This is section 3 of 5 sections. Access the Full PDF Version of the Comment Compilation Here.

Comments in grey box formatting were received after the comment deadline.

1. Factors to Determine Allocation among K-12 and TCUs

A. Support for An Equitable Formula

We support a fair and equitable distribution of the $850 million dollars in ARP funds to BIE K-12 schools and the 35 TCUs. The Fort Belknap Indian Community has a TCU that operates as Aaniih Nakada College (ANC). ANC influences both the lives of students and the local economy in a remote area. The college plays a key role in helping students increase their employability and achieve their individual potential. Therefore, we support a more equitable distribution of the ARP education funds for TCUs. (17-Fort Berthold)

This is very important and needs to be equitably distributed to Tribes so that they individually can decide where the funds should go and meet needs they individually have prioritized. For example, we have a large infrastructure project at our K-8 school to pay for; the installation of a back-up generator providing electricity when the primary power is not available. We have the generator on-site but need it moved and installed and operable. (78 – Coeur D’Alene)

Tribes are deeply invested in educating our children kids because we know these kids are our future community leaders, cultural protectors, and language speakers. Education is a central component of the trust obligation but the educational statistics for AI/AN children reflect academic achievements that lag significantly behind their white peers and a high school graduation rate that is less than 50% annually. The Federal government is failing to uphold their trust obligation to educate our AI/AN children. Currently, over 90% of AI/AN children attend public schools but the BIE’s educational funding supports 8% of AI/AN children who attend either BIA or Tribally owned K-12 schools. We would advocate for funding to support the education of all AI/AN students that attend Tribal Headstart programs, K-12 educational institutions, Tribal colleges and universities, vocational institutions, and other institutions of higher learning. Since Jamestown S’Klallam children do not attend BIA or Tribally owned schools, we will refrain from commenting on the distribution of the $850 million other than to say that we support funding all eligible schools on a fair and equitable basis. We would also urge DOI to coordinate with the Department of Education to ensure all AI/AN students are provided adequate funding and afforded a quality education. (67 - Jamestown S’Klallam)

B. Direct More Funding to K-12

We oppose all funds being directed to tribal colleges and tribal schools. Currently in California we do not have a tribal college, making this allocation unfair and does not provide for our community. Because of our isolated location, we have very limited enrollment. We would like to request that this funding be made available for tribal educational programs that support tribal members. The Chemehuevi Education Center has established programs that addressed the unmet needs from our school district during the COVID-19 pandemic since the shutdown and up to this point. Establishing the protective protocols to safely meet the needs of the tribe while all our local schools were closed and or providing only distance learning. In addition, the Chemehuevi Education Center provides continuing education for our membership by means of scholarships, tutoring, school counseling, and many other support measures. (75 - Chemehuevi Indian Tribe)

Given that the Navajo Nation reservation is home to 32 BIE operated schools, we urge the BIE to allocate a greater portion of the $850 million to support our K-12 schools. (57-Navajo Nation)

NIEA recommends that the Bureau of Indian Education allocate funding between K-12 Bureau-funded schools, Tribal Colleges and Universities, and administrative costs in proportion to the amounts allocated in annual appropriations for Fiscal Year 2021. This would amount to, reflected in the chart below [80% or $6580 million to K-12 Bureau-funded schools; 15% or $127.5 million to Tribal Colleges and Universities; 5% or $42.5 to Education Management.] See comment for additional details. (52-NIEA)

We propose that a significant majority of funding directed through the Bureau of Indian Education be directed to the K-12 schools because primary and secondary education is fundamental to everything else and must be prioritized. The allocation could rationally be based on a "per student served" basis. We doubt the usefulness of allocating any ARP funds to Bureau-wide facilities improvements or a learning management system due to the multitude of unique circumstances facing each school. (43-Pueblo of Laguna)

SFIS recommends that not more than 5% of the funds be set aside for BIE Administrative use and that not less than 60% of these funds be distributed to BIE-funded elementary and secondary schools and dormitories. In addition, SFIS recommends that the portion of the $850,000,000 allocated to BIE-funded elementary and secondary schools and dormitories be distributed according to 25 CFR Part 39, using the Indian School Equalization Formula (ISEF) based on Weighted Student Units (WSUs). Given the status of WSUs in the CFR and the fact that they are the current method for allocating funds, we believe that WSUs should be used as the basis for determining these funding allocations. (81-Santa Fe Indian School)

