Detailed Information on the
Indian Education Grants to Local Educational Agencies Assessment

Implement a system to collect, review, analyze and publicly report grantee-level student achievement data.

Use performance information obtained through the new performance measures tracking system to identify areas that could benefit from technical assistance, and develop options that would address these issues.

Work with Congress to address statutory requirements that have made the program vulnerable to abuse and limited its ability to significantly impact the educational outcomes of Indian students.

Complete and post six web-based training sessions intended for grantees.

Refine program efficiency measure to assess the cost of achieving key program outcomes.

Measure: Percentage of fourth-grade Indian students scoring at or above Basic in reading on the NAEP.

Explanation:A baseline was set using 2005 NAEP data, which includes an oversampling of Indian students. Targets were established using the baseline plus a 2 percentage point increase for each NAEP administration.

Measure: Percentage of fourth-grade Indian students scoring at or above Basic in mathematics on the NAEP.

Explanation:A baseline was set using 2005 NAEP data, which includes an oversampling of Indian students. Targets were established using the baseline plus a 2 percentage point increase for each NAEP administration.

Measure: Percentage of eighth-grade Indian students scoring at or above Basic in reading on the NAEP.

Explanation:A baseline was set using 2005 NAEP data, which includes an oversampling of Indian students. Targets were established using the baseline plus a 2 percentage point increase for each NAEP administration.

Measure: Percentage of eighth-grade Indian students scoring at or above Basic in mathematics on the NAEP.

Explanation:A baseline was set using 2005 NAEP data, which includes an oversampling of Indian students. Targets were established using the baseline plus a 2 percentage point increase for each NAEP administration.

Measure: The percentage of Indian students in grades 3-8 meeting State performance standards by scoring at the proficient or advanced levels in reading on State assessments.

Explanation:The baseline was calculated using 2003-04 CSPR assessment data and performance targets were established to reflect progress toward the statutory goal of 100 percent proficiency in reading by SY 2013-2014. For the calculation of the actual data, the percentages were derived by aggregating Indian student data in reading across grade levels and across all states.

Measure: The percentage of Indian students in grades 3-8 meeting State performance standards by scoring at the proficient or advanced levels in mathematics on State assessments.

Explanation:The baseline was calculated using 2003-04 CSPR assessment data and performance targets were established to reflect progress toward the statutory goal of 100 percent proficiency in mathematics by SY 2013-2014. For the calculation of the actual data, the percentages were derived by aggregating Indian student data in mathematics across grade levels and across all states.

Measure: The difference between the percentage of Indian students in grades 3-8 scoring at the proficient or advanced levels in reading on State assessments and the percentage of all students scoring at those levels.

Explanation:This measure focuses on the program goal of closing achievement gaps in reading between Indian students and other students. The baseline difference was calculated by aggregating Indian student achievement data across grade levels and across all states compared to achievement data for all students across grade levels and across states.

Measure: The difference between the percentage of Indian students in grades 3-8 scoring at the proficient or advanced levels in mathematics on State assessments and the percentage of all students scoring at those levels.

Explanation:This measure focuses on the program goal of closing achievement gaps in mathematics between Indian students and other students.

Measure: Percentage of Indian students who graduate from high school.

Explanation:The graduation rate data reported on Consolidated State Performance Reports lags by one year. For example on the 2004-05 CSPR, graduation rates will be reported for the 2003-04 SY. Not all States reported graduation rate data for the American Indian/Alaskan Native subgroup. Only 37 States reported data for 2002-03, 44 for 2003-04, and 43 for 2004-05. Numbers are derived by averaging state percentages. The targets were established using the goal of attaining a 90 percent graduation rate by 2014 for Indian students.

Measure: Percentage of funds used prior to grant closeout by formula grantees.

Explanation:Data are calculated using the percentage of formula grant funds that remain unspent at the end of the five years and must be returned to the Department of the Treasury. Baseline data represent grants that were awarded in FY 2001 in the amount of $92,765,000.00 and of these funds $5,701,000 expired in FY 2006, which is equivalent to 6.15 percent of funds remaining or 93.85 percent of funds used by grantees. The established targets increase by 1.25 percent each year to reach a goal of 100 percent by 2011.

