Detailed Information on the
Bureau of Indian Affairs - Human Services Assessment

Conduct an independent review of the program's management.

Collect performance data to evaluate the program based on performance results and take corrective action as necessary.

Measure: Percent of reciepients that complete the goals identified in the Indivdual Self-Sufficiency Plans (ISP).

Explanation:Pursuant to 25 CFR Part 20, general assistance recipients are required to achieve self-sufficiency, by complying with goals identified in an Individual Self-Sufficiency Plan (ISP). Moreover, this regulatory requirement is monitored and documented via annual program quality reviews. The number of recipients receiving general assistance is under collection, and total number of individual that have completed the goals of the ISP will be made available in November 2006. Targets for this measurement are estimates, and are projected to increase (above the baseline) by 3.5 percent each year. Measurement is calculated by dividing the number of GA recipients who have completed all ISP goals within a specified performance year, by the total number of GA recipients who are being expected to complete all ISP goals.

Measure: Percentage of active supervise IIM case records reviewed in accordance with 25 CFR Part 115.247.

Explanation:The program has a statutory requirement to supervise and manage Individual Indian Money (IIM) Accounts. The results are measured by calculating the total number of active supervised IIM accounts, by the total number of active supervised account case records reviews in accordance with the regulations. In FY 2005, the total number of active supervised IIM accounts was 1,381, of which 1,785 were reviewed in accordance with 25 CFR Part 115. Each year, the program will increase the number of case records review by 5%. The measure is calculated by dividing the total number of active supervised IIM account case records that are found to be in compliance with 25 CFR 115.427, requirements by the total number of active supervised IIM accounts case records reviewed in the specified performance year.

Measure: Percent of Indian Child Welfare Act notices processed within 15 days of receipt.

Explanation:By regulation, the program is required to ensure that tribes receive notice of child custody proceedings. The program will demonstrate results by calculating the total number of Indian Child Welfare Act (ICWA) notices received, by the total number of ICWA notices processed within 15 days. In FY 2005, the total number of ICWA notices received was 44,514; a total of 46,015 of these notices were processed within the designated time frame. The program will increase the number of notices processed by 5% each year. The measure is calculated by dividing the total administrative time to process all ICWA notices in a specified performance year by the total number of ICWA notices processed that year.

Is the program purpose clear?

Explanation: Human Services includes three program areas aimed at providing human services to federally recognized tribal members: 1) general assistance; 2) supervision of Individual Indian Money (IIM) Accounts; and 3) child services. All three program areas have clears purposes. The general welfare assistance program provides both children and adults, financial assistance to meet basic needs such as food, clothing, and shelter when such assistance is not available from states, counties and/or other federal agencies. The supervision of Individual Indian Money Accounts program consists of the Individual trust fund accounts which have been mandated by Tribal courts to supervised status for minors, adults who require assistance in managing their accounts. Lastly, child services programs prevent the unnecessary removal of Indian and Alaskan Native children from their homes and communities to promote stability of tribes and families. The Indian Child Welfare Act (ICWA) program provides for the proper notification and placement of Indian children into Indian and Alaskan Native families or home when removed because of abuse and/or neglect.

Evidence: 1) The Synder Act and 25 CFR Part 20, Financial Assistance & Social Services Programs establishes the purpose for general assistance. 2) 25 CFR Part 115, Trust Management Reform on Leasing/Permitting, Grazing, Probate and Funds Held in Trust, Executive Order No. 3215, and the Principles of Discharge of the Secretary's Trust Responsibilities establish the need for IIM account. Public Law 95-608, Indian Child Welfare Act of 1978 and 25 CFR Part 23, Indian Child Welfare Act expresses the need to protect Indian and Alaskan Native children.

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

Explanation: All three program areas address specific human needs. For general welfare assistance it is reported that Indian reservations have the highest unemployment rate in the United States. Of the 1.6 million federally recognized tribal members about forty-nine percent were unemployed and of these the program provided assistance to more than 88,000 residing on reservations and Alaskan Native Villages in FY 2005. The supervised IIM program, as of March 2006, had a total of 41,232 accounts being managed. In FY 2005, more than 30,000 Indian child placement notices were received by BIA from state court proceedings for the placement of children outside their natural homes due to alleged child abuse and neglect.