C. Direct More Funding to TCUs

AIHEC urges the Department of the Interior, and more specifically the Bureau of Indian Education, to provide TCUs and our students with an equitable share of the $850 million

provided to the Bureau of Indian Education. […] To equitably address ongoing TCU COVID-19-related needs and adaptation strategies of both BIE-funded elementary and secondary schools and TCUs, the BIE Education Stabilization Fund should be divided based on the number of students served. Given the number of students served (and using only academic students for TCUs), the TCU share of the BIE COVID-19 relief fund should be 40.84 percent, and the K-12 share would be 59.15 percent. Rounded, this would be 40 percent to the TCUs and 60 percent to the K-12 schools. This request is reasonable and justifiable based on the number of students served in.” See comment for additional details. (45-AIHEC)

C. Weighted Student Unit (WSU) and Pro Rata

The factors to be used to determine fair and equitable distribution between K-12 systems and Tribal Colleges and Universities: For K-12 systems we would like to use the ISEP/WSU number. Schools must be held harmless to the end of this SY 20-21. Initiate student count in SY 21/22. Question: What is the percentage being proposed? (13 – Cheyenne River Sioux)

The BIE should provide additional funding to schools with older, inadequate facilities. In addition to funding for improved ventilation and social distancing, many of the schools have an acute need for funding for facility replacement. [W]e urge the BIE to analyze current school populations and trends prior to the COVID-19 pandemic.

  • BIE should consider the 3-year averages for WSU, compare the WSU to building/facility age and space, and fund those schools who show a need for additional facility funding. As with the CRRSA funds, schools should be able to plan funding for facility upgrades, expansion, and repair.
  • BIE should consider providing additional funding to residential programs. Additional funding is now needed for residential programs to meet the needs of students during and after the COVID pandemic. Consideration should be made by the BIE to provide additional funding to schools and residential programs that continued costly operations throughout the 2020-2021 school year.
  • We strongly encourage BIE to consider distributing a portion of these funds to TPA Education programs, using the updated tribal enrollment data. The ARP provides that the $850 million be distributed to "programs or activities operated or funded by the Bureau of Indian Education," not only BIE-operated schools and universities, and thus the BIE has authority to distribute funding to assist more Native students. (23-Choctaw Nation; see comments for more background)

The Nation supports the use of Weighted Student Unit for determining funds distribution. If the BIE were to take into consideration other factors, the BIE could consider the age of facilities or the needs based on the Operation and Maintenance MAXIMO system, which would show the need for repairs at facilities. Keeping our students safe in sound facilities is important. (25-Oneida Nation)

LLBO believes that pro-rata distribution based upon student count would be a fair and equitable distribution. Our student count is as of Dec 30, 2020, was at 211 students, will you need the updated student count as of Feb 1, 2021? (33-Leech Lake Band; see comments for more background)

We recommend that:

  • The BIE distribute its $850 million allocation under the ARPA on a percentage basis between BIE-funded K-12 schools and TCUs.
  • The BIE reserve no more than 5% of the overall funding and that the use of such funds should be determined through consultation with tribal leaders.
  • The BIE [consider] increased ISEP counts for School Year (SY) 20-21 for schools like KCS with increased enrollment in SY 20-21 as BIE determines how to allocate funding.
  • The WSU needs to be reexamined and improved going forward. Although WSU seems like a fair way to distribute ARPA money to BIE K-12 schools, the weights within WSU are outdated.
  • The BIE consider allowing these funds to be used for expenditures within the BIE-funded school system and TCUs to the maximum extent possible.

(35-Santa Clara Pueblo; see comments for more background)

D. Funds to Special Needs, Head Start, and/or JOM

The Yurok Tribe, like many other tribes, does not have a BIE-funded school in its area. However, the Yurok Tribe is concerned about the welfare of its children and families. We support investment in head start, early head start, and FACE programs. We urge BIE to pay close attention to the students with special needs whose accommodation may be particularly difficult during this pandemic. (30-Yurok Tribe)