Is the program purpose clear?

Explanation: The purpose of the program is to assist local educational agencies (LEAs) in providing Indian students with educational services that both address their unique educational and culturally related academic needs and help them achieve to the same challenging State performance standards expected of all students. Program services include activities such as incorporation of Native cultural elements in social studies classes; after-school tutoring and mentoring activities that provide instruction in Native languages, arts, and music; development of curricula that incorporate Native elements and are aligned with State standards; and conducting outreach to Native parents to provide strategies for helping their children with schoolwork.

Evidence: Elementary and Secondary Education Act (ESEA) Sec. 7111- Purpose of the Indian Education Formula Grants to Local Educational Agencies program.

Does the program address a specific and existing problem, interest, or need?

Explanation: The Federal Government maintains a special interest in the education of Indian students based on a unique relationship between the Federal Government and Indian peoples, as established through Federal treaties, statutes, and the US Constitution. In addition, the program addresses the historic problem of low achievement among Indian students. Although there is evidence showing some improvement in Indian students' academic outcomes, these students continue to be subject to significant risk factors that threaten their ability to improve their academic achievement and their general well-being. For example, the number of Indian students enrolling in colleges and universities has more than doubled in the last 25 years, but the National Assessment of Educational Progress (NAEP) shows persistent achievement gaps between Indian and white students. This program provides additional resources to local educational agencies to provide high-quality elementary and secondary educational programs for Indian students.

Evidence: Presidential Executive Order 13336 on American Indian and Alaska Native Education; Freeman, C., and Fox. M. (2005). Status and Trends in the Education of American Indians and Alaska Natives (NCES 2005-108). U.S. Department of Education, National Center for Education Statistics. Washington, DC: U.S. Government Printing Office.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: This is the major Federal formula program that provides resources directly to LEAs (or, in some cases, tribes) that serve Indian students for the specific purpose of improving the educational programs in the public schools that serve them. Although the Bureau of Indian Education (BIE) receives funding for education purposes, the great majority of Indian students (approx. 93 percent) are enrolled in public schools; only 7 percent are enrolled in BIE schools. The availability of State and local resources for Indian education programs varies widely. While some States, such as Montana, devote resources to Indian education specifically, not every State that enrolls Indian students does so. The BIE-administered Johnson-O'Malley program authorizes similar services for Indian students enrolled in public education systems. However, Johnson-O'Malley serves a somewhat different population of students (only students who are at least quarter-blood members of federally recognized tribes) and the program is structured differently. Under Johnson-O'Malley, funds flow through tribal authorities rather than to public school systems directly, and parents have final say over the services to be provided with program funds. In addition, although a large proportion of Impact Aid funds benefit Indian students (almost half of FY2007 funds under the Impact Aid-Basic Support Payments program go to LEAs serving Indian students), the purpose of the program is to replace districts' revenues for the burden of educating federally connected children, not improving academic outcomes for Indian students.

Evidence: Freeman, C., and Fox. M. (2005). Status and Trends in the Education of American Indians and Alaska Natives (NCES 2005-108). U.S. Department of Education, National Center for Education Statistics. Washington, DC: U.S. Government Printing Office.; U.S. Department of the Interior, Bureau of Indian Affairs, Office of Indian Education Programs (OIEP), unpublished data, 2003-04.; National Center for Education Statistics Common Core of Data (CCD); 2000 Census; Montana "Indian Education for All" Act; Johnson-O'Malley Act.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: There is no major evidence that the program contains flaws that limit its effectiveness or efficiency. The program is aligned with the principles of No Child Left Behind (NCLB), and recipients are subject to the same accountability requirements as are LEAs under Title I and other Department programs. In keeping with the purpose of the program to provide Indian students with culturally appropriate instruction, funds flow directly to local school systems, parents and stakeholders must be consulted in the design and implementation of the program, and recipients have flexibility as to how to use grant funds. However, there are some provisions of the statute that might be considered problematic and that should be reconsidered when the program comes up for reauthorization. For one thing, grants to LEAs can be as small as $3,000, and can flow to districts that have as few as one Indian child enrolled. It is unclear whether meaningful activities can be carried out with such a small amount of funding and whether it is an efficient use of resources to make grants to LEAs with only a small number of eligible children. Second, the statute's definition of eligible Indian students is broad, and allows Indian students who might not otherwise receive Indian education services to benefit from the program; potentially making this program vulnerable to abuse. Third, the "integration of services" authorization in the statute is poorly designed and seldom used, and should be reviewed during reauthorization.