Evidence: The extent of the human service needs of the Indian and Alaskan Native population was demonstrated by the American Indian Population & Labor Force Report; 2003 Indian Service Population on GA / FY 2002 AFCARS Data, Montana and New Mexico; 2002 Current Statistics Concerning the Pine Ridge Oglala Lakota (Sioux) Reservation; Quality Analysis of Funds Summary; FY 2005/2006 Office of the Special Trustee, IIM Supervised Account Totals; and the 2006 Government Performance Results Act (GPRA)

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

Explanation: The program areas do not duplicate other federal, state or local effort. Although there are other programs that provide similar benefits, yet their eligibility requirements cannot be met by this service population. The BIA general assistance program funds are made available only if there are no other non-BIA resources available and program eligibility requirements are met. These other non-BIA programs include: Temporary Assistance to Needy Families (TANF), Medicaid, Supplementary Security Income (SSI), Foster Care and Child Welfare. For the IIM program, only BIA can supervise IIM accounts. The BIA is also the only entity that can provide Tribes the ability to intervene in state child custody matters.

Evidence: Eligibility requirements for this program are straight and are contained in the following: 25 CFR Part 20; 25 CFR Part 115; 25 CFR Part 23; Executive Order No. 3215, Principles of Discharge of the Secretary's Trust Responsibilities; Interagency Procedures Handbook Implementation and Training; Individual Indian Money (IIM) Supervised Account - Policy Clarification, 2004; Memorandum 1996; Denial Letter Sampler

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

Explanation: In general, the management of these programs is free of major management flaws. All the program areas have clear statutes and regulations that allow the programs to operate in a manner that is not confusing to the service population and to the BIA and Tribes that carry out some of these programs under contract with the BIA. Regulations are reviewed regularly and updated when necessary to meet contemporary needs of the service population and to account for newly passes legislation of other agencies providing welfare and child assistance programs to the Indian population to ensure that the BIA general welfare program is not supplementing their programs. The distribution of welfare assistance funds is based on annual documented and reported need because needs changes significantly from year-to-year. Thus, funds follow the annual reported need within each tribes recurring base allocation. Annual program reviews and corrective action plans are performed. Independent evaluations have demonstrated program effectiveness.

Evidence: These references are used to manage the program: 25 CFR Part 20; 25 CFR Part 115; 25 CFR Part 23; P. L. 95-608; Interagency Handbook; IIM Supervised Account - Policy Clarification, 2004; 25 CFR 20, Technical Amendments, 2001; Analysis of Tribal Feedback on Final Welfare Assistance Regulations (2/19/01); Welfare Assistance Memorandum, 2004; Social Service Payment Standards for Programs in 25 CFR 20, 2000.

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

Explanation: All three program areas deal only with federally recognized Native Americans and Alaskan Natives and all three program areas are targeted to only those individuals that are eligible and have unmet needs. The general welfare program requires 100% of funds be provided for basic unmet needs. For the supervised IIM program, the court determines the individual in need and the BIA provides services directly or by contract with Tribes. One hundred percent of funding for child protection is distributed directly to Tribes. In addition, ICWA funds are used to intervene in child proceedings in state court and to ensure the safety of eligible children.

Evidence: The program operates using these sources of references: 25 CFR Part 20; 25 CFR Part 115; 25 CFR Part 23; P. L. 95-608; Interagency Handbook; IIM Supervised Account - Policy Clarification,2004, and the Welfare Assistance Memorandum, 2004.

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 program has limited number of specific long term performance measures that focus on outcome and reflect the program's purpose. Some of the measures are contained in the Bureau's 2007 budget, and new ones have been developed as a result of this PART review. The long-term performance measures for general assistance is to 1) support recipients to achieve self-sufficiency. The long-term goal for the Individual Indian Money (IIM) program is 2) to better fulfilling Indian trust responsibility of supervises Individual Indian Money (IIM) accounts. 3) To maximize the potential for harm to Indian and Alaskan children is the final long-term performance measure. The program's long-term performance measures l support the Department's Goal of Developing Quality Communities.

Evidence: These measures are contained in the President Performance Budget, FY 2006 & 2007; Government and Performance Result Accountability Act Data (GPRA), FY 2005 & 2006; and the Government and Performance Rating Accountability Report, Summary Table.