The Bureau of Indian Education (BIE) allocation of funds allocated by ARPA should not be confined to only BIE-funded K-12 schools and Tribal Colleges and Universities. Certainly, there are pressing needs at all 218 of those institutions, however other lines of funding administered via BIE should receive a portion of the funds. Just 2.5 percent of the BIA ARPA appropriation would grant a one-time doubling to the Johnson O'Malley (JOM) program, which serves Native children in non-BIE schools. According to the most recent National Indian Education Study, only about eight percent of Native students attend BIE schools. The ARPA statute does not direct BIE to distribute only to BIE institutions, and the decision to do so withholds funding from the 92 percent of Native K-12 students who attend U.S. public schools. While other sources of ARPA funding may be intended for public schools, they are not earmarked for Native students and experience teaches us that unrestricted dollars disproportionately go to non-Natives in these situations, if they reach them at all. The language of ARPA in section 11005 allows BIE to expend funds "for programs or activities operated or funded by the Bureau of Indian Education," which includes JOM. An increase to JOM would ensure that ARPA funds are spent on educational enhancement for Native students and should be implemented by DOI using this allocation. (37-Citizen Potawatomi Nation)

PGST would like to recommend Head Start to be included in the educational pool and support services for our youngest members who are served through home visiting and Head Start programs be included in this distribution. There are limitations in the allocations that DHHS receives for tribal programs and needs continue to go unmet. PGST [also] would like to have Johnson O’Malley to be included in the distribution, a majority of our students attend public schools. Also continued funding for our Academic Coach Program that works with local Public Schools and after school programs. (38-Port Gamble S’Klallam)

2. Investment Areas in Addition to LMS and Facility Improvements

Learning Management Systems (LMS) or related technology investments: It would be difficult to use a LMS if connectivity continues to be an issue. Connectivity continues to be a major issue for some of the schools, due to the remoteness of their location and/or the lack of resources. There is a need for all students and staff to have current devices for virtual learning. Question: Who determines what LMS to use? The schools or the BIE?

  • Facility-related improvements: Maximo continues to be a hindrance to some of the schools who lack the personnel to input information to Maximo. There is a need for a clear definition of facility management issues regarding maintenance, repair, replacement, and construction. Schools continue to have a need for hands on assistance with Maximo to assure the schools have access and understand the data entry access for all schools. Funding to support a Maximo trained data entry position would provide daily support for schools. All schools have safety issues and more now that COVID 19 has been impacted by the CDC safety guidelines for schools. Schools struggle with the ability to access the resources to repair or replace HV AC systems to meet identified CDC guidelines for ventilation; Space utilization for required social distancing and the placement of dividers; Signage for schools with face-to-face school to social distance safely. All schools need generators for when there is a lack of electricity to keep technology available for all. There are schools with outdated lagoons, that need an upgrade or the sewer systems to meet the needs of their school. Waste products need to be managed safely. Due to increased numbers of contaminated waste materials such as PPE items, disposable food containers, and other disposable waste, there is a need to increase equipment for the safe disposal of waste materials. Waste management costs increase additional funding requested to support safe waste management disposal. Access to additional funding for Personal Protective Equipment for identified personnel.
  • Other area of investments:
    • Transportation issues: School bus routes on substandard gravel/dirt roads lack maintenance for safe bus travel on the roads that are rough, washboards, soft surface, slick, road shoulders eroding away, bridge wash outs, buses becoming stuck in mud while transporting students, food, and delivery of student Wi-Fi.
    • Mental and Social-Emotional Support for staff, students, and parent/ guardians: The pandemic mental impact has impacted the entire communities. There is a need for local support to address the social and emotional needs of staff, students, and parents/guardians. School will need financial support to arrange for health personnel at the school to help address health related issues from the pandemic for students and staff. Question: Can funds be used for Special Education, Johnson O'Malley, and Early Childhood (13 – Cheyenne River Sioux)

Chemehuevi requests that fund eligibilities are broadened to cover tribal educational programs also. This would allow our Education Center to be eligible for this funding.( 75 - Chemehuevi Indian Tribe)

BIE should provide maximum flexibility and tribal discretion on how these dollars are spent. For example, funds should be used to ensure our students can return to the classroom safely by improving ventilation and sanitation systems and retrofitting and expanding existing buildings to ensure social distancing. Additionally, funds should be used to increase the technical capacity of our schools by investing in technology that improves online learning, increases access to broadband, and equips our students with tablets and computers should we not be able to return to the classroom in the immediate future and/or should our communities be impacted by a similar, unfortunate event in the future. (57-Navajo Nation)