Evidence: ESEA Sec. 7111- Indian Education Program purpose; ESEA Sec. 7112-Grants to local educational agencies and tribes (specifies grant awards must be made to LEAs, or to Tribes if an LEA does not establish a committee that includes representatives of Indian parents and teachers); ESEA Sec. 7114-Applications, subsection (c) requires consultation with community members and parents; ESEA Sec. 7113-Amount of grants specifies minimum grant size; ESEA Sec. 7116- Integration of Services Authorized.

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: Funds flow directly to LEAs (or tribes) that enroll Indian children (as defined in the statute itself), and the purpose of the funds is to provide services to eligible Indian students. The program has a supplement not supplant provision, ensuring that LEAs contribute their share of resources to educate the Indian children enrolled in their public schools. The flow of funds directly to LEAs helps ensure that Indian communities and parents are involved in making decisions about the programs that will address the academic needs of their children in culturally appropriate ways. However, the formula does yield a large number of small grants under $20,000 (approximately 20 percent of all grants), which may limit the extent and comprehensiveness of the services a recipient can offer. To ensure that grants benefit eligible students, the Department has instituted several requirements. Grantees are required to submit to the Department forms, signed by committee members, certifying the local Indian Parent Committee participated in the development of the grant proposal. Applicants must submit a detailed budget that identifies and justifies all project costs. Applications must include a needs assessment (supported by student academic achievement data) and descriptions of the activities the applicant proposes (and associated costs). Progress reports must also include student academic achievement data to document grantee progress in meeting program objectives. All grantees must provide the same data regardless of the grant size. Program monitoring includes review of all student achievement data submitted and discussion of the use of program funds.

Evidence: ESEA Sec. 7112 (Grants to local educational agencies) specifies that grant awards must be made to LEAs (or to Tribes if an LEA does not establish a committee that includes representatives of Indian parents and teachers); ESEA Sec. 7112 (Grants to local educational agencies) and Sec. 7113 (Amount of grants) describe the process for making allocations to recipients; ESEA Sec. 7114 (Applications) subsection (c)(1) requires recipients to use program funds to supplement funds the recipient already provides for educating Indian students, and not to use Federal program funds to provide those services instead; Indian Education Program FY2007 Application for formula grants to local educational agencies; US Department of Education Office of Indian Education monitoring plan.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The Department has established a number of long-term measures that focus on Indian students' academic achievement over time as measured by (1) the National Assessment of Educational Progress (NAEP) and (2) State assessments. The indicators measure Indian students' reading and mathematics achievement on the 4th- and 8th-grade NAEP, the performance of Indian students in grades 3-8 on State assessments in reading and mathematics, and the difference in performance between Indian students and all students on those assessments. Another indicator measures Indian students' high school graduation rates. In order to ensure that the Department has adequate and reliable data on Indian students' performance, the Department has used National Activities funds to ensure that the NAEP includes a sufficient number of Indian students.

