2. Indian Affairs Offices Poor Recordkeeping and Coordination Threaten Impact of Tiwahe Initiative
U.S. Department of the Interior
Office of Inspector General Report No ER-018

3. Overview
Our focus was on two offices: the Office of Indian Services (OIS) and the Office of Self Governance (OSG) – both of which manage aspects of funding for American Indian and Alaska Native tribes, as well as the Office of the Assistant Secretary of Indian Affairs (AS-IA).
We reviewed the roles of these offices in distributing money to tribes for funding social services and child welfare programs through the initiative’s five year pilot program (FY 2015 through FY 2019)

4. Evaluation Objective
Our objective for the evaluation was to determine whether the Office of Indian Services (OIS) accurately distributed increased Tiwahe Initiative appropriations to Title IV tribes in fiscal years 2015 through 2017.

5. Scope
Consisted of a general review of the appropriations increase for the Tiwahe initiative during fiscal years 2015 to 2017.
We focused on the distributions of funds to Title IV tribes
We examined the accuracy of the distributions
We looked at how the Office of Self Governance maintained tribal records
We looked at internal controls
For comparison, we reviewed on a limited basis, funding for Title I tribes.

6. Brief Summary of Findings
We found that Tiwahe Initiative Funding was not properly distributed.
Title IV tribes received inaccurate funding during the initiative for two primary reasons:
The OIS applied the methodology for calculating tribes funding amounts to outdated Child Welfare and Social Services program funding levels, which were provided by the OSG in the FY 2014 Budget Justification
The OIS did not apply the funding methodology consistently when it calculated the distributions.

7. Specific Findings
Office of Self Governance did not publish accurate figures in the Budget Justifications
OSG did not consistently include yearly updates to social services and child welfare funds to account for changes to the Federal budget as part of the office’s annual contribution to the Budget Justifications
Tiwahe increase was based on 21.54% increase to 2014 ICWA funding and 8.07% increase to 2014 Social Services funding
OIS used the outdated budget numbers in their calculations, likely resulting in lower-than-accurate base fund amounts being used to calculate the funding increases for many of the individual Title IV tribes
OSG did consistently provide annual increases to the tribes’ total self-governance funds, identified in the Budget Justifications as the Total Self Governance Base.
OIG designed an estimate using tribal Self Governance Base data. We noted an average discrepancy of 10 percent between the Total Self Governance Base funding in the year a tribe’s Child Welfare and Social Services program funding amounts stopped being updated and the amounts reported in the FY 2014 Budget Justifications.
We estimate 73 out of the 87 that received Social Services funds and 70 out of the 85 that received Child Welfare funds—have been underfunded

8. Example
The Santa Clara Pueblo Tribe’s Total Self Governance Base funding in 2002 was $808,006.
Its Total Self Governance Base funding in the FY 2014 Budget Justifications was $1,097,892, approximately a 36 percent increase.
If we assume that this increase would be distributed equally across tribal programs to reflect year-to-year increases, that leaves Santa Clara with new base numbers of $74,732 for Child Welfare and $205,225 for Social Services.
If we apply the Tiwahe methodology to these corrected numbers, we get a different distribution
Child Welfare: $74,732 × = $16,067 ($4,223 increase) Social Services: $205,225 × = $16,562 ($4,372 increase)
Combined annual difference = $8,596

9. Specific Findings
Office of Indian Services considered different program budget lines for Title I tribes than for Title IV tribes
During the initial distribution, the Office of Indian Services considered different program budget lines depending on whether a tribe was Title I or Title IV, thus failing to consistently apply its own methodology when distributing funds to tribes.
OIS used ICWA and Social Services TPA numbers to calculate distribution to Title IV tribes.
OIS used ICWA, Social Services TPA numbers and CTGP Tables to calculate distribution to Title I tribes.
OSG stopped printing CTGP tables in the Budget Justifications in 2005, whereas Title I updated them every year.
The inconsistent application of the distribution methodology resulted in funding delays of approximately $830,000, across two reconciliations, to Title IV tribes.