Learning Management System: Though NIEA appreciates the longstanding need for a learning management system, this system has not arisen because of the pandemic, nor does it significantly impact student health, safety, or ability to access educational services on a daily basis. For these reasons, we oppose the use of emergency funding for the use of a learning management system. Infrastructure Improvements and Repairs: As our schools look at reopening, even our newest facilities are undergoing major renovations to heating and air, plumbing, and other systems to ensure the safety of students, staff, and faculty in the building. Due to space limitations, some school leaders are considering the use of temporary modular classroom units to relieve overcrowding in classrooms. Due to emergent considerations regarding safety of students in reopening classrooms, NIEA strongly supports the use of emergency funds for critical infrastructure improvement and repair. (52-NIEA)

Congress has made clear that funding provided under all the COVID-19 relief bills must be spent solely on activities and programs specifically related to the pandemic. Funding cannot be used to address other needs, no matter how compelling; rather, unused funding must be returned to the federal treasury to reduce the federal budget deficit.

  • A BIE-wide learning management system is not pandemic-related. (Further, this system would cover only BIE operated schools. It could not include the other BIE tribally controlled schools due to privacy issues.) Also, TCUs have their own systems developed over a number of years at great expense to each institution. One system could not address K-12 and higher education issues and needs.
  • To date, BIE has received funding under CARES ($69 million, plus $153.75 million) and CRRSAA ($409.4 million) to specifically address the needs listed. Many schools and TCUs have already addressed these needs, are in the process of addressing these needs, or can best address them at the local level. Centralized funding is not needed for local activities.
  • This funding is intended to address local needs and to support students and families in our communities. As much funding as possible should go to the K-12 schools and TCUs, not to centralized administrations and for-profit contractors. Further, there is no way to ensure centralized funding is equitably distributed. For example, the TCUs have not been permitted to participate in the BIE’s CARES Act programs (mental health counseling and IT infrastructure) despite significant needs and promises by the BIE that TCUs would be included.
  • While TCUs received additional COVID-19 relief funds through the Department of Education, TCUs are required to use at least half of these funds for emergency aid to students. With the support of direct student aid, many TCU students were able to stay enrolled in school while also caring for family needs. This is another example of COVID-19 relief funds supporting local needs.
  • AIHEC recently conducted a survey on the impact of COVID-19 on TCU students (February 2021). The survey revealed a variety of challenges, such as: difficulty adapting to online or hybrid classes, lack of dedicated studying space, lack of broadband access, and decline of mental and physical health. TCUs are uniquely positioned to support TCU students and families during these unprecedented times. However, TCUs need equitable support from the BIE to do so.” (See comment for additional detail on survey results) (45-AIHEC)

As Tribes in rural California are currently experiencing, access to California Public and even private schools is getting more difficult for Native Americans living on or near Federal Indian Reservations. Due to the declining set asides in California Government for previously well funded school programs, that have enabled Native American school aged children better access to schools, transportation is now increasingly being cut back forcing more Native American Families to struggle with alternative methods for providing a safe method of transporting their children to and from school. In short, California schools are in decline and COVID schedule changes have made this decline worse for children from Native families to get safe access to schools. We recommend a small portion of funding for BIE or PSJ funds be set aside for " school transportation/safety improvement programs". Additional factors that should be considered for PSJ programs are those Tribes that are now assessing a Tribal Court or Tribal Public Safety Officer Program. Rural Tribe's should be given priority for these funds having never accessed these programs before. (44-Tuolumne Band)

The Tribe is requesting some funds be set-aside for alternative school programs that do not receive BIE funds currently. The Tribe operates both an afterschool tutoring program and an "in-school" tutoring program where Tribally funded, accredited teachers are made available to native students attending local California/Tuolumne County Schools. The Tribe needs a way to expand its either current tutoring program or open up new K-3 programs on Reservation or adult education GED programs and vocational schools. The Tribe suffers from underemployment and a lack of education and its current sources of funding are limited and shrinking. The Tribe would like to access BIE funds in the future, so the request is for 5% of the funds be set aside for schools to apply for pilot/demonstration progran1s that are new to many Tribes in similar circumstances. (44-Tuolumne Band)