Evidence: Department of Education Fiscal Year 2008 Justifications of Appropriation Estimates to the Congress; measures tab.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The Department has established baseline and biennial targets for increasing proficiency in reading and mathematics on the 4th- and 8th- grade National Assessment of Educational Progress (NAEP). The 2005 NAEP administration, which included an oversampling of Indian students, provides the first reliable estimates of reading and mathematics achievement for this population and also provides sound baseline data for the program's long-term measures. The target increment of two percentage points per NAEP administration was based on a review of NAEP trend data for comparable student populations, such as low-income students (those eligible for free or reduced price lunch). These data show that between 2003 and 2005, the percentage of low-income 4th-grade students who scored at or above basic in reading increased by one percentage point. The mathematics data show that the percentage of low-income 8th-grade students who scored at or above basic increased by three percentage points between 2003 and 2005. These data show that a two-percentage point increase on the NAEP assessment is a realistic target. Following receipt of the 2007 NAEP data, expected to be available in the summer of 2008, the Department will have sufficient data on Indian student performance to assess the appropriateness of the targets for the four NAEP measures and, if necessary, revise the targets. The Department has also established baselines and targets for increasing Indian students' proficiency in reading and mathematics and reducing the achievement gap in both subjects, as measured through State assessments. The targets are consistent with the statutory goal of 100 percent proficiency in reading and mathematics for all students by 2014. Further, the Department has determined a baseline and targets for increasing the percentage of Indian students who graduate from high school to reflect a goal of 90 percent by 2014. Unlike other measures of achievement, NCLB does not require graduation rates to move toward a specific goal (such as reaching 100 percent by the year 2014) or to be disaggregated by subgroup. Therefore, as part of developing a graduation rate target for Indian students, the Department reviewed State graduation rates and found considerable variation in definitions, calculations, and targets, ranging from 50 percent to 95 percent. Given this variability, the Department has determined that a graduation rate goal of 90 percent by 2014 is a realistic target. As States continue, under the 2005 National Governors Association's Compact on State High School Graduation Rate Data, to adopt a common graduation rate definition and to build their capacity to collect and report accurate graduation data, the Department will assess the appropriateness of the current graduation rate goal of 90 percent by 2014 and, if necessary, revise the target.

Evidence: Measures tab; CSPR; National Governors Association. Graduation Counts: A Report of the National Governors Association Task Force on State High School Graduation Data (Washington, DC: 2005). http://www.nga.org/Files/pdf/0507GRAD.PDF

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The Department has established a number of annual measures that focus on Indian students' academic achievement on annual State assessments to demonstrate that over time the program is helping to improve Indian student achievement. These measures are aligned with the NCLB directive to school systems to close the achievement gap and ensure that all students meet standards of academic proficiency by school year 2013-2014. State assessments are used to track students' academic progress toward that goal through the use of various instruments that are aligned with State academic standards. The annual measures track the performance of Indian students in grades 3-8 on State reading and mathematics assessments, and the difference in performance between Indian students and all students on those assessments. Another indicator measures Indian students' high school graduation rates. The Department also has established an efficiency measure to track the number of grantees that receive late grant awards due to administrative error. Program data show that, in FY 2005, one application was not funded due to administrative error and, in FY 2006, this number was reduced to zero. Based on the negligible number of errors, the Department is in the process of developing a second efficiency measure that is more closely related to program outcomes. The Department is considering a measure focused on increasing the percentage of funds used by grantees prior to the grant closeout. By monitoring unspent grant funds throughout the grant period, the Department can assist grantees in allocating all available funds prior to the end of the grant period and more effectively serve the educational needs of Indian students. The Department is assessing the feasibility of this new measure and plans to make a final decision on the measure and develop a baseline and targets during the summer of 2007.

Evidence: Measures tab

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The Department has determined baseline and annual targets for increasing proficiency in reading and mathematics and reducing the achievement gap in both subjects. The targets are consistent with the statutory program goal of 100 percent proficiency in reading and math for all students by 2014. Baseline data were derived from State assessment results reported to the Department for the 2003-04, 2004-05, and 2005-06 school years. Additionally, the Department has established a baseline and targets for increasing the percentage of Indian students who graduate from high school to reflect a goal of 90 percent by 2014. Unlike other measures of achievement, NCLB does not require graduation rates to move toward a specific goal (such as reaching 100 percent by the year 2014) or to be disaggregated by subgroup. Therefore, as part of developing a graduation rate target for Indian students, the Department reviewed State graduation rates and found considerable variation in definitions, calculations, and targets, ranging from 50 percent to 95 percent. Given this variability among States, the Department has determined that a graduation rate goal of 90 percent by 2014 is a realistic target. As States continue, under the 2005 National Governors Association's Compact on State High School Graduation Rate Data, to adopt a common graduation rate definition and to build their capacity to collect and report accurate graduation data, the Department will assess the appropriateness of the current graduation rate goal of 90 percent by 2014 and, if necessary, revise the target.

