffic Year
Existing Average Daily Traffic
Surface Condition Index (SCI)/ Wearing Surface Condition  To identify which road sections in the NTTFI are proposed and which are  existing, we used two data fields—the Construction Need and Existing  Surface Type fields. Road sections with either the Construction Need  data field equal to “4” (proposed) or the Existing Surface Type data field  equal to “0” (proposed) were classified as a proposed road section. Road  sections with neither the Construction Need data field equal to “4”  (proposed) nor the Existing Surface Type data field equal to “0” were  classified as existing. If both of those data fields were blank, we  categorized the road section as unknown. Our review did not include  ensuring that the road sections in the inventory met the current statutory  requirements for inclusion in the NTTFI, and we did not physically inspect  roads to assess the accuracy of road section length or surface type  entries.
The DMR system includes inventory and condition data for all BIA roads  in 10 of the 12 BIA Regions. There are no BIA roads in the Alaska and  Eastern Oklahoma BIA regions, according to BIA officials, so these  regions were not included in our assessment of DMR data. We conducted  electronic testing on the following DMR data fields:  To identify any challenges stakeholders face in improving and maintaining  roads on tribal lands, we reviewed relevant federal laws such as the  Intermodal Surface Transportation Efficiency Act of 1991;  Transportation  Equity Act for the 21st Century;  the Safe, Accountable, Flexible, Efficient  Transportation Equity Act: A Legacy for Users;  Moving Ahead for  Progress in the 21st Century Act (MAP-21); and Fixing America’s  Surface Transportation Act. We also reviewed the federal regulation,  guidance, and funding processes pertaining to the TTP and RMP.  We  reviewed both TTP and RMP program documentation including reports to  Congress on the program’s performance measures and program goals.  We analyzed FHWA budget justification data and BIA RMP funding data  for fiscal years 2009 through 2016 to understand the annual level of  funding for each program during those years. We also reviewed tribal  transportation documents for conducting road improvement and  maintenance, such as selected tribes’ program agreements (e.g., for  TTP), lists of tribal transportation projects and priority lists, and various  management plans.
We interviewed FHWA and BIA headquarters and regional officials to  gain a better understanding of the TTP and RMP programs and examine  how the agencies coordinate with tribes to maintain and improve roads on  tribal lands. We also interviewed federal, state, local, and tribal  transportation officials on how they plan, prioritize, and coordinate road  projects, address jurisdictional issues and National Environmental Policy  Act requirements,  and manage other factors affecting road maintenance  and improvement on tribal lands. We conducted site visits to 10 selected  schools and school districts and 7 transportation offices within the Navajo,  Pine Ridge, and Rosebud Indian Reservations. The Navajo Nation is  located in Arizona, New Mexico, and Utah and is within the BIA Navajo  Region; the Oglala Sioux and Rosebud Sioux Tribes are located in South  Dakota and are within the BIA Great Plains Region. While all 567  federally recognized tribes were considered for selection, these three  sites were chosen because they reflect factors such as different BIA  regions; considerable tribal and BIA road mileage; presence of Bureau of  Indian Education (BIE) schools; and different program agreements.  During our site visits, in addition to meeting with school, tribal, and  transportation officials, we observed road conditions first-hand, including  riding on school busses along their delivery routes. As part of one site  visit, we conducted a facilitated group discussion with 10 tribes from the  BIA Great Plains and Rocky Mountain Regions, including two tribes we  visited. Our site visits provide information and illustrative examples on a  range of road condition and student attendance issues on tribal lands but  are not generalizable to all tribal areas. We also attended four tribal  transportation-related conferences through which we met with various  tribal officials. We also met with tribal technical assistance experts and  representatives from national Indian associations such as the National  Congress of American Indians, Intertribal Transportation Association,  National Indian Education Association, and the National Indian Justice  Center.  Last, we obtained geospatial data from the Navajo Nation on  road ownership, road surface type, and road maintenance partnerships  for two school districts within the Navajo Nation. After analyzing the  geospatial data and partnership information, we developed maps and  provided those maps to the Navajo Nation and Coconino County  (Arizona) for them to review our analysis and validate that we developed  accurate maps.
To determine what is known about the connection between road  conditions on tribal lands and school attendance as well as school  transportation, we used a variety of methods. We reviewed relevant laws,  regulations, and guidance from the Department of Education (Education)  and Department of the Interior’s BIE. To provide national data about  student attendance including for Indians, we analyzed two Education data  sets—the Civil Rights Data Collection for school year 2013–14 and the  National Assessment of Educational Progress for 2015.   For both data  sets, we used the most recently available data and assessed reliability by  reviewing related documentation and interviewing knowledgeable agency  officials, among other steps. Based on these efforts, we determined that  these data were sufficiently reliable for our purposes.
We also interviewed Education and BIE officials on these issues and  conducted a literature review of national and international academic  studies written about factors that affect student attendance. Specifically,  we searched for (1) connections between road conditions on tribal lands  and school attendance in the United States and/or other countries; (2)  connections between road conditions and school attendance in the United  States and/or other countries; (3) factors connected with school  attendance in the United States for Indian students; or (4) factors  connected with school attendance, in general, in the United States. We  identified peer-reviewed studies published since 2000 through searches  in research databases, including the Education Resources Information  Center (ERIC), Scopus, and WorldCat. We also reviewed a list of studies  related to school attendance compiled and provided by the National  Library of Education of the Department of Education. Based on our  database searches and the list from Education, we reviewed abstracts  and introductions of studies, and determined that a total of 39 sources  were at least minimally relevant. We determined that 10 of the 39 identified studies were both methodologically sufficient and topically  relevant to the research objective. The 10 studies examined factors  connected with school attendance and absenteeism, which were  generally grouped into one or more of four categories: individual factors,  family factors, school factors, and environment or community factors,  where road conditions and related issues, such as adequate public  transportation, generally fell within the environment or community factor  category. We used a data collection instrument to consistently record  information about key findings related to the connection between road  condition and attendance from each relevant source.
Lastly, as part of our site visits with the three Tribal Nations noted above,  we selected ten BIE schools and public school districts to visit on those  reservations.  We selected schools and districts with at least 50 enrolled  students and similar student demographics—mostly Indian and mostly  low-income—and with school bus routes of varying road surface types  (i.e., paved, gravel, and earth). At these 10 schools and districts, we  collected available information on attendance, school bus routes, and  road conditions along school bus routes.  We interviewed school and  district officials, including superintendents, principals, transportation  directors, business managers, bus drivers, as well as tribal community  officials.  Topics of these interviews and related data requests  addressed reasons of student absences, conditions of roads serving the  school, and changes to school bus routes due to road conditions, among  others. We directly observed the road conditions on school bus routes by  riding on or following behind school vehicles such as buses and sports  utility vehicles. We compared this information with guidance from an  education forum and federal standards for internal control.  During our  site visits, we took photographs and videos of road conditions on tribal  lands, the equipment used to maintain and repair them, and vehicles the  schools use to transport students on those roads.  We also attended a  group discussion with tribal and education officials of the Oglala Sioux  Tribe at the request of a tribal education organization. The interviews and  literature results are not generalizable across all tribal nations;  nonetheless, they do provide qualitative and quantitative evidence on the  connection between road conditions on tribal lands and student  attendance. Tribal and other entities we interviewed or collected  information from for all objectives are listed in table 2.
We conducted this performance audit from December 2015 to May 2017,  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: NTTFI Road Miles Data by BIA Region, Owner, and Road Surface Type
paragraphs: The Bureau of Indian Affairs (BIA) uses the National Tribal Transportation  Facility Inventory (NTTFI) to document existing and proposed roads on  tribal lands that are eligible for Tribal Transportation Program (TTP)  funding.  According to our analysis, we found that the NTTFI identifies  over 147,000 existing road miles, over 13,000 proposed road miles for a  total of about 161,000 miles of existing and proposed roads on tribal  lands in the 12 BIA regions.
Of the existing roads identified in the NTTFI, about 40 percent are  identified as paved (concrete or bituminous), about 25 percent as gravel,  and about 35 percent as either earth or primitive type roads like two-track  or wagon trails. The majority of BIA- and tribal-owned roads are  identified as earth or primitive while state- and local-owned roads are  mostly identified as paved or gravel.
section_title: Appendix III: Road Ownership, Surface Type, and School Bus Route Maintenance Responsibility in Selected School Districts
paragraphs: Figures 11 through 13 include the rollover information for road ownership,  surface type, and school bus route maintenance responsibility in Page  and Tuba City Unified School Districts on the Navajo Nation in Arizona  (Corresponds to Interactive Fig. 4).
section_title: Appendix IV: Selected Examples of Partnerships for Road Improvement and Maintenance on Tribal Lands
paragraphs: Below are selected examples of partnerships between federal, state,  local, and tribal entities that primarily shared the costs to conduct road  maintenance and improvements on tribal lands (see table 5).
section_title: Appendix V: Select Strategies of Visited Schools to Mitigate Difficult Road Conditions
paragraphs: According to officials at the 10 schools and districts that we visited, they  or others have used several strategies to lessen the effect of road  conditions on tribal lands; these strategies aim to improve students’  access to attend school (see table 6).
section_title: Appendix VI: Comments from the Department of the Interior
section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact name above, Mike Armes (Assistant Director),  Aisha Cabrer (Analyst-in-Charge), Les Locke, Matt Saradjian, Irina  Carnevale, Georgeann Higgins, Jeff Malcolm, Sara Ann Moessbauer,  Melinda Cordero, Malika Rice, Cheryl Peterson, Jeanette Soares,  Geoffrey Hamilton, Elizabeth Sirois, Jerry Sandau, Mitchell B. Karpman,  David Blanding, Jr., Justin Fisher, Leia Dickerson, Melissa Bodeau,  Benjamin T. Licht, and Jon Melhus made key contributions to this report.  Jacques Arsenault and Theresa Perkins made key contributions to the  multimedia for this report.