The Choctaw Nation does not recommend holding funds from distribution for centrally managed projects. Funds should be distributed to the field allowing direction to local priorities. There are too many differences in the schools and TCUs to fund projects that can equally benefit all the BIE system. Tribal leaders and school administrators are in the best position to make those decisions based on the specific individual needs of our schools. (23-Choctaw Nation)

The area of need, as seen across the many different locations of BIE school systems would be the facility need for upgrades to the ventilation systems in the older buildings. Another factor is many facilities do not have the space to allow for 6 feet apart, when students return beyond 50%. The Nation’s elementary program will be planning for a 50% return with 30% of our students virtual. It will be hard to allow for all students to be back at half capacity with the current classrooms. Our school staff is aware of schools in the Western part of the country that have written applications and been approved for doublewide classrooms. While the Oneida Nation School System does have a common Learning Management System in Google Class with staff provided training on virtual instruction, this related expense for other school systems may be helpful. The Nation realizes some BIE-funded schools, located in remote areas have not developed an LMS system and some other elementary schools still deliver packets to homes, due to not having connectivity or devices/laptops for all the students. Our school system has planned for this virtual format with the earlier CARES funding and the back orders of devices has been delivered to keep our system working proficiently. The BIE facilities department would be an area that may benefit school systems that are in need of repair or needing urgently to build a new facility, due to the age of the structure, or placement of school programs within a shared facility. This alone would not be the sole reason for a new school structure, but sharing a space, along with a space analysis of the safety needs would be a program that would need additional funding in millions of dollars to assist in construction of additional spaces or buildings that comply with all the school safety measures. (25-Oneida Nation)

Infrastructure dollars will be essential to continue the build-out of broadband and affordable access to broadband that supports student needs and learning and to develop a Learning Management System and related info tech investments for instructional continuity that would benefit the equitable access to education and needs of the LLBO community. (33-Leech Lake Band; see comments for more background)

More funding is needed for our new Distance Learning Program to be able to continue to develop our Learning Management System and related technology for K-12. (38-Port Gamble S’Klallam)

SFIS recognizes that the pivot to remote learning requires the proficient use of digital tools, access to devices, and broadband connectivity for each student. Unfortunately, BIE schools in New Mexico had very limited access to and experience with all three prior to COVID-19, severely disadvantaging Native students. This is compounded in small rural schools without the staff and resources to easily pivot to remote learning. These are the locations who could best benefit by a centralized LMS implementation. Despite that hope and given the current position of IT operations outside of the BIE, we do not recommend that the BIE endeavor to implement a centralized LMS application. Were the BIE to have a dedicated IT Department, with a direct focus on educational technology and school network development, then the BIE would be in the position to grow and extend such services. Until IT support is located within BIE, a better use of the funds would be direct distribution to the schools who have the discretion to address their priority needs. Through the COVID-19 State of New Mexico response, there have been various procurement tools developed to provide devices and connectivity to unserved students. However, due to a lack of data sharing agreements, BIE schools have systematically been excluded from participating in NM State programs to both identify the students and then match them to local low-cost Internet Service Provider options. To increase support for Native students in NM, SFIS emphasizes the importance of executing data sharing agreements and recommends that the BIE actively engage the State to complete this due diligence. This includes an outreach campaign and education for Tribally-controlled schools. (81-Santa Fe Indian School)

3. Other Comments Re: Distribution of the $850M

Regarding the $850 million for BIE related programs and services. We want to ensure that tribal BIE schools and Tribal Colleges have the maximum flexibility in the use of funds. We also hope the distribution methodology will be transparent and more expeditiously than the distribution of funds under last year’s CARES Act, which was unnecessarily repeatedly delayed. (36-White Earth)

While we defer to our membership with BIE and Tribally-operated schools for their responses to the consultation questions, we note the distribution of similar funding under the CARES Act utilizing existing methodologies. While we also note the unreasonable delay associated with these funds, we are not aware of concerns related to the distribution methodology. (32-USET SPF)

Regarding the $850 million for BIE related programs and services, Red Lake wants to make sure Tribal Colleges receive their fair share of these funds. Also, why not allocate some of the funds for the two principal BIE programs that tribes receive direct allocations from: Tribal Scholarships & Johnson O'Malley? The legislation says these funds are for BIE related and funded programs and services, and Tribal Scholarships and Johnson O'Malley are in fact BIE related programs and services. Tribes have covid 19 related funding needs for these two programs! (03-Red Lake Band)

Education should have been a separate consultation time. Education of our future should not have to take a second seat… Questions: (Since these questions were not answered during the Tribal Consultation I am including them in the document. I attended the March 26th, 2021 and March 29th, 2021 tribal consultation. The line was finally opened for me on March 29th, 2021.)