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

Explanation: Definite targets and timeframes have been developed for long-term measures. The long-term/annual measure for the general assistance program is that by 2012, 18.5% of general assistance recipients will have achieved self sufficiency by completing the goals identified in the Individual Self-Sufficiency Plans (ISP). The program will also improve general assistance program efficiency by decreasing the cost per client served. To better fulfill Indian trust responsibilities by 2012, 100% of active supervised IIM accounts case records will be reviewed in accordance with 115.427, and the administrative processing time of these accounts will have improved by 35%. By 2012, the child services program will have minimize the potential for harm to Indian and Alaskan Native children at risk for abuse and neglect, by improving in the administrative processing time for Indian Child Welfare Act (ICWA) notices by 99.5%.

Evidence: President Performance Budget, FY 2005, 2006, and 2007; Government and Performance Result Accountability Report, FY 2005 and 2006; Government and Performance Result Accountability Act Report, Summary Table; Activity Base Costing Data (Regional Survey: Volume by Output)

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 program has a limited number of specific annual performance measures that demonstrates progress toward achieving the program long-term goals. The general assistance annual performance measurement is to (1) increase the number of general assistance recipients that complete the goals identified in the Individual Self- Sufficiency Plans (ISP). Moreover, the program intends to (2) augment the percentage of active supervised IIM account reviewed in accordance with 25 CRR Part 115, as well as (3) improve the administrative processing time for these accounts records via web-base development. The annual performance goal identified for the child assistance program is to (4) improve the administrative processing time for ICWA notices.

Evidence: Annual performance measures are evident in the: President Performance Budget, FY 2006 and 2007; Government and Performance Result Accountability Act, Summary Table; Activity Base Costing Data (Regional Survey: Volume by Output); and BIA IIM Social Service Web (draft).

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

Explanation: Explanation: The Bureau has most of the baseline information for its measurements, and is has made satisfactory progress towards establishing baselines for the newly developed measures. Government Performance Results Act (GPRA) data has tracked the progress of active supervised Individual Indian Money (IIM) reviews in accordance with 25 CFR 115, and the number of Indian Child Welfare Act (ICWA) notices processed. Activity Based Costing (ABC) data has monitored the costs per client served for an efficiency measure of the general assistance program. The program has a regulatory requirement (25 CFR 20) for general assistance recipients to complete the ISP, which is monitored and documented via annual program quality reviews. The baseline for this measure has been established and actual data will be available in November 2006. The program has drafted a web-page that will decrease the administrative process time for annual supervised Individual Indian Money (IIM) accounts reviews.

Evidence: The program's baselines and annual measures are documented in the President Performance Budget, FY 2006 and 2007; Government Performance and Result Act, Reporting Tool; Government Performance Rating Tool Performance; Activity Base Costing Data (Regional Survey: Volume by Output); BIA IIM Social Services (Web Outline); and the Individual Self-Sufficiency Plans, samples.

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: Partners (include federally recognized tribes and Alaskan Natives) are committed and work with the program towards achieving the annual and long term goals. Federal and tribal partners operating the general assistance program are required by regulation to have clients and case managers develop and sign the Individual Self-Sufficiency Plan (ISP). Federal and tribal partners have implemented policy regarding the management and review of active supervised IIM account deficiencies. Tribal and other government partners are committed to and work towards eliminating child abuse and neglect, and improving the ICWA notification and processing time between tribes and the States.

Evidence: Partners' commitment to working towards the program's annual and long-term performance goals are supported by: 25 CFR Part 20; Office of Self-Governance, PL 102-477 Contract (Port Gamble S'Klallam Tribe); Pub L. 102-477 Contract, Yakutat Tlingit Tribe; Pub L. 102-477 Contract, Red Lake Band of Chippewa Indians; Memorandum, Individual Indian Money (IIM) Supervised Account, Policy Clarification, September 2004; Indian Child Welfare Act (ICWA) Notification Memorandum, November 2005; Indian Child Welfare Act (ICWA) Designated Agent List, March 2005; the ICWA & PART Measurement; and the Tribal Training Agenda.

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: Regularly, independent evaluations are conducted by a number of entities on the general assistance, Individual Indian Money, and child services program, which assesses program effectiveness and relevance regarding interests and needs. However, the Bureau needs to establish its own evaluations to manage its programs. A GAO audit of Navajo Nation's general assistance program, for instance, recommends administrative improvements, via training and technical assistance. An evaluation by the Casey Family Program and National Indian Child Association (NICWA) concluded that the development of a database would improve accuracy of child abuse and neglect cases reported in Indian country. The Casey Family Program is a private foundation provides an array of permanency planning, prevention, and transition services. The NICWA is a private non-profit organization provides training and technical assistance related to Indian child welfare services. KPMG conducted program performance audit in 2004, which cited various inconsistencies in the review process, and recommended that the BIA standardize IIM policies and procedures for compacted and contracted social services functions. Annually, quality control program and state reviews are conducted and corrective action plans are developed on programs as needed.

