oversight

Special Education: Estimates of Handicapped Indian Preschoolers and Sufficiency of Services

Published by the Government Accountability Office on 1990-03-05.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                          ,”   .’


%-


        United   States   General   Accounting   Office             I

GAO‘,   Briefing Report to Congressional
        Requesters
GAO
      United States
      General Accounting  Office
      Washington, D.C. 20548

      Human Resources        Division

      B-238080

      March 5. 1990

      The Honorable Daniel K. Inouye
      Chairman, Select Committee on Indian Affairs
      United States Senate

      The Honorable Augustus F. Hawkins
      Chairman, Committee on Education and Labor
      House of Representatives

      This report discusses our estimates of (1) the number of handicapped
      Indian preschoolers on the 63 reservations with schools administered by
      the Department of the Interior’s Bureau of Indian Affairs (BIA) and (2)
      the sufficiency of services they receive. It responds to the requirement
      in Public Law loo-297 that we review BIA’S program for educating these
      preschoolers. This legislation requires us to determine the number of
      these preschoolers aged 3 and 4 on (1) all 297 federally recognized
      Indian reservations and (2) the 63 reservations with BIA schools receiv-
      ing BIA-funded services. Concerning the preschoolers on these 63 reser-
      vations, the act further requires us to determine (1) the sufficiency of
      the services these preschoolers receive and (2) the number who can be
      expected to attend BIA schools when they reach school age. This report
      elaborates on our April 28, 1989, briefing to your offices.

      We obtained the information required by Public Law loo-297 primarily
      through the use of a data collection instrument completed by BIA’S spe-
      cial education coordinators. These 32 coordinators, located in BIA field
      offices, are responsible for special education-related matters on the 63
      reservations with BIA schools.

      To estimate the number of handicapped Indian preschoolers on reserva-
      tions and in all areas of Alaska and Oklahoma,’ we used patient registra-
      tion data maintained by the Indian Health Service (IHS) and prevalence
      rates for handicapping conditions developed by the Native American
      Research and Training Center (University of Arizona and Northern Ari-
      zona University). We analyzed available school attendance data for
      Indian children on reservations with BIA schools to estimate the number
      of handicapped Indian preschoolers who might attend BIA schools when
      they reach school age.



      ‘Because of the large Indian and Native Alaskan population who live in nonreservation areas in
      Alaska and Oklahoma, we were asked by congressional staff to estimate the number of handicapped
      Indian preschoolers in these states.



      Page 1                                GAO/HRD-9061BR      Special Education   for Indian Children
             B-238080




             To determine policies and procedures for, as well as opinions of, special
             education programs for handicapped Indian preschoolers, we inter-
             viewed various officials from BIA, the Department of Education, Head
             Start, as well as IHS and state education officials in the 20 states with BIA
             schools on reservations. Our work was done from September 1988
             through July 1989 in accordance with generally accepted government
             auditing standards (see pp. 12-17).


             Public Law 99-457, the 1986 amendments to the Education of the Handi-
Background   capped Act (Em), required the Department of the Interior to assure that
             all handicapped Indian preschoolers aged 3 to 5, living on reservations
             with BIA schools, receive a “free and appropriate” education, beginning
             in school year 1987-88. State and local education agencies, says a
             Department of Education policy memorandum, must provide a free and
             appropriate education to handicapped Indian preschoolers on reserva-
             tions without BIA schools. Handicapped Indian preschoolers living on
             reservations with BI.4 schools have the option, when available, of attend-
             ing BIA, public, or private preschool classes.

             For handicapped preschoolers, an “appropriate” education includes
             both special education and related services. Determining the services
             needed, as well as diagnosing children thought to have handicapping
             conditions, is the responsibility of multidisciplinary evaluation teams.
             Their diagnoses, as well as the services they recommend, are docu-
             mented in each child’s Individual Education Program (IEP). Federal regu-
             lations require that IEPS list all services recommended or that they
             justify why any recommended services are excluded.

             BIA’S regulations also require it to conduct annual “child-find”              activities.
             These regulations (25 C.F.R. 45.11) state that each           BIA   field office

             “...must insure that every child within its jurisdiction between the ages of birth and
             twenty-two years who is suspected of being handicapped and in need of special edu-
             cation and related services is identified and located.”

             BIA special education programs operate with EHA funds provided by the
             Department of Education. EHA limits BIA'S funding to an amount not to
             exceed 1.25 percent of the aggregate amount awarded to the states for
             providing special education services to handicapped children (see pp.
             10-12).




             Page 2                            GAO/HRD-90-61BR   Special Education   for Indian Children
                        B238080




                        We estimate that nearly 3,000 handicapped Indian preschoolers aged 3
Significant Number of   and 4 live on the 63 reservations with BLA schools. Another 5,500 to
Handicapped Indian      9,800 live on the other 234 federally recognized reservations or in the
Preschoolers May Be     states of Alaska and Oklahoma.” However, only 838 of these 3,000 were
                        receiving special education services in school year 1988-89.
Unserved
                        On the reservations with BW schools, about 2,110 of the estimated 2,948
                        handicapped indian preschoolers may need, but were not receiving, spe-
                        cial education services in school year 1988-89. The other 838 were
                        receiving services from one or more service providers, including BIA,
                        Head Start, IHS,and local public school districts. BIA provided at least
                        some funding for 437, or 52 percent, of the 838 preschoolers receiving
                        services. About 1,237 of the 2,110 preschoolers who, we estimate, may
                        need special education services are those who have not been individu-
                        ally identified and located, as required by 25 C.F.R. 45.11. Consequently,
                        we are uncertain of the precise number of preschoolers who actually
                        need special education services (see pp. 18-22).


                        Of the 791 handicapped Indian preschoolers with IEPS,” at least 24 per-
Services Provided       cent were receiving fewer services than their IEPS prescribe. Further-
Preschoolers Are        more, because IEPS may lack all the services handicapped children need,
Insufficient            the actual percentage of children underserved may be higher than the
                        24 percent we calculated. In this regard, both our survey of BIA coor-
                        dinators and recent testimony presented to the Senate Subcommittee on
                        Disability Policy indicate that in many cases, for both BIA and public
                        schools, IEPS only list those services educational agencies are able to pro-
                        vide, rather than all the services a child needs (see pp. 23-28).




                        ‘Available data permitted us to provide estimates for 249 of the 297 federally recognized reserv;~-
                        tions. Indians living on the 48 reservations for which data were unavailable represent about 2 percent
                        of the Indian population living on reservations.

                        “We only analyzed the sufficiency of services provided to preschool children with IEPs. Of the 791
                        children with IEPs, 789 were receiving services. In addition to these 789, another 49 children were
                        receiving services but lacked IEPs.



                        Page 3                                  GAO/HRDSO-GlBR       Special Education   for Indian Children
                         B-238080




                             officials told us that many handicapped Indian preschoolers received
Major Reasons for        BIA
                         insufficient services because of shortages of qualified personnel and
Insufficient Services-   inadequate funding to hire them. Concerning personnel shortages, 16 of
Personnel Shortages      the 32 BIA coordinators reported that on the reservations they serve, at
                         least 6 1 specialized staff vacancies existed. Funding limitations, which
and Inadequate           BIA officials told us were brought about because of an increase in its
Funding                  service population and the lack of any additional funding source for its
                         preschool programs, resulted in BIA’S providing only $2.7 of the $4.3 mil-
                         lion requested by its field offices to serve handicapped preschool chil-
                         dren in school year 1988-89 (see pp. 29-33).


                         BIA, the Department of Education, and the states have differing interpre-
Agency Responsibility    tations about who must provide services to handicapped Indian children
for Special Education    on reservations with BIA schools. These differences could make efforts
Subject to               to serve these children difficult and contribute to BIA’S inability to serve
                         some children for whom it is responsible.
Interpretation
                         We believe that as a condition of accepting EHA funds, Interior assumes
                         primary responsibility for assuring services to all handicapped
                         preschoolers living on reservations with BIA schools. This assurance
                         means that when other non-BIA agencies do not provide special educa-
                         tion services that a handicapped preschooler needs, Interior must pro-
                         vide them. In those instances in which non-BIA agencies agree to provide
                         handicapped Indian preschoolers with special education services, Inte-
                         rior may be able to discharge its assurance responsibility by, for exam-
                         ple, monitoring the services being provided.

                         In our opinion, the Departments of Education and Interior and certain
                         states misunderstand what EHA requires of Interior. Interior believes BIA
                         is only responsible for children enrolled in its programs and that it may
                         supplement other providers’ services. Education and some states believe
                         that BIA is solely responsible for all Indian children on reservations with
                         BIA schools.