  1. What is the Learning Management System? What does the research show regarding the impacts on Native Children learning? How can it benefit Tribal Schools? Can this be timely? Will it be carried through to the next 5-10 years? What is the effectiveness data?
  2. Regarding the Mental Health funding that the Bureau of Indian Education held back, what is the status? The Tribal Schools keep asking. The student need is now. The staff need is now. If this funding was provided to the schools that have students on site they would have been already been receiving services regularly.
  3. If schools utilize their funding to build/create/procure facility space that is needed for safe distancing children how is BIA facility going to work new space so the schools are receiving Operation and Maintenance funding immediately? How can you ensure the timely scheduling and receiving timely BIA inspection completion? How can you ensure these are met and that it will be expedited to include to BIA Engineering and approval process?
  4. What is meant by investments in Facilities for adequate air ventilation? How can that be fair to all schools? Schools are always pitted against each other to funding. What is meant by centrally invested? By the BIE? For BIE schools or for Tribally Controlled Schools?
  5. 10% or $15,385,000 was reserved by the BIE from the CARES act. What was that utilized for?
  6. Congress requested a report by March 20, 2021 regarding IT and the BIE Broadband plan. There was FY21 increases in the funding level. Where is that plan and how can we get a copy? Can you elaborate?


  1. Additional funding should be set aside and provided to the schools that provided an on-site education program as they incurred extra costs for safe guarding students opposed to those schools that chose to have virtual school. This additional funding should be according to how many days that onsite education was held.
  2. The Mental Health program funding should have been sent directly to all schools with the requirement that it was earmarked for direct student mental health and socio-emotional health services. This is the most effective way to ensure that funding is spent the way it was intended. This would have ensured timely services to students that needed them. The additional financial resources for mental health would have been on-site at the schools and already operational.
  3. Funding needs to be focused for Early Childhood Programs that are operated in and by the Schools. Strong Early Childhood Education can make the most impact early rather than trying to catch up children that are 2-3 grade levels behind later. Children are coming to school not ready for Kindergarten. The SWO Data is stating that. We need to invest in our early learners and their teachers to ensure that they are ready to learn. Another option should be a Junior Kindergarten focus or two year Kindergarten. Why have a child always struggling when given another year they could be at the top of their class. The maturation level of Native Children needs to be researched and compared to their non-native peers.
  4. Family and Child Education (FACE) needs to have an increase funding. This funding level has been stagnant for years. Yearly teaching and support staff receive a cost of living increase and perhaps a step increase and yet the funding does not increase to accommodate this. Inflation of supplies, instructional tools and materials also increases with the changes in our economy but funding remains the same. There also is no availability to write for extra funding for exemplary programs or implement new projects internally.
  5. Funding should be fairly divided by WSU for all K-12 students. There are 183 schools and 35 tribal colleges which in percentage is 84% are Tribal Schools and 16% are Tribal Colleges. That funding should be split as such according to the WSU’s and Higher Ed Student Count. The formula should be skewed that the K-12 students should receive the greatest amount of funding for the basic compensatory education. K-2 Education should receive the greatest amount of funding so that it ensures a stronger education program which mandates a lower teacher and student ratio.
  6. ISEP funding needs an increase in the base funding. The Base funding has shown a little increase lately but it is not adequate to provide for student needs. ISEP funding is primarily utilized for Teacher salaries and thus with more funding more instructional staff can be employed.
  7. Invest in Professional Develop Funding for a Grow Your Own Teacher program at each school. Teacher shortages in Indian Country is well documented and yet there is little funding to develop full programs that support teacher education. Programs should be operated at every school to help off-set the teacher shortages across the nation. Mentoring programs should be mandated to support teachers in the schools which should be monitored by the accreditation agencies or other oversight.
  8. Learned Management Systems (I have many questions regarding this!) should be a site-based management decision. The schools should be provided the funding for this and allowed to tailor the programs for the student’s needs. This should be a decision by the School Administrative Teams that analyze quarterly informative assessment data, other school informative assessment data (Vocabulary, writing, science, math or other assessments) and the annual high stakes assessment data. This should not be a decision that is made for the schools.
  9. Funding for school facilities needs to be increased. Currently the level of Operation and Maintenance funding is below 50% of the need. …Then we have to wonder why the BIE school buildings are not well maintained and have fallen in disrepair. To mitigate the problem the administrators have to supplement this budget and it is supplemented through Instructional funding (ISEP) for most part. Thus it causes a shortage in the Instructional Program but in this situation what do you do… you have to keep children safe in their educational environment.
  10. It is unknown where the past CARES Act funding for technology initiatives went. They were not equally distributed and the schools nor students at Sisseton-Wahpeton Oyate did not benefit. A report needs to be requested on the Technology funding and who is benefited.
  11. Adequate Construction funding needs to be requested and appropriated for the replacement school listing. Additional funding needs to be allocated for other facility repairs to include upgrading HVAC and other ventilation systems. Windows that open and allow fresh air to students need to be researched.
  12. Funding should be provided to all schools to provide internet access for K-12 and college students equally rather than the BIE picking and choosing who shall receive the IT and Broad band extra funding.
  13. Continue to provide support and funding for our JOM Programs for our students that attend public schools to help equalize education availability and resources. (08-Sisseton-Wahpeton Oyate)

