the approval of the application by the committee (or for Part B, evidence for community input), an assessment of the educational needs of the students to be served, a complete justification for, and description of, the activities to be performed by the grantee in meeting the needs, and budget projection broken out by major cost category.

Once grant awards have been made, projects are monitored and evaluated via a quarterly reporting system, using the telephone to follow-up problems encountered by grantees and on-site monitoring where necessary or desirable. Additionally each grantee is required by law to do an annual evaluation of his project. Based on continuous review of problems encountered there is a continual periodic updating of our application and reporting process; we have currently redesigned these forms and are submitting them through the OMB Circular A-102 procedure.

As you know, the provisions of the Indian Education Act require OIE to submit an annual evaluation report to Congress on the progress made by projects under the Act. The two major data sources for these reports are a national assessment survey of the management processes in Title IV projects and an evaluation of data compiled from the application/reporting system. Additionally, we have completed an effort to train the largest Title IV grantees to conduct their own evaluations on a more sophisticated level than has been achieved to date, and will extend this concept by preparing evaluation handbooks that can be used by all grantees in evaluating their projects. In order to raise the effectiveness of the OIE staff in assessing evaluations of individual projects, we are preparing a training program for all OIE project officers who perform project monitoring.

Finally, with respect to the targeting of Title IV funds to Indian children we have found approximately 150 instances of funds being used for children other than Indians, but we do not yet know how widespread this practice is. Where necessary, we have requested audits (from approximately 30 Title IV projects) from the HEW Audit Agency and hope to conduct extensive site visits. When this is complete we will have a better indication of the extent of the problem. At that time, if the problem is widespread, we will take corrective action through regulation changes and monitoring.

In view of the diverse nature of Title IV projects, the degree to which Title IV funds are used for directly improving educational opportunities for Indian children can be summed up as follows.

While many projects are educationally traditional in nature, many other projects have major components directed toward reinforcing cultural heritage or cultural awareness. Although we are aware that such projects represent a little explored facet of educational programming, we have funded these projects because we feel that these latter activities may be extremely important in breaking down some of the mutual hostility and lack of understanding between the Indian child and the school district. If direct educational progress is attempted in an atmosphere of distrust, failure may well be the outcome. Unfortunately, hard evaluation data demonstrating solid educational gains may take several years to obtain, but the alternative is to provide Federal funding to a school system which is not fully aware of the particular education needs of the Indian child and in which the Indian child is unaware of the ability of the school system to relate to his or her needs. As I have noted, the probability of failure under these conditions is quite high.

Another aspect of the evaluation process that should be considered is that the necessary prerequisite to a systematic project-by-project evaluation is a base of data which describes what the existing educational needs of Indian communities all over the country are. Once this needs inventory is established, the progress projects make can be measured. Since this needs inventory does not now exist, we are in the process of establishing it by conducting a needs assessment.

One of the major problems in conducting such a study is to insure that recently completed and valid regional or tribal needs assessments are not repeated. We are making every effort to identify these studies and limit the scope of our study to only those areas where previous studies are not applicable. When this study is complete, we hope to be able to draw a national portrait of the educational needs of Indians.

Question 3. You noted in your testimony before the Committee that "not all States have been able to negotiate for public library services on the reservation." Could you please expand on that comment?

Answer. On the basis of information provided to the Office of Indian Education, it is our understanding that the following are constraints in establishing library services on reservations:

Legal tribal requirements

To establish a library on a reservation, a formal resolution must be presented to and accepted by the tribal government.

Management and staffing by Indians

There is a lack of Indian librarians and technicians who could motivate and work with the tribal decision-makers to institute library services. Individuals who are not Indians are sometimes unacceptable as negotiators.

The recruitment and training of Indians as librarians (on college levels) has had a high drop-off rate, so progress has slowed in recruiting Indian librarians who would be able to establish and direct libraries and library projects on reservations.

Jurisdictional barriers

There are legal constraints to the State or county extending funds for library services to a reservation which is outside their jurisdiction boundaries. An example of this is the ruling of the North Dakota Attorney-General that an American Indian tribe is not a part of the State government and herefore, no direct grant can be made by the State agency to a tribe.