Evidence: The following independent evaluations have been conducted on the program: Office of the Inspector General/Audit Report, Bureau of Indian Affairs, September 2004; KPMG Audit, Section 4 - Audit Findings: Supervised Accounts, September 2004; Child Abuse & Neglect Among American Indian/Alaska Native Children: An Analysis of Existing Data/Kathleen Earle, PhD, Amanda Cross, BA, December 2001; Participation in State Reviews- Rocky Mountain Region, 2005 Program; Reviews: general assistance, IIM and child service programs.

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 Bureau has several legacy measures in place to demonstrate how it intends to use the funding provided. New measure developed for this PART review will enhance it s budget presence. Annual budget requests are associated with annual and long-term performance goals, and are clearly identified in the President Performance Budget. Current budget requests identify training and the reviewing of Active Supervised Individual Indian Money (IIM) account as important achievements. Indian Child Welfare Act: FY 2004-2007 budget request, focus on the providing resources that enable Tribes to intervene in state court proceedings, as well as process ICWA notices in a timely manner. Funding request report full funding because these are grants.

Evidence: President Performance Budget, FY 2005, 2006, and 2007.

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

Explanation: The program conducted a comprehensive review of strategic and annual planning and determined existing measures were insufficient to support adequate management decision making. As a result, new measures were created and implemented. The program is continuously working on policy clarification and providing training to Bureau contracted and compacted programs.

Evidence: The actions this program has taken to correct it strategic planning deficiencies are evident in the: President Performance Budget, FY 2005, 2006, and2007; Government Performance and Results Act (GPRA) & PART Meeting, November 2005; and the Meeting & Sign-in Sheet, November 2005.

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 program collects credible performance data, including information from key programs partners. Management utilizes performance data to work with tribes for program improvement and budget requests. Quarterly Analysis of Funds reports and narratives, as well as program reviews are used for planning and training purposes for general assistance programming. Annual review reports are used to identify training needs and manage resources for IIM accounts. Data is also used to identify program review issues and coordinate efforts with other Federal agencies. Child services data is used to identify and manage the number of Indian children removed form their natural homes, as well as develop program policy. Tribal child services program information is used to generate the Designated Agent list, which assist states for ICWA notification purposes. In addition, child abuse/neglect data is collected annually, which has been used in independent studies.

Evidence: The regular collection and uses of performance data is evident in the: President's Performance Budget, FY 2006 and 2007; Government Performance Results Act Data, 2005 and 2006; Mid Year Analysis: Navajo Nation (CY 040/5), Eastern Region (FY 040/5), OSG (FY 03/04), and PL 102-477 (FY03/04); Welfare Assistance Guidance, November 2005; Memorandum, Policy Decision on Social Services Disaster Assistance for December, 2002; Fiscal Year 2005 Welfare Assistance Guidance, Southern Plains; Region Supervised Individual Indian Money (IIM) Totals, March 2006 Annual Report; Great Plains Region 2003 Distribution of Special Social Service Funding to Regions for IIM Initiative, September 2003; Meeting Notes, BIA and Social Security Administration, July 2003; Individual Indian Money Reviews, Rocky Mountain and Great Plains Regions; Indian Child Welfare Data, FY 2001-2004; Memorandum, Child Protection Teams (CPT) Work Group Survey, December 2003; Child Protection Survey Results, Eastern Region, January 2004; DRAFT: Memorandum of Agreement (MOU) Bureau of Indian Affairs and Indian Health Service, working document 2006; Federal Notice, Indian Child Welfare Act, Designated Agent List 2005; and the Casey Family Report, Child Abuse and Neglect Data Analysis, 2001.

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: Federal managers and program partners that operate the general assistance, Individual Indian Money (IIM), and child service programs are held accountable for cost, schedule and performance results. Federal Manager's, program partners, and Tribes accountability is evident in their individual U.S. Department of the Interior, Senior Executive Service Performance Plan and/or Employee Performance Appraisal Plan. The roles and responsibility regarding the management of supervised IIM account, for example, are also clearly defined for Federal managers and program partners in performance appraisals. Tribal compactor and contractor also include performance results in the Annual Funding Agreements (AFA).