Evidence: Measures tab; CSPR; National Governors Association. Graduation Counts: A Report of the National Governors Association Task Force on State High School Graduation Data (Washington, DC: 2005). http://www.nga.org/Files/pdf/0507GRAD.PDF

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: Recipients must adopt program indicators in their applications and report performance data annually. A review of a random sample of 10 percent of the approximately 1,200 grantees showed that in 2006 approximately 97 percent of grantees reported complete performance data on time. The program office conducts regional technical assistance workshops each year that include sessions on indicators and performance data. The Bureau of Indian Education (BIE), a major Federal partner, has adopted the same program indicators that LEAs must adopt. Although program recipients are LEAs rather than States, the program is also working with a group of State Chiefs from States with large numbers of Indian students to enhance collaboration and communication on NCLB implementation issues concerning the education of Indian students attending Federal, State, tribal, and local schools.

Evidence: Indian Education Program FY2007 Application for formula grants to local educational agencies; grantee applications; BIE Memorandum of Understanding; CCSSO Indian Education Group Conference Proceedings (available at http://www.ccsso.org/content/pdfs/StrengtheningPartnershipsProceedings.pdf); National Advisory Council on Indian Education (NACIE, authorized under ESEA Sec. 7141) Federal Register notices and reports to Congress.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: The program has not been independently evaluated in many years. However, the Department is investing most of its evaluation resources to ensure that the National Assessment of Educational Progress (NAEP) includes a sufficient number of Indian students. The NAEP data will not provide information on program performance directly, but it will provide reliable data on the academic performance of Indian students in general. From 2002-2004, the Department conducted a study to determine the feasibility of conducting a quantitative evaluation on the effects of culturally based interventions in Indian education. The Department determined that it is not feasible to conduct such an evaluation at this time, given the difficulty of defining culturally based education in a measurable way, the lack of research models on Indian education that would meet definitions of scientifically based research, and the small size of the Indian student population.

Evidence:

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: The Administration, due to budget constraints, is requesting level funding, rather than a budget linked to achievement of specific objectives. However, the Department has satisfied the second part of this question in that the Department's budget submissions show the full cost of the program (including S&E).

Evidence:

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: In order to devote a larger share of resources to program performance activities, the program office restructured staff assignments in late 2004. Currently, a small team serves as a single point of contact for grantees on grant management issues (such as accessing grant funds and complying with EDGAR requirements), leaving a larger share of the staff to monitor grantee progress towards meeting performance goals and providing technical assistance on issues pertaining to program improvement. The Department is also making a significant investment to ensure that NAEP includes a sufficient number of Indian students and is able to provide valid and reliable data for this population. In addition, the program office has developed an automated system to streamline the grant application process and collect data on grantee performance for the large number of grantees funded by this program.

Evidence: Indian Education Program FY2007 Application for formula grants to local educational agencies; National Assessment of Educational Progress (NAEP) website on National Indian Education Study (http://nces.ed.gov/nationsreportcard/studies/nies.asp); Indian Education FY2007 National Activities Plan; Concept of Operations document; Task Order 4 of the Education Data Exchange Network Operation, Maintenance and Enhancement (EDEN OME) Contract (ED-05-PO-1299).

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The Department collects annual performance reports that provide implementation information and student performance data. Grantee project plans are reviewed to ensure that plans are appropriate, specific, and address performance objectives. Program staff review grantee performance data to determine whether grantees are on track towards meeting performance objectives. A review of a random sample of 10 percent of grantees showed that in 2006 approximately 97 percent of grantees reported complete performance data on time. The Department uses the information contained in the reports to determine priorities for technical assistance at the program and grantee level. One of the current priorities is assisting grantees in obtaining and using disaggregated Indian student data from statewide assessments to determine whether Indian students are on track towards meeting State achievement standards.

Evidence: US Department of Education's Office Indian Education monitoring plan; grantee applications (performance reporting section).

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: The Department of Education's managers, in their employee performance plans, are held accountable for specific actions tied to improving program performance and timeliness of actions. The Department monitors grantees to ensure that expenditures are appropriate and performance is adequate, and requires grantees to take corrective action when needed. Further, the Department reviews grantees' compliance with maintenance-of-effort requirements, and decreases grant awards when recipients fail to maintain the level of local funding devoted to providing educational services to Indian students.