Administrative and attitudinal barriers

Indian communities may lack familiarity with the grant application and administration procedures. In the absence of technical expertise and grantsmanship skills, tribes may be hesitant to apply for program funds. At the program office level, this hesitancy may be interpreted as a lack of desire or ability to fulfill program requirements rather than as a need for technical assistance.

PARENTAL INVOLVEMENT

Question 1. Have you had any problems with school districts in carrying out the requirements in the Act for parental involvement? If so please describe those problems.

Answer. The Indian Education Act has been unique among Federally-funded programs in the degree to which parents are involved with the planning, implementation and evaluation of Federally supported projects; and with any change of this magnitude problems can be expected and, indeed, have been encountered. Basically, we have found three problems: interpretation of the provisions of the Act, and supporting regulations dealing with parent committees, and communication difficulties between parent committee members and district personnel.

The problems with interpretation generally take the form of an inquiry from a school district or a parent committee chairperson in which someone might ask, "Can the parent committee reject a proposal?" or "Does the parent committee have any selection role in obtaining staff to work on a Title IV project?" In cases like this, our Part A staff will respond with interpretations and technical assistance.

The far larger problem that we have encountered is that of severe communica tion difficulties between parent committee members and school district officials Based on the evaluation survey we recently completed, we feel one cause of the problem is that the educational terminology and the different meanings assigned to the same words by each group are quite different. Once clear indication of this is that at meetings between parent committees and school administrators, school administrators often fail to communicate to the Indian community in a meaningful, relevant manner. Thus, the two groups arrive at significantly different perceptions as to what was discussed at a joint meeting. We have concluded that before we can make any significant progress toward developing more effective projects, the communication difficulties must be solved.

However, we have also had many successes in parent committees working with school districts to plan and implement Title IV projects. Based on data resulting from the evaluation survey we recently completed, it appears that over seventyfive percent of parent committees are intimately involved in project operations, including such areas as determining educational needs, developing requirements for staff selections, budgeting and other administrative management and functions.

Question 2. Is your office working with Indian parent committees to advise them on their role under the Act? Do you believe that Federal funds should be available for the training of Indian parents to serve on advisory councils?

Answer. Yes, we are working with Indian parent committees to advise them of their role. We are also working with them to help solve the communication barriers discussed earlier.

We have sponsored, and will continue to sponsor, a series of conferences in various parts of the country to provide technical assistance to both Title IV grantees and parent committees. At these conferences, workshops dealing with the authority and responsibilities of parent committees are conducted.

In addition to the workshops, we are currently developing a media kit for parent committees. The purpose of this media kit is to provide essential information to all parent committees, including those that could not be reached by the conferences, regarding their role, their rights and responsibilities, in school districts and Title IV operations. The media kit is intended to clarify and define concepts which hinder communication.

Finally, in Fiscal Year 1975 we funded four Part B projects whose purpose is to train parent committees. These projects are being conducted by the Coalition of Indian Controlled School Boards, the Northern Cheyenne Tribe, the Sisseton Wahpeton Sioux Tribe, and Indian Education Training of Albuquerque, New Mexico. The total funding level for these projects is approximately $290,000.

With respect to the last part of your question, dealing with Federal support of parent committees, in accordance with the DHEW, USOE General Provisions for Program Administration, Title IV funds are also made available to parent committees for such purposes as mileage to and from meetings, baby sitting reimbursement and travel expenses to attend USOE-sponsored conferences.

Queston 3. What is your office doing to promote Indian controlled schools? Answer. The Office of Indian Education provides three services to Indian controlled schools: financial support through the Part A 10 percent setaside for nonpublic schools districts, direct Part B financial assistance, and technical assistance through a Part B grant to the Coalition of Indian Controlled School Boards. Financial support offered to Indian controlled schools helps defray the costs of meeting the special educational needs of Indian children attending these schools, and is not usually intended to be basic support. Part A, non-LEA support in Fiscal Year 1975 was $2,272,727 and direct Part B support to Indian controlled schools was $730,881 and included seven projects. The purpose of the Coalition grant is to provide legal and technical assistance to Indian controlled schools that may encounter difficulties in operating their systems.

ROLE OF THE OFFICE OF INDIAN EDUCATION

Question 1. Do you believe the Office of Indian Education should perform an advocacy function for Indians within the Office of Education?