Evidence: Managerial and partners accountability is documented in the Senior Executive Service Performance Plan(s), Regional Director(s), 2006; Senior Executive Service Performance Plan; Deputy Director, Tribal Services, 2006: Employee Performance Appraisal Plan, 2005; and the Annual Funding Agreement.

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

Explanation: Program funds are obligated in a timely manner and spent for intended purpose as evidenced by funding documents. General assistance funds are obligated into approved 638 contracts as soon as they are available. Individual Indian Money funding is spent for managing IIM supervised accounts and to provide training. Child service funding is obligated into grants and/or contracts that are reviewed and approved by a BIA approving official. These grants are included within all tribes reoccurring Tribal Priority Allocations (TPA) and are received via 638 grants. Indian Child Welfare grants are subject to the Single Audit Act.

Evidence: Indications that funds are accurately reported and spend for its intended purpose is supported by: Pub L. 638 Contract, Crow Creek Sioux Tribe, FY 2005; Annual Funding Agreement; Funding Document -520, FY 04/05; Social Service Automation System (SSAS) Reports; Financial Reports 269 A, Winnebago Tribe 2005; and the Office of Management and Budget Circular, A 133.

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 program has procedures to measure and achieve efficiencies and effectiveness in program execution. The programs are monitored annually for compliance with federal legislation and regulation requirements, which assist to assure that services and funding are provided to only eligible clients. A automated program is currently under construction that will increase the administrative processing time of active supervised IIM accounts and response time for ICWA notification via automating the currently paper system. Activity Base Cost (ABC) data tracks the cost per client served for social service assistance.

Evidence: Procedures to measure cost effectiveness is evidenced in: 25 CFR Part 20; Quality Control Program Reviews; Web Page Design; and the Activity Base Costing data (Regional Survey: Volume by Output).

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program routinely collaborates and coordinates with related programs. It is the BIA's policy that the general assistance program coordinates with other State, County and Federal programs in order to provide non-duplicative services to clientele. Individual Indian Money funds are also managed in coordination with the Veterans Administration and Social Security Administration funding that may be deposited into the account. Tribal Per Capita and Judgment funds are distributed in accordance with Tribal Resolutions. Staff works with Office of the Special Trustee personnel and appropriate court systems to administer funds. Legislation also requires that child services be effectively collaborated and coordinated with other related programs.

Evidence: Program collaboration and corrdination is caputred in 25 CFR Part 20; Memorandum of Agreement, United States Attorneys Office Memorandum of Agreement, Bureau of Indian Affairs, Rocky Mountain and Indian Health Services, Billings Area, 25 CFR 115, seesection 3.2 Memorandum of Agreement, BIA and Office of Trust Funds Management, May 2002 Interagency Procedures Handbook, section 3.2 BIA and Social Security Meeting Notes, see section 3.2 DRAFT: Memorandum of Agreement (MOU) Bureau of Indian Affairs and Indian Health Service, working document 2006, see section 3.1

Does the program use strong financial management practices?

Explanation: The program uses strong financial practices and complies with the single audits required by the Office of Management and Budget (OMB) Circular. Regional quality assurance reviews are conducted on the general assistance program and child services programs to ensure regulatory compliancy. Standard Forms 269 (SF 269) are submitted and reviewed annually to ensure fiscal accountability, as required by Pub. L. 93-638. KPMG audits of BIA supervised IIM account records demonstrate that an outside party have reviewed these records for compliance. The KPMG audit findings indicated that controls within the BIA organization are adequate regarding the distribution of supervised IIM accounts and are in accordance with the distribution plan. The OST's accounting system for disbursements of IIM accounts is used for approval of BIA Distribution Plan.

Evidence: The program's strong financial practices are supported by the: Quarterly Analysis of Funds Report and Narratives; Social Services Automation System Report; Circular No. A-133 - Revised June 1997, Audits of State, Local Government, and Non-Profit Organization; Annual Funding Agreements; Annual Quality Control Reviews; and the Standard Form 269 KPMG Audit dated September 10, 2004, Section-4, Findings: Supervised Accounts, January 2005.