Evidence: EDPAS plans; US Department of Education Office of Indian Education monitoring plan.

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: Funds are obligated within the timeframes set out by Department schedules and used for the purposes intended. The program office monitors grantee budgets and expenditures, and reviews grantee audit reports. As part of the monitoring process, the program office also reviews grantee data on numbers of eligible Indian students and recovers excessive grant funds awarded due to errors in those counts.

Evidence: US Department of Education Office of Indian Education monitoring plan; US Department of Education Grants Administration and Payment System (GAPS) records.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The Department has developed a new efficiency measure, including a baseline and targets, focused on increasing the percentage of funds used prior to the grant closeout by the program's formula grantees. By monitoring unspent grant funds throughout the grant period, the Department will be able to assist grantees in allocating all available funds prior to the end of the grant period and more effectively serving the educational needs of Indian students. The Department also is working to provide more accurate and timely reporting of performance data through the new Indian Education web-based application and performance system, which is integrated with the Department's EDFacts system. Through this new performance system, the Department will be better able to assist States in obtaining and disaggregating student data to determine the degree of progress in meeting State achievement standards. Several features of the new web-based system will help to improve the quality and timeliness of reporting performance data for the program's 1,200 grantees. The new system imports data from EDFacts to pre-populate the reporting document and provides access to current State- and local-level student performance and grants data, which in turn simplifies the data collection process for grantees and facilitates alignment with State data submissions. Further, the system uses a two-part design, allowing the Department to verify student counts, calculate the award amounts, and provide initial award amounts prior to applicants submitting their budget and program information. This design feature should help to reduce administrative errors and also accelerate timing of the grant award process. The system design also allows the program office to communicate electronically with applicants, both on the initial application and throughout the grant period. The Department began using new application and performance system during the FY 2007 grant competition and preliminary data for this cohort are expected in the late fall of 2007.

Evidence: Indian Education FY 2007 National Activities Plan; Concept of Operations document; Task Order 4 of the Education Data Exchange Network Operation, Maintenance and Enhancement (EDEN OME) Contract (ED-05-PO-1299); Measures tab.

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program office works closely with the Bureau of Indian Education (BIE) and with other programs within the Department to ensure coherence and accountability among all programs that serve Indian students. The program office worked extensively with the BIE to ensure that BIE's NCLB plan addressed all NCLB requirements. In particular, the program office helped the BIE develop and implement its school improvement plan. The program office also works with the Impact Aid office as well as with external partners to improve collaboration and coordination with related programs. Collaboration continues with the Council of Chief State School Officers (CCSSO) to improve relationships between State educational agencies and tribal authorities in a number of States with the goal of improving educational services for Indian students under all NCLB programs.

Evidence: BIE MOU (includes accountability plan under Title I), National Indian Impacted Schools Association.

Does the program use strong financial management practices?

Explanation: Agency-wide audits have not identified deficiencies in the financial management of this program. The program office monitors the rate at which grantees draw down funds to determine whether grantees are expending funds on a timely basis. Grantees that do not do so are required to take corrective action or provide a justification for their rate of expenditures. The program office also reviews grantee audit reports and incorporates financial management topics in technical assistance sessions if there are audit findings.

Evidence: US Department of Education Office of Indian Education monitoring plan.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The program office has developed an automated system to streamline the grant application process and collect data on grantee performance for the large number of grantees funded by this program. The system will help program staff and grantees reduce errors in the application process and associated data, and will facilitate analysis of program performance data. In addition, the program office restructured staff assignments in late 2004 in order to devote a larger share of resources to program performance activities. Currently, a small team serves as a single point of contact for grantees on grant management issues (such as accessing grant funds and complying with EDGAR requirements), leaving a larger share of the staff to monitor grantee progress towards meeting performance goals and providing technical assistance on issues pertaining to program improvement.

Evidence: Concept of Operations document; Task Order 4 of the Education Data Exchange Network Operation, Maintenance and Enhancement (EDEN OME) Contract (ED-05-PO-1299).