BIE Process for Distributing $850M ARP Funds – The rationale for employing an equitable distribution of BIA ARP funds also applies to the BIE funds. Small Tribes, such as ours, have education-related needs that are presently not being met by the BIE. We could certainly benefit from additional funds to be directed toward our education components. Although none is presently being funded by the BIE or BIA, we could make good use of additional ARP funds for our education program. To limit Tribal recipients of the additional BIE ARP funds only to Tribes with existing BIE programs, compounds the existing problem of underfunding or non-funding of

similar programs operated by small Tribes. Congress could not have intended for Tribes, such as ours, to be left out of a funding distribution only to see Tribes with presently-funded programs widen the disparity in funding between the “haves” and the “have nots.” (09-Kialegee Tribal Town)

The Community does not operate a BIE school, college, or university; as the $ 850 million is strictly for current operating schools; as this funding does not apply to the Community in that context. However, there should be consideration of the native students attending public schools across the United States. According the National Indian Education Association (NIEA), 72% of Native students attend public schools. The Community' s student population majority attend the local public- school district or surrounding charter schools. There should be funding set aside to support our students outside the BIE school operation; either through education program funding or scholarship line items. (11-Ak-Chin Indian Community)

We do not have BIE schools in our region, but agree that those schools should be modernized and maintained up-to-code, as all school children and young learning adults, need to enjoy the safety, comforts and benefits of modern schools. (15-Asa’carsarmiut)

In response to your questions regarding the Bureau of Indian Education: Chemawa School is within our Service Area and it is essential to fill the Superintendent vacancy as soon as possible. It is our position that funds should be used on the Chemawa campus to repair/upgrade buildings and other areas, invest in the swimming pool by way of facilities maintenance and money, and provide additional classes like art, music, and sports. The administrators at the Bureau of Indian Education needs to pay attention to the needs of Chemawa. (19-Confederated Tribes of Siletz)

Both prior to and throughout the pandemic, the Internet speeds at a number of TCUs – particularly at their satellite campuses – are at or below 100 mbps. No other institutions of higher education in the country have Internet speeds this slow, yet no TCUs have been included in the BIE’s announced commitment to use its own “10 percent reserve fund” to pay the costs needed to “ensure all BIE schools have Internet speeds of at least 100 mbps.” Nor are TCUs able to participate in the federal E-rate program, which provides hundreds of thousands of dollars to BIE K-12 schools each year. TCUs must bear the costs of improving Internet access solely on their own, using their own funds, yet throughout the pandemic, they have provided equipment, hot spots, and monthly Internet access payments to students and their families, benefiting hundreds or thousands of BIE K-12 students. (45-AIHEC)

Since BIE-funded educational institutions have unique and varied needs, we must retain the flexibility to make the kinds of local decisions that best meet the needs of the students we all serve. For this reason, SFIS also contends that the BIE should not impose any arbitrary restrictions on how these funds may be used, including timeframes or deadlines on expenditures. (81-Santa Fe Indian School)

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