Answer. Yes, we definitely believe we have a very important role to play as an advocate for Indians within the USOE. With the possible exception of certain provisions of Impact Aid, the Indian Education Act is the single program targeting funds directly to Indians, because they are Indian. For example, although Title I of the Elementary and Secondary Education Act provides funding to many Indian children, it does so on the basis of their inclusion as a member of an economically disadvantaged group. Consequently, the Title I thrust, as with the thrust of other USOE programs, is not directed toward a single minority group, but instead has focused on a particular set of educational problems. The administrative mechanism of the Indian Education Act can focus on the unique set of educational problems of Indian children and that capability places the Office of Indian Education in a unique position to act as an advocate for Indians.

Question 2. In your prepared statement there are references to several other OE programs which are serving Indian students. Does the O.I.E. work with the other bureaus within the OE to target funds under these programs for Indian students? Does the O.I.E. work with these other bureaus to monitor funds administered by those bureaus which are being used for Indian children?

Answer. We have recently completed an analysis of the targeting problems encountered by other USOE programs in providing funds to Indians. The major findings from this study have been identified and discussed in the testimony submitted to this Subcommittee. Using the results of this analysis, we are beginning to work with other USOE programs to insure that adequate targeting, monitoring, and technical assistance of projects directed toward Indians are accomplished. As examples of this coordination, we have been instrumental in helping a consortium

of States secure a Title V (Strengthening State Departments of Education) grant to examine ways of upgrading services provided by State departments of education to heavily impacted Indian districts by the Department of Education of the States in which these districts are located. Our OIE staff have served as readers of grant applications for several USOE programs. We completed an analysis of the bilingual education funding requirements and have been engaged in joint planning exercises with the administrators of the Bilingual Education Program to explore ways in which Indians can more fully participate in that program. To date, our coordination efforts have concentrated on the planning, targeting and application review functions, but as we progress I would envision more emphasis on the monitoring activities. In an effort to sensitize other OE programs to perceptions and needs at the local Indian community level, OIE staff people have worked with other OE programs in evaluating grants and contracts and providing technical input in intra-agency task forces.

Question 3. Are you applying Indian preference for hiring within the OIE? Do you believe that there should be such a rule within OIE and within OE in general? Answer. Currently, we do not apply Indian preference in our Office of Indian Education hiring practices. OIE requested of the DHEW General Counsel an opinion on whether OIE can apply Indian preference. This issue is currently under examination. If the law provides for such preference, it would be the legal obligation of the Office of Indian Education to see it applied.

Question 4. There seems to be a tremendous backlog of school construction needs for Indian children under Public Law 815. Could you describe how OE will use the funds appropriated for fiscal '76 under 815 to meet these needs? Will construction on reservations receive the same priority as construction in school districts off reservations? Does the OIE work with the Impact Aid Office with OE to design these priorities?

Answer. On the basis of information provided to the Office of Indian Education by the SAFA program, it is our understanding that P.L. 81-815 school construction assistance may be provided under Section 14(a) or 14 (b) for pupils who reside on Indian lands, or under Section 5 for pupils who reside on, or who reside with a parent employed on, Federal property (which included tax-exempt Indian trust land). A priority index based on relative urgency of need is established for each eligible application in accordance with 45 CFR 114.5 and 114.6 (Copy enclosed) regulations. These regulations were established prior to the creation of OIE.

All eligible, unfunded applications are ranked and funded in priority order by section of the Act. P.L. 81-815 funds will be allocated to the various sections of the Act in accordance with the fiscal 1976 Appropriation language. That portion of the appropriation which may be allocated to Section 14 will be distributed as far down the Section 14 priority list (beginning with that application having the highest priority) as available funds will reach. Similarly, Section 5 funds will be distributed as far down the Section 5 priority list as they will reach. Had H.R. 5901 been approved $7.875 million would have been available for Section 14 applications and $7.125 for Section 5 applications.

HIGHER EDUCATION

Question. Your testimony mentions that colleges in various States are receiving funds under Title III of the Higher Education Act for American Indian programs and that Indian controlled community colleges are being funded through these other colleges. Your testimony also notes that Indian controlled community colleges are also receiving direct grants under Title III. Why are the Indian controlled colleges receiving grants both directly and through other colleges? Do you believe that there should be a change so that Indian controlled colleges will receive all their funds directly?

Answer. As a result of consultation with the Higher Education Program Office we have been advised that Developing Institutions support to Indiancontrolled Community Colleges is in the nature of both direct aid and indirect aid through other institutions. The question whether it might be more appropriate to provide direct grants only to Indian-controlled colleges has been raised.

The Title III program is an institutional support program designed to strengthen developing colleges through funding programs in faculty growth, curriculum improvement, administrative development and student services. Grants are made to institutions to help them to develop the basic strengths needed to attain secure status. Under this program, institutions form consortiums or cooperative arrangements under which they participate. An institution may submit an

application for support from a consortium of institutions established to achieve a specific goal. Although only one institution is considered as a grantee, there are other developing institutions participating in the consortium who benefit greatly from participation in the Title III program. The Title III program staff feels strongly that the current option to participate as either a grantee or as a participant in a consortium be maintained. Clearly it allows greater flexibility for a developing institution seeking support under the Developing Institution Program. RELATIONSHIP WITH THE BUREAU OF INDIAN AFFAIRS

Question 1a. What is the Office of Education doing to monitor the expenditure of the $17.5 million transferred to BIA for compensatory education programs under Title I of the Elementary and Secondary Education Act?

Answer. According to the Title I program officer, each year a team of at least two people conduct on-site program reviews of the BIA Title I projects. This includes a review of a sample of projects at the school building level as well as the BIA Title I management unit at the headquarters level.

The scope of the review includes all compliance requirements applicable to the BIA and the management techniques employed. Findings and recommendations for improvement resulting from each review are transmitted to BIA officials.

In addition, technical assistance and advice is provided to BIA on a continuing basis through conferences, correspondence and telephone communication. Question b. What is OE doing to monitor the expenditure by BIA of the other Title monies (approximately $2.5 million) being transferred to BIA under the other Title programs?

Answer. According to the Office of Bilingual Education, P.L. 93-380 S722 (b) authorizes the transfer of monies to the Secretary of Interior to carry out programs of bilingual education for children on Indian reservations served by elementary and secondary schools for Indian children operated or funded by the Department of Interior.

To date, all projects which are funded in this manner undergo the same monitoring (financial and programmatic) procedures which are applied to other Title VII programs.

Routine procedure is as follows: Financial and programmatic reports are submitted to the Grants and Procurements Management Division, which then forwards copies to bilingual staff. If there are discrepancies in the financial area of the report, the responsible staff person in Grants and Procurements Management Division contacts the appropriate BIA people, and the school district directly. To date the only discrepancies which have appeared have been mathematical errors. If a problem appears on the programmatic review, the responsible Title VII project monitor contacts the Grants and Procurement Management Division so that they may deal directly with the local educational agency to rectify any problems in this area.

Internal Title VII evaluation occurs when the project monitor makes a site visit. Of the nine Title VII projects funded through BIA channels, two were continuations, and seven were new grants. Four of the new projects were visited. A fifth project in Alaska was scheduled to be visited, but the trip was cancelled because of inclement weather, and could not be rescheduled before the application and funding process began. The sixth, in Florida, was funded with supplemental monies. The staff travel schedule had been worked out prior to the funding of the project. The seventh project was not scheduled to be visited, as were neither of the two continuations. Please note that because of staff and financial limitations it has been possible for us to site visit new projects only.

Upon return, project monitors then write a statement of their findings and make recommendations on situations within the programs which need to be changed or rectified. These recommendations are generally well received and complied with.

Answer 2. According to the Bureau of Education for the Handicapped, a State Plan officer in the Aid-to-States Branch of the Bureau of Education for the Handicapped, in addition to other duties, is assigned specifically to BIA. The assigned State Plan Officer provides technical assistance as the BIA plans projected activities; answering questions and providing guidance concerning application of EHA Part B to the planned programs. The State Plan Amendment, submitted pursuant to Part B, EHA, is reviewed by the State Plan Oncer who gives both oral and written comments based on established review procedures. Following this review, site visits might include local activities funded by EMA, 62-746-76——6