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The Department collects project plans that include budget data and reviews each plan to ensure that project performance objectives, implementation plans, and budget are aligned. Due to the large number of grantees under the program (1,200-1,300) the program office selects a random sample of grantees each year for on-site review. Random sites are selected on a regional level to ensure maximum coverage of grantees. All grantees are reviewed off-site annually, and grantees with particular risk factors are monitored on a quarterly basis.

Evidence: US Department of Education Office of Indian Education monitoring plan.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: The program office collects grantee performance data annually as part of the applications for next year's funding cycle; however, it does not have a system in place currently to make individual grantee data available for its approximately 1,200-1,300 grantees. The Department is determining the feasibility of using the new automated grant and performance system to aggregate grantee data and make them available publicly. Some grant recipients serve small numbers of Indian students, and publication of their subgroup's academic achievement data may constitute display of personally identifiable information, which the Family Educational Rights and Privacy Act (FERPA) prohibits. Although ED is not able to make individual grantee data publicly available, it has developed a webpage that shows State-level Indian student achievement data on state assessments of mathematics and reading. Those data are available at http://www.indianeducation.org.

Evidence: Indian Education Program FY2007 Application for formula grants to local educational agencies; grantee applications. http://www.indianeducation.org.

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: The Department has established baselines and targets for the program's long-term and annual performance measures. Analysis of State performance data, collected through the CSPR, shows that the program is exceeding its targets for the percentage of students in grades 3-8 scoring at or above State proficiency standards on reading State assessments. From SY 2003-2004 to SY 2004-2005, the percentage of Indian students who scored at or above proficient in reading rose from 48.6 percent to 54.2 percent and those gains continued to increase to 60.4 percent in SY 2005-2006, exceeding the performance targets both years. Data also show steady gains on the percentage of students in grades 3-8 scoring at or above State proficiency standards in mathematics, from 45.6 percent to 49.7 percent between SY 2003-2004 and SY 2004-2005 with continued improvement to 53.6 percent in SY 2005-2006. These gains are significant and show gradual progress toward acheiving the program's long-term performance goal. In addition, when comparing Indian students and all students across grades 3-8, the difference in proficiency levels on reading and mathematics State assessments show a widening of the gap, which indicates that Indian students are not improving at the same rate as all other students nationwide. Data on the graduation rate for Indian students show some progress between 2003 and 2004, but then a slight decline in 2005. These data show overall gains as compared to the baseline, with the target exceeded in 2004 but not in 2005. However, the variability across years may be the result of the lack of uniformity in the definition of the graduation rate across States rather than an actual decrease in the percent of students graduating. Data from the 2005 NAEP administration provide the baselines to assess Indian student achievement in 4th- and 8th- grade reading and mathematics on the NAEP. These data represent the first year that NAEP included an adequate sample size of Indian students to report reliable data on their academic progress. Results from the 2007 NAEP, expected to be available in the summer of 2008, will provide the first comparison year to assess annual and long-term progress on the four NAEP performance measures. These performance data are available because of the considerable progress that the Department and its program partners have made in developing and implementing reliable assessment and reporting systems that provide the nationally disaggregated results needed to measure program performance. Access to reliable performance data will be further enhanced with the implementation of the new Indian Education grant performance management system, beginning with the FY 2007 cohort of grantees.

Evidence: Measures tab; CSPR

Does the program (including program partners) achieve its annual performance goals?