10. Example
Title I Tribe Stockbridge-Munsee Community received $13,297 in ICWA funds despite not having any ICWA funding listed in the Budget Justifications TPA tables. Stockbridge-Munsee was funded purely on its CTGP figures.
Title IV Tribe, Kaw Tribe, only had Social Services and ICWA funds used in its calculation, despite a $261,285 CTGP budget.
Reprogramming to correct this error took 1.5 years and reduced the efficiency of the program,

11. This table shows the amounts the Office of Indian Services reprogrammed to 27 Title IV tribes in January 2017 to correct funding errors in the initial Tiwahe Initiative distribution.
Tribe
Social Services
Child Welfare
Total
Choctaw
$70,240 -
Coos Bay
14,588
$ 25,952
40,540
Coquille Indian Tribe
4,842
Cow Creek
10,492
15,074
25,566
Fond Du Lac
2,231
Grand Portage
9,546
Grand Ronde
44,992
Jemez, Pueblo of
6,755
Kaw
1,470
15,216
16,686
Metlakatla
13,342
23,646
36,988
Modoc Tribe of Oklahoma
2,582
12,620
15,202
Ohkay Owingeh
5,749
Osage
23,018
Quapaw Tribe of OK
2,242
Sac and Fox - OK
3,440
Saint Paul
4,294
Smith River
3,452
Taos Pueblo
5,479
Umatilla
20,180
43,826
Wampanoag
14,446
9,656
24,102
White Earth 84
Ysleta Del Sur
9,949
Ak-Chin
16,152
Ewiiaapaayp
13,006
Little River
16,876
North Fork
30,150
Seldovia
$273,413
$214,614
$488,027

12. OIG Recommendations Seven Recommendations for AS-IA:
Direct the OSG to work with tribes to track the components of the CTGP funding and publish these individual amounts each year in the BIA’s Budget Justifications
Direct the OSG to determine appropriate levels of Child Welfare and Social Services program funding that should have appeared in the FY 2014 Budget Justifications

13. OIG Recommendations
Direct the OIS to reapply its methodology and reconcile the Tiwahe funds
Direct the OSG to determine the actual funding levels of individual tribal programs and report them annually in the Budget Justifications
Direct the OSG to develop and implement a records management policy to track the annual funding for each program
Ensure that the OIS and OSG develop standard operating procedures, and formalize them in a memorandum of understanding or other document agreeing to work together and create a functional funding methodology for future distributions

14. OIG Recommendations
Direct the OIS and OSG to use Part 70, Chapter 3, of the Indian Affairs Manual (“Human Services Financial Assistance and Social Services Reporting”) as a guide to develop and implement a formal policy to address funding distributions at each office.

15. AS-IA Response to OIG Recommendations
Recommendation 1: Concur
Recommendation 2: Concur
Recommendation 3: Concur
Recommendation 4: Did Not Concur
Recommendation 5: Did Not Concur
Recommendation 6: Concur
Recommendation 7: Partial Concur

16. Report Conclusions We found that:
The Tiwahe initiative has so far distributed $20M in funding to eligible tribes to support Child Welfare and family stability as well as to promote and strengthen tribal communities
There are significant records management problems at the OSG along with poor execution of the funding methodology at the OIS as well as an absence of regular communication between the two offices
Failure to correct current practices at both offices will likely perpetuate inaccurate funding not only with the Tiwahe initiative but with other initiatives

17. Report Conclusions
Poor coordination between OSG and OIS along with the absence of internal policies will likely adversely impact the efficiency of business operations and have a measurable effect on the tribes the offices serve.
Recordkeeping issues identified with the Tiwahe initiative extend to other programs such as Aid to Tribal Government and without corrective action, OIS and OSG will not be prepared if Congress again offers funding distributions based on Tribal Priority Allocations records.

18. QUESTIONS