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

Explanation: The program continuously evaluates and addresses its' management deficiencies. Program analysis conducted during the FY 2005, Regional Social Workers meeting, for example, indicated a lack of consistency in policy and program implementation from region to region regarding the review of active IIM account. As a result, consistent policy for several key areas has been identified as a management priority. The program is proactively monitoring all active supervised IIM accounts through annual reviews and corrective action plans. Another programmatic shortfall in the child services program is the high number of ICWA notices received by the state, which reportedly has caused back log at the agency and regional level. Management is currently working towards improving the notification process to meet the required 15-day time frame. Annually a Designated Agents list is published in the Federal Register for receipt of Indian Child Welfare (ICWA) Notices and a policy memorandum has been issues. Moreover, management has established a mail listing of State Attorney Offices and will be issuing a letter to each office as well.

Evidence: Improvement in management deficiencies are captured in the: Individual Indian Money (IIM) Supervised Account - Policy Clarification, 2004; Program Reviews; Pub L. 93-638; Annual Funding Agreements; Annual Reviews; Corrective Action Plans; Indian Child Welfare Act (ICWA) Notification; and the ICWA Designated Agent List, March 2005.

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

Explanation: The Bureau has several legacy measurements that can demonstrate progress, but new measures have been developed that better demonstrate progress. Government Performance Rating Act (GPRA) measures includes the long-term goals of advancing quality communities by ensuring timely reviews of supervised Individual Indian Money (IIM) Accounts, and efficient management of social service programs. Government Rating Performance Act (GPRA) data indicates that 77 % of all active supervised IIM account case records have been reviewed for compliance during FY 2006. The program has developed a Human Services IIM Web-page that will track and further improve the administrative processing time of IIM account case records. As a result of the PART review, new measurements were introduced and actual data will be made available during FY 2006. For example, the long-term measures for the general assistance program is to support clients achieve self sufficiency, by increasing the percentage of the goals identified in the Individual Self-Sufficiency Plan (ISP). FY 2006 GPRA data also indicates that the child services program has processed 97% of the ICWA notices as required by regulation.

Evidence: The program's progress in achieving its long-term goal is supported by: Government Performance Results Act Data, FY 2005, 2006 and 2007; Activity Base Costing (ABC) (Regional Survey: Volume Output, FY 2005); Supervised Individual Indian Money (IIM) Account Review Summary, May 2005; Policy Clarification Memorandum, September 2004; and the Indian Child Welfare Act (ICWA) Notification 2005, memorandum.

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

Explanation: The program has demonstrated notable progress towards achieving its annual performance goals. Government Performance Rating Act (GPRA) data, for instance, indicate that the program is on target for meeting the annual goal to review supervised Individual Indian Money (IIM) Account case records in accordance with 25 CFR Part 115. The GPRA data also demonstrates that the program is meeting the annual goal to improve the ICWA notification processing time between tribes and the States. In addition, Activity Base Costing data (ABC) has tracked decreased cost for general assistant clients served. The program has an establish baseline for its general assistance annual goal as well, which Federal and tribal partners have started to implement. Some tribal programs that operate general assistance contacts under Pub L. 102-477, for instance, identify the ISP (also termed the Individual Development Plan -IDP) as major program component. Moreover, all BIA contracting and compacting tribes are required to submit GPRA data. Although the program has effectively achieved many of its annual goals, one annual goal requires additional information to determine its full status. Notwithstanding the program has implemented policy regarding the management active supervised IIM account and a data base has been developed to improve the administrative processing time of these account case records.

Evidence: The program's efforts to achieve annual goals are documented in he Presidents Performance Budget, FY 2006 and 2007, Activity Base Costing: (Regional Survey: Volume by Output); Government Performance Rating Act Reports, FY 2005 and 2006, Office of Self-Governance Contract; and a Pub L. 102-477 Contract.

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

Explanation: The program has established new efficiency measures, and as a result improvement cannot be demonstrated. However, programs that operate general assistance are required to serve as the payee of last resort and partnerships must be established with other programs for assistance. The program has also managed Activity Base Cost (ABC) data that tracks the cost per client served for social service assistance since FY 2005 The KPMG audit indicates that the program has been working cooperatively with the Office of the Special Trustee (OST) to assure appropriate distribution of supervised Individual Indian Money accounts. Joint training occurs and policy has been issued to improve IIM operational and administrative procedures. Child services are responsive and partnerships are established with other programs for assistance. Improved procedures recently issued by the Central Office have facilitated uniform policy in responding to ICWA notices from state courts. Program regulation and quality assurance reviews are key elements in the management of program's cost effectiveness.