Explanation: Analysis of data from the CSPR shows significant gains in the percentage of Indian students in grades 3-8 meeting proficiency standards in reading and mathematics on State assessments. From SY 2003-2004 to SY 2004-2005, the percentage of Indian students who scored at or above proficient in reading rose from 48.6 percent to 54.2 percent and those gains continued increase to 60.4 percent in SY 2005-2006, exceeding the performance targets both years. In mathematics, the percentage of Indian students at or above proficient rose from 45.6 percent to 49.7 percent between SY 2003-2004 and SY 2004-2005 with continued improvement to 53.6 percent in SY 2005-2006. These early data show that Indian student achievement is gradually improving and that these improvements are comparable, in magnitude, to the performance increases of low-income students. For example, between SY 2003-04 and SY 2004-05, the percentage of low-income students who scored at least proficient in reading rose from 49.7 percent to 52.5 percent and in mathematics from 47.6 percent to 50.6 percent. On the measures that compare Indian student achievement in grades 3-8 in reading and mathematics, the results show a widening of the gap, indicating that students nationwide are improving at a faster rate than Indian students. This may be a result of several factors occurring in SY 2005-2006, including the addition of new State assessments and the first year that States were required to assess all students in grades 3-8. When more data become available, in particular during the next year when all States will be required to submit achievement data through EDFacts, the Department plans to reexamine the data and determine whether SY 2004-2005 was an appropriate baseline year for this measure. Despite this increased achievement gap, the overall gains in achievement among Indian students indicates that the program is having a positive impact and, therefore, making progress toward meeting its annual goals. The final measure, on the percentage of Indian students who graduate from high school, shows some progress between 2003 and 2004 rising from 70 percent to 73 percent and then a slight decline in 2005 to 72 percent. These data show overall gains as compared to the baseline, with the target exceeded in 2004 but not in 2005. However, the variability across years may be the result of the lack of uniformity in both the definition and calculation of the graduation rate across States, rather than an actual decrease in the percent of students graduating.

Evidence: Measures tab; CSPR

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: The Department has improved the efficiency and the cost-effectiveness of its data collection by refining questions on the Consolidated State Performance Report (CSPR) forms to improve clarity and eliminate duplication, and by implementing the EDFacts system to significantly streamline the CSPR reporting process. This system uses a single cross-program data request to States, and these data can be submitted electronically at the time when they are available. These data are then imported into the new Indian Education grant performance management system and used to pre-populate the reporting document, which avoids duplicative data entry by grantees and facilitates alignment with State data submissions. To further facilitate the data collection process, the system uses a two-part design, allowing the Department to verify student counts, calculate the award amounts, and provide initial award amounts prior to applicants submitting their budget and program information. In the past, this process required several paper submissions by the applicants and numerous interactions with the Department; by implementing this new electronic system the Department expects to reduce administrative errors and accelerate timing of the grant award process significantly. These steps should result in data that are more accurate and reduce the reporting burden on grantees, so that more attention can be focused on program implementation. Further, the system improvements should provide the Department's program managers with more timely data for use in budget, policy, and management decisions. The Department also has developed a new efficiency measure focused on increasing the percentage of funds used prior to the grant closeout by the program's formula grantees. Baseline data show that LEAs, awarded funds under the Indian Education Formula Grants program, used 93.85 percent of grant funds prior to their grant closeouts in FY 2006. The Department has established targets of a 1.25 percent increase each year to reach 100 percent of grant funds used by 2011. Efficiency data are based on the amount of Indian Education Formula grant funds that remain unspent at the end of five years and are subsequently returned to the Department of the Treasury. By monitoring the percentage of unspent program funds throughout the grant period, the Department will be able to assist grantees in allocating all available funds prior to the end of the grant period and more effectively serve the educational needs of Indian students.

Evidence: Indian Education FY 2007 National Activities Plan; Measures tab.

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: There are no comparable programs that provide funds directly to LEAs on a formula basis for the purpose of educating Indian students through programs that address both their educational and culturally related academic needs. Although the BIE-administered Johnson-O'Malley program provides funds for educational services to Indian students attending public schools, it serves a somewhat different population of students and the program is structured differently. Under the Johnson-O'Malley program funds flow through tribal authorities rather than to public school systems directly. This structure limits accountability for the academic performance of Indian students receiving services funded by the Johnson-O'Malley program. Note: Prior to the public release of this review, the Department will seek to determine if there is a valid way of comparing this program with the Johnson-O'Malley program.

Evidence:

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: The program has not been independently evaluated in many years. However, the Department is investing resources to ensure that the NAEP includes a sufficient number of Indian students. Although the NAEP data will not provide information on program performance directly, it will provide reliable data on the academic performance of Indian students in general. The Department conducted a study to determine the feasibility of conducting a quantitative evaluation study to determine effects of culturally based interventions in Indian education from 2002-2004. The Department determined that it is not feasible to conduct such an evaluation at this time, given the difficulty of defining culturally based education in a measurable way, the lack of research models on Indian education that would meet definitions of scientifically based research, and the small size of the Indian student population.

Evidence: