page 5/recommendations, Minnesota Chippewa Tribe Indian tribe. Justification for this position is available in the JOM study commissioned by the Tribe and conducted on the six reservations. The study results and report will be made available to the contractor for the national study, the National Indian Education Association. 17. The Minnesota Chippewa Tribe recommends a legislative change be considered in Title IV, the Indian Education Act, P.L. 92-318, in that the Tribe recommends the Title IV fund available under Part A of the act be contracted to Tribes for the administration of and dissemination to (of funds) the Local Educational agencies. 18. The Minnesota Chippewa Tribe recommend Title IV interpretation of rules and regulations be in writing and disseminated on a regular basis to Indian tribes and organizations. The oral interpretation presently carried out by Part A, Title IV staff causes confusion between tribal groups and LEA representatives. 19. Title IV rules and regulations ought to be revised to include "definition of teacher", further, parent committee eligibility requirements shoudl be clearly stated regarding eligibility of white parents of Indian children, a clear definition of "foster parent" is needed and additionally the rules and regulations ought to limit teacher voting participation for parent committee members to a specific percentage point of not more than ten percent (10%) of the total voting constituency. page 6/recommendations, Minnesota Chippewa Tribe 20. The Minnesota Chippewa Tribe recommends the regulations for Title IV be changed to show Indian Tribes' guidelines for tribal elections as the recommended way to elect Parent Committees and further, that Indian tribes be designated as the Official election board for Title IV eligible districts within their jursidiction. 21. Title IV rules and regulations should state "there shall be annual elections" (of parent committees); as the rules are presently stated regarding elections, it is not clear to Parent committees and LEA's that yearly elections must be held if the proposal cycle requirements are to be met, in the public hearings must be held each year after which the committee is to be elected. 22. The authority of the Parent committee should be clearly defined regarding parent committee recommendations and basic guidelines as promulgated by parent committees on LEA personnel selections for Title IV positions. 23. The Tribe recommends Title IV Washington Office be instructed by Congress to write and disseminate a "layman's" version of the rules and regulations for Part A and B and C of the Indian Education Act. 24. As HEW permits under its regulations, a written interpretation of the rules and regulations show a clear mentod of automatic carry-over provisions for Title IV fiscal year-end funds. If page 7/recommendations, Minnesota Chippewa Tribe HEW regulations do not permit automatic carry-over provisions the Office of Indian Education should be directed to study HEW regulations to permit a change to allow such a procedure. 25. Indian preference interpretation by the Office of Indian Education as being appropriate or inappropriate for Title IV personnel be released through the Federal Register mechanism with the necessary supporting data. 26. The Office of Indian Education should be instructed by Congress to promulgate measures for the LEA's to provide documentation signed by Parent Committee members showing spending of Title IV funds are carried out as stated in the proposal or revised proposal. 27. The Minnesota Chippewa Tribe recommends congress instruct the Office of Indian Education to show consistency within the Office of Indian Education regarding interpretations of the rules and regulations. For example, recent rules and regulations interpretation as provided by the present acting manager of Part A are from time to time inconsistent with previous interpretations as promulgated by the past manager of Part A. These inconsistencies cause anguish, confusion and hardship at the tribal, parent committee and LEA level. 28. The Tribe recommends the Office of Indian Education offer a clear written interpretation regarding precedence of the LEA or the parent committee on personnel recommendations for Title IV positions. page 8/recommendations, Minnesota Chippewa Tribe 29. The Tribe recommends the Office of Indian Education be instructed to adhere to Part B, Title IV intent of preference to tribes based on need rather than the actual practice of looking at other federal funding dollars available (to the Tribes) and basing grant allocation on the federal funding dollar information. 30. For all appropriate sections (a, B and C), the Office of Indian Education be directed to disseminate proposal approvals and disapprovals procedures to Indian tribes and organizations and through the Federal Register in order to document proper procedures are followed at the Washington office for proposal cycles. Appeal procedures ought to be clearly defined. If no appeal procedures exist the Minnesota Chippewa Tribe recommends appeal procedures be implemented. 31. The Tribe recommends that teh SEA, LEA level and where appropriate other government levels be instructed to show the actual benefits each organization receives from the Indian children body count. Comparison ought to be made with these actual dollars brought in by Indian children to the tax dollar brought by non-Indian children. The dollars so allocated ought to show total budget breakdown figures. THE FOLLOWING IS A SUMMARY OF THE COMMENTS, SUGGESTIONS, AND WE FEEL THE EXPANSION OF THE REGULATIONS TO INCLUDE EDUCATIONAL SECTION 403.12. WE FEEL THAT THE WORDING "FROM EARLY CHILD- SECTION 403.13. WE OBJECT TO THE INCLUSION OF "OPERATIONAL SUP- SECTION 403.31. WE MOST STRENOUSLY DISAGREE AND OBJECT TO THAT |