Evidence: The program's efficiency and cost effectiveness is required in 25 CFR Part 20; and evidenced in the Quarterly Analysis of Funds Report & Narratives; Supervised Accounts - Policy Clarification; Interagency Procedures Handbook Implementation and Training, Activity Base Costing Data (Regional Survey: Volume by Output); and the ICWA Notification Memorandum, November 2005.

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

Explanation: Although some federal and state programs provide similar welfare/general assistance services, they have eligibility requirements that the Bureau's service population cannot meet. Moreover, the Bureau provides a direct service to Indians and Alaskan Native reservations that are not covered by local, state or other federal programs. An evaluation of the general assistance program was considered, but it was determined that there exist a number of variables that would make a favorable comparison between the BIA and state programs impossible. Each state/tribe relationship, for example, is unique depending on legal jurisdiction and political relationships, and BIA funded programs must adjust to these differences. In addition, the general assistance and child services programs provides for local delivery of assistance and collaboration amongst programs (e.g. IV-B, employment and Indian Child Welfare) to individuals and children living in remote areas with limited services and resources. The Individual Indian Money (IIM) program manages separate records on all supervised accountholders and monitors the distribution of trust funds to ensure that payments are made in the accountholder's best interest. No other Federal program is legally responsible for maintaining supervised IIM cases or Indian adoptions records. In addition, the BIA is the only government program that is responsible for assisting tribes to exercising their rights to intervene in state child custody matters as directed under the Indian Child Welfare Act.

Evidence: Non-program comparison is supported by: 25 CFR Part 20; Quarterly Analysis of Funds Report & Narratives; 25 CFR 115; OST and BIA, Interagency Handbook; and Pub. L. 95-608, the Indian Child Welfare Act.

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

Explanation: The program receives many evaluations from a number of sources. However, sources in the BIA need to establish a systematic approach on conducting its own independent review on a predetermine cycle on its management of the program. The independent evaluations that have been conducted, suggest that the programs are operating adequately and for the most part achieving results. A KPMG program performance audit was done in 2004 indicates that controls within the BIA organization appeared adequate and the distribution of supervised IIM accounts are in accordance with the distribution plan. The study did find instances of noncompliance with 25 CFR Part 115. At four agency offices, for instance, KPMG noted that the "Social Service Assessment and Evaluation" forms were not completed and/or approved by the supervisor or BIA Superintendent. A Government Account Office (GAO) report was published in April 2005, on the Indian Child Welfare Act. Although the BIA does not have direct authority over state placement matters, the BIA provided interviews and data for this evaluation. Another child services study conducted in 2001, by the Casey Family Program and Native American Child Welfare Association (NICWA), reviewed child abuse and neglect data among American Indian/Alaskan Native children. This study compared publications regarding child abuse and neglect, including data submitted by the BIA. The study noted that one of the strengths was the raw data made available from the BIA Western Region Office. The Office of the Inspector General Office (IG) issued a report concerning the management of social services funds by the Cheyenne and Arapaho Tribes of Oklahoma. This report was not favorable, and indicated that the tribe does not adequately document applicant eligibility and has allowed ineligible applicants to receive general assistance funding. Another IG audit of the Navajo Nation's general assistance program recommended that the BIA more closely monitor this program and provide the tribe with technical assistance to help improve program management controls.

Evidence: Indicators of program effectiveness and achievement is reflected in the: Office of the Inspector General/Audit Report, Bureau of Indian Affairs, Contract with the Navajo Nation for Social Services, Report No. QIN-BIA-0098-/September 2004; Office of the Inspector General/Audit Report Management of Federal Funds/Cheyenne and Arapaho Tribes of Oklahoma Report 2002-I-0006/January 2002; Corrective Action Plan in response to GAO Audit Report/Long-standing Internal Control Memo/Central Office Jan 21, 2005 /s/ Michael R. Smith/KPMG Audit dated September 10, 2004, Section 4 - Audit Findings: Supervised Accounts; Child Abuse & Neglect Among American Indian/Alaska Native Children: An Analysis of Existing Data/Kathleen Earle, PhD, Amanda Cross, BA, December 2001; and the Indian Child Welfare Act, Existing Information on Implementation Issues Could Be Used to Target Guidance and Assistance to States, April 2005.