Inaccuracies Limit the Usefulness of Some BIA Data on the Condition of Roads on Tribal Lands

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. 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. We found the DMR  data to be useful for identifying roads in the BIA inventory. 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. Stakeholders Face Various Challenges to Improving Roads on Tribal Lands, Although Partnerships Have Helped to Mitigate

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. For example, two adjacent school  districts within the Navajo Nation use many of the same roads for their  school bus routes. 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. Indian Students Have Higher Absence Rates, and Road Conditions Can Be a Barrier to School Attendance on Tribal Lands, Although Data Are Limited

		Indian Students Nationwide Have Higher Absence Rates than Non- Indian Students, but Research about the Effect of Road Conditions Is Limited

			Higher Absence Rates

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. Further, BIE has not provided guidance to its  schools regarding capturing reasons for absences related to roads and  weather. (See fig. 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. Many factors affect student attendance, among them the condition of  roads. 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. Interior agreed with two of our recommendations for improving DMR and  disagreed with one. We continue to  believe that these recommendations are important for BIE to implement. (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. Appendix II: NTTFI Road Miles Data by BIA Region, Owner, and Road Surface Type

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.
Why GAO Did This Study

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.

What GAO Found

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

What GAO Recommends

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.