                         The difference in views concerning Interior’s EHA responsibilities has the
                         potential for allowing handicapped Indian preschoolers to be unserved.
                         When there are significant differences of opinion about who is primarily
                         responsible for serving handicapped Indian children, especially when
                         neither BIA nor the state accepts primary responsibility, cooperation in
                         meeting the needs of these preschoolers may be difficult to obtain. Fur-
                         ther, when agreements are not reached with other agencies to provide



                         Page 4                        GAO/HRDSOSlBR   Special Education   for Indian Children
                       B-238080




                       services, Interior’s position- that it is not primarily responsible-cre-
                       ates the potential for children to be unserved (see
                       pp. 33-34).


                       Most of the enrollment data needed to reliably estimate the number of
Preschoolers Who May   handicapped Indian preschoolers who might, upon reaching school age,
Attend BIA Schools     attend BIA schools rather than the public or private schools was unavail-
                       able. However, the data provided for 20 of the 63 reservations with BIA
                       schools indicate that approximately 50 percent of the total eligible kin-
                       dergarten and first-grade Indian students attend BIA schools (see
                       pp. 34-35).


                       At the time of our review, BIA had not individually identified and located
Conclusions            all preschool Indian children who are thought to be handicapped, as its
                       regulations, 25 C.F.R. 45.11, require. We believe that if BIA fully com-
                       plied with its child-find regulations, it would be better able to work with
                       other service providers-such      as Indian Head Start programs and local
                       public school districts-to   meet the special educational needs of handi-
                       capped Indian preschoolers. As a result, these preschoolers would have
                       a better chance of receiving the services that EHA legislation requires
                       they be provided (see p. 35).


                       We recommend that the Secretary of the Interior direct the Assistant
Recommendation to      Secretary for Indian Affairs to fully implement the requirements of 25
the Secretary of the   C.F.R. 45.11. Concerning this, the Assistant Secretary should take
Interior               actions to assure that on the 63 reservations with BIA schools, each BIA
                       field office annually identifies and locates every preschooler thought to
                       be handicapped and in need of special education services (see p. 36).


                       In commenting on a draft copy of this report, the Department of the
Agency Comments        Interior stated that it agreed with many of our findings (see app. VI).
                       However, the Department stated that BIA had successfully implemented
                       annual child-find activities for many years. We disagree with the
                       Department’s statement concerning Indian preschoolers. BIA’S special
                       education coordinators estimated there are about 1,237 Indiar
                       preschoolers who are thought to be handicapped, but have not been
                       individually identified and located.




                       Page 5                        GAO/HRD90431BR   Special Education   for Lndian Children
B-238080




The Department also provided comments dealing with several sections
of the report that it believes warrant further clarification and explana-
tion. These comments were considered and incorporated as appropriate
(see p. 59).


Copies of this report are being sent to the Secretaries of the Interior,
Health and Human Services, and Education, as well as other interested
parties. Please call me on (202) 275-1793 if you or your staff have any
questions about this report. Other major contributors are listed in
appendix VII.




                            v
Franklin Frazier
Director, Education and
   Employment Issues




Page 6                       GAO/HRJMO-61BR   Special Education   for Indian (‘hildrrn
Page 7   GAO/HRD-90-61BR   Special Education   for Indian Children
Contents


Letter                                                                                                            1

Special Education:                                                                                           10
Estimates of              Background                                                                         10
                          Objectives, Scope, and Methodology                                                 12
Handicapped Indian        Significant Number of Handicapped Indian Preschoolers                              18
Preschoolers and               May Be Unserved
Sufficiency of Services   Services Provided to Handicapped Indian Preschoolers                               23
                               Are Insufficient
                          Major Reasons for Insufficient Services--Personnel                                 29
                               Shortages and Inadequate Funding
                          Agency Responsibility for Special Education Subject to                             33
                               Interpretation
                          Handicapped Indian Preschoolers Who May Attend BIA                                 34
                               Schools
                          Conclusions                                                                        35
                          Recommendation to the Secretary of the Interior                                    36

Appendixes                Appendix I: Technical Description of the Methodologies                             38
                              Used to Estimate the Number of Handicapped Indian
                              Preschoolers
                          Appendix II: Estimated Handicapped Indian Preschool                                42
                              Population by State
                          Appendix III: Estimated Handicapped Indian Preschoolers                            43
                              on Reservations With BIA Schools
                          Appendix IV: Diagnosed Handicapping Conditions Among                               46
                              Indian Preschoolers
                          Appendix V: GAO’s Data Collection Instrument                                       48
                          Appendix VI: Comments From the Department of the                                   58
                              Interior
                          Appendix VII: Major Contributors to This Report                                    68

Tables                    Table 1: Total EHA Funding in School Years 1986-87                                 11
                              Through 1988-89
                          Table 2: BIA’s Special Education Programs in School                                12
                              Years 1986-87 Through 1988-89
                          Table 3: Indian Kindergartners and First Graders                                   35
                              Attending BIA Schools
                          Table I. 1: Comparison of Estimates at 24 Reservations                             41




                          Page 8                       GAO/HRD-9041BR   Special Education   for Indian Children
          Contents




Figures   Figure 1: Summary of Public Law loo-297 Requirements
          Figure 2: States With Federally Recognized Indian
               Reservations
          Figure 3: Number and Location of Handicapped Indian
               Preschoolers
          Figure 4: BIA’s Potential Service Population-63                                     21
               Reservations
          Figure 5: Agencies Serving Handicapped Indian                                       22
               Preschoolers
          Figure 6: Preschoolers Who May Need Services                                        23
          Figure 7: Preschoolers Do Not Receive All IEP-Prescribed                            25
               Services
          Figure 8: Do IEPs Contain All Services Needed?                                      27
          Figure 9: Why Do IEPs Lack Needed Services?                                         30
          Figure 10: Local Examples of Hiring Difficulties                                    31
          Figure IV. 1: Diagnosed Handicapping Conditions                                     4-i




          Abbreviations

          BIA        Bureau of Indian Affairs
          EHA        Education of the Handicapped Act
          GAO        General Accounting Office
          IEP        Individual Education Program
          IHS        Indian Health Service
          OCR        Office for Civil Rights


          Page 9                       GAO/HRD-90-6lBR   Special Education   for Indian Children
SpecialEducation: Estimatesof Handicapped
Indian Preschoolersand Sufficiency of Services

               The Education of the Handicapped Act (EHA) is the principal federal leg-
Background     islation for providing federal assistance to state and local educational
               agencies; this legislation enables these agencies to meet the special edu-
               cational and related service needs of handicapped children. EHA requires
               each state receiving federal assistance to provide a “free and appropri-
               ate” public education to all handicapped children regardless of the
               nature or severity of the handicapping condition. For handicapped chil-
               dren, an “appropriate” education includes both special education, and
               related services.

               Special education is instruction specifically designed to meet the unique
               needs of a handicapped child. Related services are the developmental,
               corrective, and other support services required to help the handicapped
               child benefit from special education instruction. Examples of related
               services include physical and occupational therapy, counseling, and
               speech pathology. In this report, the term “special education services”
               includes both special education instruction and related services.

               Determining the special education services handicapped children need is
               the responsibility of multidisciplinary evaluation teams comprised of
               education and related service specialists. These teams evaluate children,
               determine their handicapping condition(s), and recommend the special
               education services needed to improve educational performance or ability
               to learn or both. Federal regulations require that all recommended ser-
               vices for each child be included in a document called an Individual Edu-
               cation Program (IEP). In addition, an IEP must justify why any
               recommended services are excluded.

               Before 1986, EHA required the states to provide special education ser-
               vices only to handicapped children aged 5 through 17. However, handi-
               capped children younger than 5 or older than 17 could be served if
               consistent with state law or practice. In addition, by providing incentive
               grants, EHA encouraged the states to serve handicapped preschoolers
               aged3to5.

               In 1986, the Congress, responding to advances in the understanding of
               how very young children develop and studies of the long-term benefits
               of early intervention programs, amended EHA to more adequately
               address the educational needs of handicapped infants, toddlers, and
               preschoolers. The 1986 amendments (P. L. 99-457) authorized funding
               for those states that choose to provide services to handicapped infants




               Page 10                      GAO/HRDMMlBR    Special Education   for Indian Children
                                       Special Education: Estimates of Handicapped
                                       Indian Preschoolers and Sufficiency
                                       of Services




                                       and toddlers (children from birth through the age of 2). The amend-
                                       ments also require the states to begin serving all handicapped
                                       preschoolers, children aged 3 through 5, no later than October 1, 1990.

                                       The Department of Education administers EHA and distributes funds to
                                       the states. The funds allocated and the number of handicapped students
                                       in the United States receiving special education services in school years
                                        1986-87 through 1988-89 are highlighted in table 1.

Table 1: Total EHA Funding in School
Years 1986-87 Through 1988-89                                                                           School year
                                                                                             1986-87        1987-88            1988-89
                                       Funds allocated     (in btllions)                        $1.1               $1.3             $1 4
                                       Students   served                                    4.166,692       4,235,263                     d
                                       aThese data were unavailable




BIA’s Role in Special                  Under EHX, BIA is similar to a state education agency. Like the states. BIX
                                       receives its funding from the Department of Education and must pro-
Education                              vide special education services to handicapped children living on reser-
                                       vations with schools for Indian children operated or funded by the
                                       Department of the Interior (BL4 schools). Handicapped Indian
                                       preschoolers living on reservations with BIA schools can attend either
                                       BIA, public, or private preschool classes, when those options exist.

                                       Unlike the states, BIA’S funding is not allocated on a per child basis.
                                       Instead, BIA receives an annual percentage, that is, a set-aside (up to
                                       1.25 percent), of the aggregate amount of EHA funds awarded to states
                                       for providing special education services to handicapped children. This
                                       aggregate amount is known as part B funds.

                                       Public Law 99-457 required BIA to begin serving handicapped Indian
                                       preschoolers by school year 1987-88,3 years before states are mandated
                                       to begin providing services to handicapped preschoolers in the nation’s
                                       public schools. To fund special education services for handicapped
                                       Indian preschoolers, the 1986 amendments increased the set-aside from
                                       an amount not to exceed 1 percent to an amount not to exceed 1.25 per-
                                       cent of the part B funds awarded to the states.

                                       As part of its special education program, BU’S regulations requires it to
                                       conduct annual “child-find” activities. These regulations, 25 C.F.R.
                                       45.11, state that each BIA field office



                                       Page I1                              GAO/HRD9@61BR      Special Education    for Indian Children
                                   Special Education: Estimates of Handicapped
                                   Indian Preschoolers and Sufficiency
                                   of Services




                                   “...must insure that every child within its jurisdiction between the ages of birth and
                                   twenty-two years who is suspected of being handicapped and in need of special edu-
                                   cation and related services is identified and located.”

                                   EHA funds allocated to BL4 special education programs for handicapped
                                   Indian students during the past 3 school years are shown in table 2.

Table 2: BIA’s Special Education
Programs in School Years 1986-87                                                                             School year
Through 1988-89                                                                               1986-87            1987-88               1988-89
                                   EHA funds allocated
                                     To states      (In mllllons)                              $1,1633           $1,330.0              $1,431 7
                                     To BIA (In mllllons)                                         $11.5               $16.5              $177
                                     Percentage                                                      99%               123%                1 23%
                                   BIA allocatlon       (In mllllons)
                                     School-age       program                                     $11 5               $5.75               $15 0
                                                                                                                                _..-        .-
                                     Preschool       program                                             a               75                $2.7
                                   Children    served
                                     School-age         program                                   5,366               6,311 ---____       6,762
                                   Preschool         Droaram                                             b                  b                   b

                                   aData are unavailable
                                   bBIA does not know the actual number of handicapped lndlan preschoolers aged 3 through 5 it provided
                                   services to In the last 3 school years However, the Department of the Intenor estimates that 100 handl-
                                   capped preschoolers aged 3 through 5 were served In school years 1986-87, 1,200 In 1987-88, and
                                   1,600 In 1988-89


                                   Oversight of BIA'S special education programs is provided by the Branch
                                   of Exceptional Education, Office of Indian Education Programs, in
                                   Washington D.C. Within the branch, an early childhood program special-
                                   ist is assigned to develop the programs for handicapped Indian children
                                   from birth through the age of 5.

                                   The branch develops the policies and regulations BIA schools must follow
                                   when implementing their special education programs. At the field office
                                   level, 32 special education coordinators are responsible for ensuring that
                                   BIA schools comply with applicable policies and regulations.



Objectives, Scope, and             School Improvement Amendments of 1988 (P. L. 100-297) required that
Methodology                        GAO conduct a study of BIA’S preschool special education program. The
                                   study’s requirements are shown in figure 1.




                                   Page 12                                  GAO/HRD-90-6IBR       Special Education     for Indian Children
                           Special Education: Estimates of Handicapped
                           Indian Preschoolers and Sufficiency
                           of Services




Figure 1


           GAO Summary of Public Law
               loo-297 Requirements
                  GAO asked to determine
              l   Number & location of handi-
                  capped Indian preschoolers
              l   Number receiving BIA-funded
                  services
              l   Number to attend BIA schools
              l   Sufficiency of service
                  & unmet needs
                           Based on discussions with staff from the House Education and Labor
                           Committee and the Senate Select Committee on Indian Affairs, we
                           agreed to obtain estimates of the number of handicapped Indian
                           preschoolers who live on each of the nation’s federally recognized reser-
                           vations and in all areas of Alaska and Oklahoma. Committee staff mem-
                           bers asked us to estimate the number of handicapped Indian
                           preschoolers in Alaska and Oklahoma because of the large Indian popu-
                           lation living on nonreservation land in these states.




                           Page 13                               GAO/HRD-90-61BR   Special Education   for Indian   Children
Special Education: Estimates of Handicapped
Indian Preschoolers and Sufficiency
of Services




We identified 297 federally recognized reservations in 3 1 states (fig. 2).l
Sixty-three reservations in 20 states have BIA schools. At least 20 of
these 63 reservations also have public schools located within the reser-
vation boundaries. The other 234 reservations have public or private
schools or both, but no BIA schools.




‘This total includes (1) 283 reservations recognized by BIA’s Division of Real Estate Services as of
August 8. 1988; (2) 13 areas administered as reservations by BIA’s Sacramento Area Office because
of B1.4’~interpretation of a court order (Tillie Hardwick vs. United States of America, C-79.L’ilO-SLV):
and (3) 1 reservation established by the Congress on September 9, 1988.



Page 14                                  GAO/HRD-906lBR       Special Education   for Indian Children
                                           Special Education: Estimates of Handicapped
                                           II&II    Preschoolers and Sufficiency
                                           of Services




Figure 2: States With Federally Recognized Indian Reservations




                                                      No federally recognized    reservations   in these 19 states
                                              m       Reservations   without BIA schools are in these 8 states

                                              @g&3     eservations   with BIA schwls     are in these 20 states

                                                      Reservations   and off-resection     schools are in these states



 -

                                            We used two separate methodologies to estimate the number of handi-
                                            capped Indian preschoolers. For the 63 reservations with BIA schools,
                                            the coordinators obtained estimates for us. For the reservations without
                                            BIA schools and for all areas of Alaska and Oklahoma, we obtained esti-
                                            mates by multiplying estimates of the number of Indian preschoolers by


                                            Page 15                                        GAO/BRD-90-61BR           Special Education   for Lndian Children
Special Education: Estimates of Handicapped
lndian Preschoolers and Sufficiency
of Services




prevalence rates of handicapping conditions among Native American
children.? We used these methodologies because neither BIA, the Bureau
of Census, the Department of Education, nor 19 of the 20 states with
reservations and BIA schools had data documenting the number of handi-
capped Indian preschoolers. The details of these methodologies are dis-
cussed in appendix I.

Using the two methodologies, we obtained estimates for 249, or 84 per-
cent, of the 297 reservations and for the entire states of Alaska and
Oklahoma. These 249 reservations contain about 98 percent of the
Indian population living on reservations.3 The 249 reservations include
all 63 reservations with BIA schools and 186, or 79 percent, of the 234
reservations without these schools. The estimates we obtained are
reported by state in appendix II. The estimates provided by the coor-
dinators for each of the 63 reservations with BIA schools are in appendix
III.

The coordinators also identified the total number of handicapped Indian
preschoolers receiving BIA funded services. The data collection instru-
ment (see app. V) we developed for their use in estimating the number
of handicapped Indian preschoolers also required the coordinators to
specify which ones received sL4-funded services.

We were unable to obtain a comprehensive estimate of the number of
handicapped Indian preschoolers who will attend BL4 schools because
data were unavailable for most reservations with these schools. We
requested attendance data about all kindergarten and first-grade Indian
children attending BIA, public, or private schools in school years 1986-
87, 1987-88, and 1988-89 on each of the 63 reservations with BIA
schools. BIA officials provided attendance data for all BIA schools on all
63 reservations. However, attendance data for public and private
schools was provided for only 20 of the 63 reservations. Using the data
provided, we calculated the percentage of Indian children in kindergar-
ten and first grade attending BIA, public, and private schools.

To determine the sufficiency of services, the coordinators provided data
on the services needed by, and services being provided to, handicapped

‘We obtained estimates of the number of Indian children from the Indian Health Service (IHS) and the
prevalence rates from a Native American Research and Traning Center study.
“The 48 reservations for which no data were available do not materially affect our estimates. Popula-
tion estimates contained in a BIA publication, “Indian Service Population and Labor Force Estimates”
(Jan. 1989), show that these reservations contain about 2 percent of the total Indian population who
live on reservations.



 Page 16                                GAO/BRD-9@61BR       Special Education   for Indian Children
Special Education: Estimates of Handicapped
Indian Preschoolers and Sufficiency
of Services




Indian preschoolers with IEPS. The coordinators collected this informa-
tion from the various providers of special education services on the res-
ervations, such as BIA-Operated programs, Indian Head Start, and local
public schools. Using the data provided, we classified each child into one
of three categories: those receiving full service, partial service, and no
service. “Full service” means that the child was receiving all the ser-
vices specified in his or her IEP,at the frequency prescribed. “Partial
service” means that the child was receiving some services listed in the
IEP, but either some services were not provided or were provided less
frequently than prescribed. “No service” means the child failed to
receive any IEP-prescribed service.

We also surveyed the coordinators to determine if the services listed in
IEPS were all the services handicapped children need. We asked them if
IEPS contain all the services recommended by multidisciplinary  evalua-
tion teams and, if IEPSlacked some recommended services, why.

In doing our work, we visited four reservations -- Cheyenne River,
South Dakota; Gila River, Arizona; Isleta, New Mexico; and portions of
the Navajo, Arizona. At the Cheyenne River and Gila River reservations,
we observed special education classes, reviewed IEPS,and interviewed
BIA, Head Start, and public school officials. At the Isleta and Navajo res-
ervations, we observed special education classes and interviewed school
officials and BIA’S coordinators. To determine policies and procedures
for, as well as opinions of, special education programs, we also inter-
viewed officials in the Washington, D.C., area headquarters of BIA, the
Department of Education, Head Start, and IHS. To determine the views of
state officials working in special education as to the states’ responsibil-
ity to handicapped Indian preschoolers, we spoke with officials in 20
states with reservations and BIA schools.

Our field work was done from September 1988 through July 1989. We
did this review in accordance with generally accepted government audit-
ing standards.




Page 17                              GAO/BRDSO-6lBR   Special Education   for Indian Children
                         Special Education: Estimates of Handicapped
                         Indian Preschoolers and Sufficiency
                         of Services




                         Only 838 of the estimated 2,948 handicapped Indian preschool living on
Significant Number of    reservations with BIA schools received special education services in
Handicapped Indian       school year 1988-89. The majority (1,237) of the other 2,110 children
Preschoolers May Be      thought to be handicapped have yet to be specifically identified or
                         located as required by federal regulations. Consequently, we are uncer-
Unserved                 tain of the precise number of preschoolers who actually need special
                         education services.


Number and Location of   For school year 1988-89, we estimate that about 8,500 to 12,800 handi-
                         capped Indian preschoolers aged 3 and 4 live on 249 of the 297 federally
Handicapped Indian       recognized reservations and in Alaska and Oklahoma (fig. 3).” An esti-
Preschoolers             mated 2,948 of these preschoolers live on the 63 reservations with BIA
                         schools. Appendices II and III contain detailed information on the
                         number of handicapped Indian preschoolers who live in each state with
                         federally recognized reservations and on the 63 reservations with BIA
                         schools.




                         4.4sdiscussed in appendix I, the lower end of this estimate, 8,500, could be understated by about 8
                         percent. In addition, the upper end, 12,800, could be overstated by about 21 percent.



                         Page 18                                 GAO/HRD!4O-61BR      Special Education   for Indian Children
                     Special Education: Estimates of Handicapped
                     Indian Preschoolers and Sufficiency
                     of Services




Figure 3


       GAQ Number & Location
           of Handicapped Preschoolers

            l About 8,500 to 12,800 on
              249 of 297 reservations
              in Alaska & Oklahoma
            aAbout 3,000 on 63
             reservations with HA schools




L

                     For the 63 reservations with BIA schools, the coordinators provided their
                     estimates in three parts. The first part consists of those Indian preschool
                     children who have been diagnosed as having handicapping conditions.
                     The second part consists of those Indian preschool children who have
                     been referred for diagnostic evaluation, primarily because they failed a
                     screening test. The third, and largest, part is the coordinators’ estimates
                     of the number of Indian preschoolers who may be handicapped but who
                     have yet to be individually identified or located. The individual count
                     for each part of the coordinators’ estimates is shown in figure 4.




                     Page 19                              GAO/HRD9O-6lBR   Special Education   for Indian Children
Special  Education: Estimates of Handicapped
Indian Preschoolers and Sufficiency
of Services




BIA  regulations define a handicapped child as one who has a diagnosed
handicapping condition and, because of this condition, needs special
education services. Only those children in the first part of the coordina-
tors’ estimates meet this definition. The children in the second and third
parts-those who have been referred for a diagnostic evaluation and
those who may be handicapped but who have yet to be individually
identified-were    presumed by the coordinators to be handicapped on
the basis of their personal knowledge or information they obtained to
make their estimates or both.




Page 20                               GAO/HRD-!MMlBR   Special Education   for Indian Children
                             Special Education: Estimates of Handicapped
                             Indian Preschoolers and Sufficiency
                             of Services




Fiaure 4


       GAO BlA’s Potential Service
           Population--63 Reservations
              Source of Estimate                                                          Number

              Diagnosed as Handicapped                                                                 985
              (791 with IEPs, 194 without)
              Referred for Evaluation                                                                  726

              Coordinator Estimate of Others                                                     1,237
              Total                                                                              2,948

Handicapped Indian           About 28 percent, or 838, of the estimated 2,948 handicapped Indian
                             preschoolers on reservations with BIA schools, received special education
Preschoolers Received        services in school year 1988-89. Of the 838 served,” 437, or 52 percent,
Special Education Services   were funded, at least partially, by BIA. In many cases, these 838
in School Year 1988-89       preschoolers received special education services from more than one ser-
                             vice provider. The number of handicapped Indian preschoolers with IEPS
                             being served by each service provider is shown in figure 5.




                             “Of the 8.38bring ser\red, 789 had IEPs and 49 did not.



                             Page 21                                 GAO/HRDSOSlBR     Special Education   for Indian   ChiJdren
                                         Special Education: Estimates of Handicapped
                                         Indian Preschoolers and Sufficiency
                                         of Services




Figure 5: Agencies Serving Handicapped
Indian Preschoolers
                                         600 -aswad
                                         756
                                         706
                                         656
                                         606
                                         566
                                         500
                                         456
                                         406
                                         350
                                                               \
                                         300
                                         256
                                         200
                                         150
                                         166




                                         1 Total exceeds number of preschoolers    with IEPs because many children recetve services from more
                                         than one agency

                                         2. BIA IS provldtng funding for a total of 437 handicapped Indian preschoolers; 341 are recelvlng services
                                         directly from BIA and 96 are recelvlng services provided by other agencies but funded by BIA




Handicapped Indian                       Of the estimated 2,948 handicapped Indian preschoolers on the 63 reser-
                                         vations with BIA schools, about 2,110 (72 percent) may need, but were
Preschoolers Who May                     not receiving, special education services in school year 1988-89. Each of
Need Special Education                   these preschoolers was in the various stages of being identified as handi-
Services                                 capped. Some had been referred for diagnostic evaluations because they
                                         had failed screening tests. Others had been diagnosed as handicapped
                                         but were without completed IEPS and receiving no services. The major-
                                         ity, however, were those who may be handicapped but who have yet to
                                         be individually identified or located (fig. 6). This latter category of
                                         potentially handicapped should have been, but were not, identified. at
                                         the time of our review, through BIA’S child-find activities.




                                         Page 22                                   GAOjHRD-90-61BR       Special Education    for Indiau Children
                         Special Education: Estimates of Handicapped
                         Indian Preschoolers aud Sufficiency
                         of Services




Figure 6


       GAO Preschoolers Who May
           Need Services
               2,100 May Need Services
           02 with IEPs not being served
           l   157 of 194 diagnosed but
               without completed IEPs
           l   714 of 726 failed initial
               screening & referred
           l   1,237 yet to be individually
               identified or evaluated

                         EHA  requires that each handicapped child receive an education individu-
Services Provided to     ally tailored to meet his or her unique needs. However, of the handi-
Handicapped Indian       capped Indian preschoolers on the reservations with BIA schools
Preschoolers Are         receiving special education services in school year 1988-89, a significant
                         percentage received insufficient services. Service information provided
Insufficient             by the coordinators shows that at least 24 percent of the 791 handi-
                         capped Indian preschoolers with IEPS were receiving fewer ser Aces than
                         their IEPS prescribe. Furthermore, because IEPS may lack all the services
                         handicapped children need, the actual percentage of preschoolers who
                          Special Education: Estimates of Handicapped
                          Indian Preschoolers and Sufficiency
                          of Services




                          received fewer services than prescribed may be higher than the 2-l per-
                          cent we calculated.


Preschoolers With IEPs    To determine the sufficiency of services, we analyzed data the coordina-
                          tors provided; these data concerned the services needed by, and the ser-
Did Not Receive All the   vices being provided to, all 791 handicapped Indian preschoolers with
Services They Needed      IEPS on the 63 reservations with BIA schools. Based on this analysis, 24
                          percent of the 791 handicapped Indian preschoolers with IEPS were
                          receiving fewer services than their IEPS prescribe (fig. 7).




                          Page 24                               GAO/HRD90-6lBR   Special Education   for Indian Children
                     Special Education: Estimates of Handicapped
                     Indian Preschoolers and Sufficiency
                     of Services




Figure 7
r




       GAL) Preschoolers Do Not Receive
            All IEP-Prescribed Services
            24% of the 791 with IEPs
            receive less than full service




                     Our analysis of the sufficiency of services provided may overstate the
                     percentage of preschoolers who received all the services they needed. In
                     addition, our survey of the BIA coordinators concerning how IEPS are
                     developed, as well as information presented at 1989 congressional hear-
                     ings on EHA reauthorization, indicates that (1) IEPS generally lack some
                     of the services recommended for handicapped children and (2) this is
                     because of the shortage of special education personnel throughout the
                     nation.

                     We were able to discuss how IEPs are developed with 29 of the 32 BIA
                     special education coordinators. Twenty of the 29 coordinators stated



                     Page 25                               GAO/HRD90-6lBR   Special Education   for Indian Children
Special Education: Estimates of Handicapped
Indian Preschoolers and Sufficiency
of Services




that, generally, IEPS lack some of the services recommended for handi-
capped Indian children (see fig. 8).




Page 26                              GAO/HRD9041BR   Special Education   for Indian Children
                        Special Education: Estimates of Handicapped
                        In&an Preschoolers  and Sufficiency
                        of Services




Figure 8


           GAQ Do IEPs Contain All Services
               Needed?
                69% of BIA Special Education
                Coordinators Say No




                        The results of our BIA coordinator survey are consistent with testimony
                        presented to the Senate Subcommittee on the Disability Policy (formerly
                        the Senate Subcommittee on the Handicapped), on April 3, 1989,” con-
                        cerning the effect of the shortage of special education personnel in pub-
                        lic school systems:

                        “...because of the lack of qualified education professionals, school districts are
                        increasingly having to employ strategies that seriously undermine the capacity of

                        “Statementof Dr. William Carriker representing the American Speech-Language-Hearing Association,
                        Council of Administrators of Special Education, Council for Exceptional Children, Council of Gradu-
                        ate Programs in CommunicationSciencesand Disorders,Higher EducationConsortiumfor Special
                        Education, and the National Association of State Directors of Special Education.



                        Page 27                                 GAO/HRLb9O43lBR      Special Education   for Indian Children
                             Special Education: Estimates of Handicapped
                             Indian Preschoolers and Sufficiency
                             of Services




                             the nation to guarantee the provision of a free appropriate public education to chil-
                             dren with handicaps. These strategies include...constraining placement and pro-
                             grammatic decisions to meet available personnel resources rather than child needs.”



Uncertainty About Qu,ality   While an evaluation of the quality of special education services being
                             provided was beyond the scope of our review, we found indications that
of Service Provided          special education services for handicapped Indian preschoolers a.re often
                             provided by individuals with little specialized training. According to
                             BIA’S early childhood program specialist, one reason this occurs is that
                             Head Start programs allow noncertified teachers to educate handi-
                             capped children. In addition, this official also told us BIA lacks the staff
                             to remedy the situation.

                             For example, the majority of the handicapped Indian preschoolers on
                             the Cheyenne River Reservation who received special education services
                             were enrolled in the reservation’s Head Start program. These children
                             received services from Head Start teachers, not BIA personnel. Only 8 of
                             the 28 Head Start teachers had teaching credentials, and none of these 8
                             had training in special education. The other 20 teachers had only a high
                             school or high school equivalency diploma. The teaching staff, who are
                             paid $4 to $6 per hour, has an annual turnover of 35 percent. According
                             to the program’s coordinator, these teachers lack the necessary skills to
                             provide special education services, but there are no alternatives.

                             The director of Head Start’s Indian Programs Branch, Washington, D.C.,
                             told us that the teachers employed in the other Indian Head Start pro-
                             grams have similar qualifications to those employed in the Cheyenne
                             River program. The qualifications of Head Start’s teachers may be sig-
                             nificant because (as shown on p. 22) Head Start was providing special
                             education services to about 74 percent of the 791 handicapped Indian
                             preschool children with IEPS on the reservations with BIA schools in
                             school year 1988-89.

                             BIA’S early childhood program specialist told us that handicapped Indian
                             preschool children enrolled in Indian Head Start programs are entitled to
                             receive special education services under EHA, including instruction by
                             certified professionals. However, this official further stated, BIA (1) is
                             currently unable to provide qualified professionals to assist Indian Head
                             Start programs that serve enrolled handicapped children and (2) has
                             few alternatives because of the overall shortage of special education
                             personnel.



                             Page 28                               GAO/HRD9O-61BR   Special Education   for Indian Children
                         Special Education: Estimates of Handicapped
                         Indian Preschoolers and Sufficiency
                         of Services




                         According to officials from BW’S Branch of Exceptional Education and
Major Reasons for        its special education coordinators, the major reasons many handicapped
Insufficient Services-   Indian preschoolers receive insufficient services are (1) the lack of qual-
                         ified service providers on or adjacent to Indian reservations and (2)the
Personnel Shortages      availability of funds to hire them if they were available.
and Inadequate
Funding

Personnel Shortages      Branch officials told us that BIA encounters difficulties attracting special
                         education personnel to work on reservations. These difficulties are com-
                         pounded by the nationwide shortage of special education personnel. As
                         a result of these shortages, there are insufficient numbers of qualified
                         teachers and other special education personnel to provide handicapped
                         Indian preschoolers with all the services recommended for them by
                         multi-disciplinary evaluation teams.

                         BIA’S difficulty in attracting teachers is a long-standing problem. HA
                         stated, in its March 1988 “Report on BIA Education: Excellence in Indian
                         Education Through the Effective Schools PLocess,” that it faces special
                         problems in attracting and retaining teachers. In the report, BIA attrib-
                         utes this problem to such factors as the geographic isolation of many
                         Indian reservations, poorly maintained housing, and low pay.

                         The difficulty BIA is having attracting special education personnel is
                         illustrated by the number of vacant positions in its special education
                         program. In a July 21, 1989, letter to our office, BIA’S Office of Indian
                         Education Programs told us that BIA has at least 61 vacancies in its spe-
                         cial education program. The letter said that each of BIA’S 32 special edu-
                         cation coordinators was asked to compile a list of vacant special
                         education positions and that, as of July 21, 1989, 16 coordinators had
                         responded. They identified 61 vacancies: 35 special education teachers.
                          14.5 speech or language pathologists, 3 psychologists, 2 coordinators,
                          1.5 counselors, 1 diagnostician, 1 occupational therapist, 1 education
                         specialist, 1 child-find technician, and 1 classroom aide.

                         According to the coordinators, the shortage of special education person-
                         nel is the prime reason IEPS generally lack all recommended services.
                         Each of the 20 coordinators who told us that IEPS generally lack some
                         recommended services cited the lack of available service providers as
                         one of the reasons (see fig. 9).




                         Page 29                              GAO/HRD-SO-GIBR   Special Education   for Indian Children
                     Special Education: Estimates of Handicapped
                     Indian Preschoolers and Sufficiency
                     of Services




Figure 9


       GAQ Why Do IEPs Lack Needed
           Services?
             Unavailability of services
             most frequently cited response




Local Examples       At the Cheyenne River and Gila River Reservations, we identified esam-
                     ples of the difficulties BIA has in obtaining special education personnel.
                     At these reservations, hiring special education personnel was either
                     time-consuming or did not result in the hiring of needed personnel (see
                     fig. 10).




                     Page 30                              GAO/HRD9041BR   Special Education   for Indian Children
                      Special Education: Estimates of Handicapped
                      Indian Preschoolers and Sufficiency
                      of Services




Figure 10


        w   Local Examples
            of Hiring Difficulties


            Cheyenne River, S. Dak.
            027 contacts, no hires

            Gila River, Ariz.
            *vacancies open 3 - 5 months



                      At the Cheyenne River Reservation, special education vacancies went
                      unfilled in school year 1988-89. To fill two vacancies-one speech thera-
                      pist and one special education teacher -BIA’S   coordinator at the Chey-
                      enne River Reservation contacted a total of 27 colleges, universities, and
                      individuals, but could not identify a single applicant whom she consid-
                      ered qualified.

                      At the Gila River Reservation, filling two special education positions
                      took 3 to 5 months in school year 1988-89. One vacancy, for a speech




                      Page 31                              GAO/HRD-9041BR   Special Education   for Indian Children
                     Special Education: Estimates of Handicapped
                     Indian Preschoolers and Sufficiency
                     of Services




                     pathologist, took 5 months to fill. The other vacancy, for a special edu-
                     cation teacher, took 3 months to fill. According to the reservation’s coor-
                     dinator, filling special education vacancies is a slow process because the
                     reservation must compete with a major metropolitan area, Phoenix, for
                     the scarce personnel with specialties in early childhood education.

                     BIA'S difficulties in hiring special education personnel mirror the finding
                     of a University of Maryland study of the national shortages in special
                     education personnel. The 1986 study, “Personnel to Educate the Handi-
                     capped in America: ,Z Status Report,” concluded that “Personnel
                     shortages continue to plague almost every state....” The predominant
                     shortage area reported in the study is speech and language. As discussed
                     in appendix IV, the most common handicapping condition among handi-
                     capped Indian preschoolers is speech impairment.


Inadequate Funding   Branch officials told us that BIA lacks sufficient funds to fully serve t,he
                     handicapped Indian preschoolers enrolled in their special education pro-
                     grams. In their view, additional funds would be necessary to serve addi-
                     tional children, such as the 2,110 preschool children who, we estimate:
                     may need, but have not received, special education services. Branch offi-
                     cials are uncertain of the cost of fully serving all handicapped Indian
                     preschool children (1) currently enrolled in their programs or (2) who
                     may need, but have not received, special education services.

                     In discussing funding difficulties, branch officials told us that the spe-
                     cial education program experienced a severe funding shortfall in school
                     years 1987-88 and 1988-89. Branch officials attributed this to an
                     increased service population and the lack of a specific funding source
                     for preschoolers; because of this, the branch provided only $2.7 of the
                     $4.3 million field offices requested to provide special education services
                     to handicapped Indian preschoolers in school year 1988-89. Branch offi-
                     cials told us that, generally, the field offices responded to this reduced
                     funding by postponing or cancelling their hiring plans and by laying off
                     some employees.

                     Branch officials told us that they are uncertain of the cost of providing
                     special education services to all handicapped Indian preschool children
                     on the 63 reservations with BIA schools. They also told us they have
                     never developed an overall cost estimate because (1) BIA'S funding is
                     determined by, and limited to, the 1.25 percent EHA appropriation set-
                     aside and (2) other agencies also serve handicapped Indian preschoolers
                     in addition, a reliable estimate is difficult to develop because of the


                     Page 32                               GAO/HRD!W61BR   Special Education   for Indian Children
                        Special Education: Estimates of Handicapped
                        Indian Preschoolers and Sufficiency
                        of Services




                        many factors to be considered, such as severity and type of handicap
                        and accessibility of services.


                        BIA, the Department of Education, and the states have differing                  interpre-
Agency Responsibility   tations about who must provide services to handicapped Indian                     children
for Special Education   on reservations with BIA schools. These differences could made                   efforts
Subject to              to serve these children difficult and contribute to BIA’S inability              to serve
                        some children for whom it is responsible.
Interpretation
                        In discussing BIA’S responsibility under EHA, BIA officials told us that BIA
                        is only responsible for providing special education services to those
                        handicapped Indian preschoolers enrolled in its programs. These offi-
                        cials also told us that other agencies, such as local public school districts
                        and Indian Head Start programs, are primarily responsible for providing
                        services to the handicapped Indian preschoolers enrolled in non-BtA
                        programs.

                        In commenting on our draft report, Interior reiterated the opinions of
                        BIA officials. Interior stated that (1) in receiving EHA funds, it agreed to
                        assure services to those children enrolled in its programs; (2) if no other
                        agencies will provide services to handicapped Indian children enrolled in
                        non-BIA programs, BIA may do so; and (3) the education delivery system
                        on Indian reservations is too complex to specify, conclusively and with-
                        out exception, which agency is responsible for providing special educa-
                        tion services to handicapped Indian preschoolers on reservations with
                        BIA schools. Interior also provided several examples of the differing edu-
                        cational delivery systems on various reservations.

                        The Department of Education disagrees with Interior’s opinion of BIA’S
                        responsibilities under EHA. In a June 19, 1989, policy memorandum, the
                        Department stated that under EHA’S section 611 (f), BIA is responsible for
                        providing free and appropriate special education services to those hand-
                        icapped Indian children who live on the 63 reservations with BIA
                        schools. Department officials told us that this means BIA is solely respon-
                        sible for all the handicapped Indian children on reservations with BIA
                        schools, even if, for example, local public schools are also located on the
                        reservation.

                        Officials from the 20 states with reservations with BIA schools have
                        mixed views concerning BIA’S and the states’ responsibilities for provid-
                        ing special education services to handicapped Indian preschoolers on
                        such reservations. Officials from eight states said their states were


                         Page 33                              GAO/HRD-!W61BR   Special Education   for Indian Children
                       Special Education: Estimates of Handicapped
                       Indian Preschoolers and Sufficiency
                       of Services




                       responsible for serving all handicapped Indian children within their
                       states, including those on reservations with BIA schools. Officials from
                       another eight states said their states had no responsibility for the handi-
                       capped Indian preschoolers on reservations with BIA schools. These offi-
                       cials said BIA was solely responsible for providing the services needed.
                       Officials from the other four states either were uncertain who was
                       responsible or said the responsibility was shared.

                       In our opinion, the Departments of Education and Interior, as well as
                       certain states, misunderstand what EHA requires of Interior. We believe
                       that as a condition of accepting EHA funds, Interior assumes primary
                       responsibility for assuring services to all handicapped Indian children
                       living on reservations with BIA schools. In our view, this assurance
                       means that when other agencies do not provide the special education
                       services a handicapped Indian child needs, Interior must provide them.
                       In such instances, Interior does not have an option. However, in those
                       instances in which other agencies agree to provide handicapped Indian
                       children special education services, Interior may be able to discharge its
                       assurance responsibility by, for example, monitoring the services being
                       provided.

                       The differing views of Interior’s EHA responsibility has the potential for
                       allowing handicapped Indian children to be unserved. When there are
                       significant differences of opinion about who is primarily responsible for
                       serving handicapped Indian children -especially when neither BIA nor
                       the state accepts primary responsibility-cooperation     in meeting the
                       needs of the children may be difficult to obtain. Further, when agree-
                       ments are not reached with other agencies to provide services, Interior’s
                       position-that    it is not primarily responsible-creates  the potential for
                       children to be unserved.


                       We were unable to obtain an estimate of the number of handicapped
Handicapped Indian     Indian preschoolers who may attend BIA schools when they reach school
Preschoolers Who May   age because attendance data for the 63 reservations with BIA schools
Attend BIA Schools     were unavailable. We requested attendance data showing the number of
                       kindergarten and first-grade Indian students attending BIA schools or
                       public and private schools on each of the 63 reservations with BIA
                       schools.7 However, complete data for only 20 reservations were pro-
                       vided. On these 20 reservations, approximately 50 percent of the Indian


                       ‘Of these 63 reservations, 7 reservations have secondary schools only.



                       Page 34                                 GAO/HRD-90-61BR      Special Education   for Indian Children
                                           Special Education: Estimates of Handicapped
                                           hilan    Preschoolers and Sufficiency
                                           of Services




                                           children attending kindergarten and first grade were in BIA schools.
                                           However, the percentage varies greatly by reservation (see table 3).

Table 3: Indian Kindergartners and First
Graders Attending BIA Schools              Figures     In percent
                                                                                         School year
                                           Reservation                        1988-89        1987-88          1988-87            Averaae
                                           Acoma,      NM                          76             81                 77                  78
                                           Brg Cypress,          FL                76             a5          __-    88                  a3
                                           Cherokee,        NC                     a5             a4                 79                  a2
                                           Cheyenne         River, SD              ai             a0                 75                  78
                                           Chrtrmacha,       LA                    73             68                 63                  68
                                           Crow Creek,        SD                   85             90    -91                              a9
                                           Devrls Lake, ND                         69             62                 76                  69
                                           Fort Berthold,        ND                78             73                 73                  75
                                           Grla Rover, AZ                          37             41                 41                  40
                                           HOPI, AZ                                59             62                 70                  64
                                           Isleta, NM                              a7             87                 87                  87
                                           Jemez.      NM                          66             66                 64                  65
                                           Laguna, NM
                                           ~_____   ___
                                                                                   54             55                 59                  56
                                           Lake Traverse,         SD               20             35                  34 --------29
                                                                                                                    -_____~~~~~
                                           Northern     Cheyenne,       MT          13             11                 19                 14
                                           Rosebud,      SD                         16             18                 18                 17
                                           Standing      Rock, ND                  38             41                 43                  40
                                           Papaao,      AZ                         40             38                 42                  40
                                           Puyallup,     WA                        30             22                 47                  31
                                           Yankton,     SD                         32             31                 31                  31
                                           Total                                   49             50                 53                  51



                                           At the time of our review, BL4 had not, as its regulations (25 C.F.R.
Conclusions                                45.11) require, individually identified and located all Indian
                                           preschoolers who are thought to be handicapped. We believe that if BIA
                                           fully complied with its child-find regulations, it would be better able to
                                           work with other service providers- such as Indian Head Start programs
                                           and local public school districts-to   meet the special educational needs
                                           of handicapped preschoolers. As a result, these children would have a
                                           better chance of receiving the services that EHA legislation requires they
                                           be provided.




                                           Page 35                           GAO/HRD-90-61BR   Special Education    for Indian    Children
                       Special Education: Estimates of Handicapped
                       Indian Preschoolers and Sufficiency
                       of Services




                       We recommend that the Secretary of the Interior direct the Assistant
Recommendation to      Secretary for Indian Affairs to fully implement the requirements of 25
the Secretary of the   C.F.R. 45.11. Concerning this, the Assistant Secretary should take
Interior               actions to assure that each BIA field office annually identifies and
                       locates every preschooler on the 63 reservations with BL4 schools
                       thought to be handicapped and in need of special education services.




                       Page 36                               GAO/HID-9041BR   Special Education   for Indian Children
Page 37   GAO/HRD-SO-GlBR   Special Education   for Indian Children
Appendix I

Technical Description of the Methodologies
Used to Estimate the Number of Handicapped
Indian Preschoolers
              In this appendix, we discuss the two methodologies we used to estimate
              the number of handicapped Indian preschoolers. We also present a table
              comparing the results of each methodology, when direct comparisons
              could be made, for the 24 reservations,

              For the 63 reservations with BIA schools, we developed and used a data
              collection instrument (see app. V), completed by BIA’S 32 special educa-
              tion coordinators, to determine the number of handicapped Indian
              preschoolers.

              Using this data collection instrument, the coordinators gathered infor-
              mation on two populations of handicapped Indian preschoolers. The
              first population is those children who were diagnosed as having a handi-
              capping condition or who were referred for a diagnostic evaluation, The
              second population is the coordinators’ estimates of the additional
              number of handicapped Indian preschool children who have yet to be
              identified or diagnosed. Each of the 32 coordinators provided this infor-
              mation for the reservations he or she serves.

              The coordinators gathered information on the first population from spe-
              cial education service providers on the reservation, including ~1.4 pro-
              grams, Head Start programs, IHS facilities, local health or social service
              agencies, public schools, private profit or nonprofit agencies, and tribal
              organizations.

              The coordinators used a variety of methods to estimate the number of
              Indian preschoolers who may be handicapped, but have yet to be identi-
              fied or diagnosed. Some of these methods included door-to-door canvass-
              ing; discussions with health care providers such as IHS, tribal health
              organizations, and public clinics; and applying handicapping prevalence
              rates to the number of those aged 3 and 4 on tribal rosters or in IHS birth
              records.

              To estimate the number of handicapped Indian preschoolers for each
              state that has reservations and for all areas of Alaska and Oklahoma,
              we used (1) data from IHS’S patient registration system and (2) a study
              of the rates of handicapping conditions among Native Americans. From
              IHS’S patient registration system, we obtained an estimate of the number
              of preschoolers aged 3 and 4. From “A Study of the Special Problems
              and Needs of American Indians with Handicaps Both On and Off the




              Page 38                       GAO/HRD9O-fXBR   Special Education   for Indian   Children
Appendix I
Technical Description of the Methodologies
Used to Estimate the Number of Handicapped
Indian Preschoolers




Reservation,“’ we obtained estimates of the rates of handicapping condi-
tions. We then multiplied the estimated number of preschoolers aged 3
and 4 by the prevalence rates.

IHS’S patient registration system contains records of each patient treated
or born at any IHS or tribally operated health care facility. According to
IHS officials, 99 percent of Indian children are born at IHS or tribal facili-
ties. In addition, IHS officials believe they identify the Indian children
born at non-Ins facilities as these children subsequently come in for
treatment. For these reasons, we believe using a patient census serves as
an adequate substitute for an actual census of Indian preschoolers.

IHSmaint,ains the patient registration data by its service units, not each
reservation. A service unit is IHS’S basic health organization for a geo-
graphic area, with most service units providing health services to more
than one reservation. For this reason, reservation-specific data were
unavailable for most reservations.

Because Indian children attend BIA schools as well as private and public
schools, the NARTC study presents two sets of prevalence rates for
handicapping conditions: one set based on data from BIA schools and one
set based on data from public schools. BIA’S data are based on enrollment
figures for children aged 5 to 21 attending its schools for school year
 1986-87. The public school data are based on a survey conducted by the
Department of Education’s Office for Civil Rights (OCR) during school
year 1984-85. Title VI of the Civil Rights Act of 1964, along with title IX
of the Education Amendments of 1972 and Section 504 of the Rehabili-
tation Act of 1973, requires the Department of Education to conduct an
annual survey of handicapped children. The OCR survey was of handi-
capped children aged 3 to 21 or 5 to 21, depending on the state mandate
for services to children with handicapping conditions.

According to the NARTC study, both sets of prevalence rates have limi-
tations. BIA’S data inflated the prevalence rates by including some
speech-impaired children, as well as the handicapped children in resi-
dential facilities, in more than one handicapping category; this over-
stated the actual number of handicapped children and the prevalence
rates, Based on data in the NARTC study, we estimate an overstatement
of 21 percent. Despite this overstatement, the researchers used BIA’S
data in computing prevalence rates; they did this because they believed

‘Native American Research and Training Center (NARTC), University   of Arizona and Northern   Ari-
zona University (Sept. 1987).




Page 39                               GAO/HR.D-!3081BR    Special Education   for Indian   Children
Appendix I
Technical Description of the Methodologies
Used to Estimate the Number of Handicapped
Indian Preschoolers




that the need for services might be better reflected in duplicated counts
since individuals with multiple handicapping conditions need different
types of rehabilitative services. The OCR data understate prevalence
rates because they exclude certain handicapping conditions specified in
EHA. Concerning this, OCR’S 1984 survey did not include all the categories
of handicapping conditions specified in EHAat the time of the survey;
the deaf, hard of hearing, orthopedically impaired, other health
impaired, and visually handicapped categories were excluded. We esti-
mate this caused the prevalence rate to be understated about 8 percent.




24 reservations for which direct comparisons could be made, the esti-
mates were comparable. BIA’S coordinators estimated that there are a
total of 1,170 handicapped Indian preschoolers on these 24 reservations.
On the basis of the IHS data and the NARTC prevalence rates, we calcu-
lated that there are between 1,128 and 1,877 handicapped Indian
preschoolers on the same 24 reservations (see table I. 1).




 Page 40                             GAO/HRD9@61BR   Special Education   for Indian Children
                                          Appendix I
                                          Technical Description of the Methodologies
                                          Used to Estimate the Number of Handicapped
                                          Indian Preschoolers




Table 1.1:Comparison of Estimates at 24
Reservations                                                                                           Estimates based on
                                                                                                                      BIA
                                          Reservation                                         OCR rates           Rates   Coordinators
                                          Cheyenne       River, SD                                     64                   98                     58
                                          Chrtrmacha,        LA                                         3                    3                         3
                                          Colvllle.    WA                                              31                   92                     62
                                          bevels Lake (Fort Totten),              ND                   47      -57                                 30
                                          Eastern      Cherokee,        NC                             40                   52                     46
                                          Flathead,     MT                                             55                   84                     19
                                          Fort Berthold,       ND                                      44                   53                     94
                                          Fort Hall, ID                                                37                   80                     23
                                          Gala River, AZ                                               87               109                        99
                                          Krckapoo,      KS                                            20                   40                     17
                                          Leech Lake, MN                                               51               140                        12
                                          Miccosukee,         FL                                        2                    6                         6
                                          Mille Lacs, MN                                                9                   24                    119
                                          MISSISSI~~I Choctaw,               MS                        15                   78                     22
                                          Northern      Cheyenne,        MT                            46                   82                     15
                                          Passamaquoddy,            ME                                 13                   11                     18
                                          Penobscot,        ME                                          5                    4                     11
                                          Pine Ridge,       SD                                        150               230                        78
                                          Rocky       Boy, MT                                          26                   46                     56
                                          Rosebud,       SD                                            77               118                        24
                                          Standing      Rock, ND                                       99               119                       111
                                          Turtle Mountain,         ND                                  80                   96                     53
                                          Wind River, WY                                               70                   87      -             155
                                          Yakima, WA                                                   57               168                        39
                                          Total                                                     1,128             1,877                    1,170




                                          Page 41                                      GAO/HRD9OH)-GlBR Special Education        for Indian Children
Appendix II

Estimated HandicappedIndian Preschool
Population by State

                                                Total
State         ~~___                         children       OCR rate’              Estimate          BIA rateb              Estimate
Alaska        ..-~-                            18,987             1320                 2.506                     c             3.207
Alabama                                            32              5 82                     2                    c                     5
Anzona                                        20,711               9.62                1,992             1200                  2 485
Calrfornla                                      4,270              6 40                  269              3 55                    152
Colorado                                          265              5.42                   14                                        45
Connecttcut                                        18              2 52                     0                                          3
Florida
--~-                                              151              5.29                    8             17 00                      26
Idaho                                             559             12.58                   70            26 88                     150
Iowa                                                0             11 00                    0             1486                          0
Kansas                                            237              8 40                   20                     ‘                  40
Loutslana                                          29              5 05                     2                    c                     5
Maine                                             118             15.34                   18             1329                       15
Mtchfgan                                          608              5.39                   33                     c                102
Minnesota                                       1,076             15.23                  164            42 17                     454
Mississippi                                       327              4.71                   15            2371                        78
Montana                                         3,088             11 81                  365            21 18                     654
North Carolina                                    346             11 48                   40             1490                       52
North Dakota          -                         1,716             15 71                  270             1892                     325
Nebraska                                          698             14 17                   99                     c                118
New Mexico                                      3,917              8.86                  347             1658                     650
Nevada                                            819              8.90                   73                     c                139
New York                                          501              5.76                   29                     ‘                  85
Oklahoma                                      13,016               9.59                1,248             14.92                  1 942
Oregon                                            946             1194                   112            23.52                     222
Rhode Island                                       55             1032                      6                    c                     9
South Dakota                                    2,786             12.92                  360             1983                     552
Texas                                               0              6.52                     0                    c                     0
Utah                                              235             11.22                   26            28.89                       68
Washington                                      2.498              9 34                  232            27.34                     684
Wisconsin                                       1,193              9.13                  109            36.18                     431
Wyoming                                           540             13.04                   70             16.15                      87
Total                                         79,742                                  8,499                                   12,785
                          aHandicapprng condrtron prevalence rate based on Department of Educatron’s Offrce for CIVIIRights
                          (OCR) survey conducted during school year 1984-85.

                          bHandtcapprng condrtion prevalence rate based on enrollment data from BIA schools for school year
                          1986-87
                          ‘State-speciftc prevalance rates are unavarlable for those states with reservations without BIA schools
                          In these 12 states, we used the natronal average of 16.89 percent In obtarnrng our estimates.




                          Page 42                                   GAO/HRD90-61BR        Special Education      for Indian Children
Appendix III

Estimated HandicappedIndian Preschoolerson
ReservationsWith BLA Schools


                                                                                           Estimated
Reservation                     Diagnosed         Referred     IEP completed                   others                        Total
Arizona
   Fort Apache                                0          0                    9                        35
                                     -___                                                                            __.       --~44
   Glla River      __~      ~~~~ ~~~ .._____ 7          13                   38                        41                         99
   Havasupal                                 0           0                    0                         4      ~~~-.__-~~~
                                                                                                                                   4
   HOPI                                       0          1                    3                         0                          4
   Navajoa                                  112        240                  130                    238                         720
   Papago                                     0         34                     2                        4                         40
   Salt River                                 0          0                    9                         5                         14
        Subtotal                         119           268                  191                    327                         925

Florida
   Bg Cypress                                 0          0                   10                         4                         14
   Mlccosukee                                 2          0                    0                         4                          6
        Subtotal                              2          0                   10                         a                       20

Idaho
                                                                                                               -___.--
  Coeur d’Alene                               1          0                    8                         0                         9
                                                                                                                           ._____
  Fort Hall                                   0          0                   18                         5                        23
        Subtotal                              1          0                   26                         5                       32

Iowa
  Sac and Fox                                 0          1                    8                        12                       21

Kansas
  KIckaDo

Loumana
  Chttlmacha                                  0          0                    0                         3                          3

Maine
  Passamaquoddy                               0         14                    0                         4                         ia
  Penobscot                                   1          3                    0                         7                         11
        Subtotal                              1         17                    0                        11                         29

Mlchlaan
  HannahwIle                                  1         20                    0                        45                       66
                                                                                                                    (continued)




                         Page 43                             GAO/HRDM8lBR          Special Education        for Indian Children
                                        Appendix JlI
                                        Estimated Handicapped Indian Preschoolers
                                        on Reservations With BIA Schools




                                                                                                            Estimated
Reservation                                   Diagnosed            Referred     IEP completed                   others                       Total
Minnesota
-.       ~--
   Fond Du Lac                 .-~--                      4                8                   11                    50                          73
   Leech Lake             --                              0                4                    8                     0                          12
   Mtlle Lacs                                              7               5                   32                    75                        Ii9
   White Earth-                                            7             211                    3                    55                        276
      Subtotal                                           ia              228                   54                   180                        480

Mrsslssrppi
   MISSISSIPPIChoctaw
                -                                   ~.    0                 1                   5                       16                       22

Montana
  Flathead
___-                                   ___-               4                5                    6                        4                          19
   Northern     Cheyenne                                  3                 1                  11                        0                          15
   Rocky      Boy                                         1                0                   12                       43                          56
      Subtotal                                                                                                                                      90

Nevada
~~
   Duckwater                                              0                0                    0                        3                           3
   Pyramid      Lake                                      1                0                    3                        2                           6
      Subtotal                                                                                  3                                                    9

New Mexico
_____-
  Acoma                                                   2                3                    7                        2                          14
   Alamo Navajo                                           0                5                    0                        1                           6
   Canoncito                                                               2                                                                        10
                                                          1                8                    6                        2                          17
~..lsleta
   Jemez                                                  7                4                    1                        2                          14
              ~--.
   Laauna                                                 3                5                    6                       20                          34
   Ramah Navato                                                            0                                                                         5
                                                                                                                         1                           5
__-San Felrpe
        ~-
   San lldefonso                                                                                                        10                          10
~___
   San Juan                                                                                                             10                          11
   Santa Clara                                                                                                          10                          11
__.~_~~
  Taos                                                                                                                  10                          11
~.~~
   Tesuque                                                                                                               0                           0
   Zia                                                                                                                   I                           a
      Subtotal                                           14               33                   38                       71                     156

North Carolrna                                                                                                                                 ~~
~___
   Eastern     Cherokee                                   2                 1                  17                       26                          46
                                                                                                                                      (continued)




                                        Page 44                               GAO/HRDSO-61BR        Special Education        for Indian   Children
                                Appendix III
                                Estimated Handicapped   Indian Preschoolers
                                on Reservations With BIA Schools




                                                                                                         Estimated
Reservation                            Diagnosed              Referred       IEP completed                   others                      Total
North Dakota
  Devils     Lake                                  3                    0                   15                       12                     30
  Fort Berthold                                    0                    1                    7                       86                     94
  Standing      Rock                               0                    0                   61                       50                    111
  Turtle Mountaln                                  2                    6                   36                         9                    53
     Subtotal                                      5                    7.               119                     157                      288

South Dakota
  Cheyenne          River                          0                    2                   47                         9                    58
  Crow Creek                                       0                    1                   12                         2                    15
  Lake Traverse                                    0                  22                     3                         0                    25
  Lower      Brule                                 1                    0                    9                         1                    11
  Pine Ridge                                       1                  59                    18                         0                    78
  Rosebud                                          2                    0                   19                         3                    24
  Yankton                                          2                    0                   12                       11                     25
     Subtotal                                      6                  a4                 120                         26                   236

Washington
  Colville
  Lummi                                            91                   00                  11
                                                                                             9                       50
                                                                                                                     1o ~- .-~~~~~~~~a 62

  Mucklfshoot                                      0                    0                    2                         5                        7
  Nlsqually                                        0                    0                    1                         1                        2
  Puyallup                                         0                    0                   30                         5                    35
  Quileute                                         0                    0                    0                         6                        6
  Yaklma                                           0                    0                   17                       22                     39
     Subtotal                                    10                    0                    70                       99                   179

Wisconsin
  Lac Courte         Oretlles                      1                   10                    9                       50                     70
  Oneida                                           1                    2                   36                       65                    104
     Subtotal                                      2                  12                    45                   115                       174

Wyoming
  Wind River                                       3                  28                    47                       77                    155
Total                                           194                  726                 791                   1,237                    2,948

                                aAls~ Includes children llvlng on the Navajo Reservation In Colorado, New Mexico, and Utah




                                Page 45                                    GAO/HRDSO-GlBR        Special Education        for Indian Children
Appendix IV

DiagnosedHandicapping ConditionsAmong
Indian Preschoolers

              According to information the coordinators obtained from preschoolers’
              IEPS and from diagnostic evaluation reports when IEPS were incomplete,
              the most common primary handicapping conditions among Indian pre-
              school children are speech impairments and developmental delays (see
              fig. IV. 1). Speech impairments include all types of communication prob-
              lems such as the inability to express thoughts and ideas and to under-
              stand what is spoken, stuttering, and articulation and voice
              impairments, Developmental delays are deficiencies in one or more of
              the following areas: cognitive development, physical development, lan-
              guage and speech skills, psycho-social development, or self-help skills.




              Page 46                       GAO/HRDSO-GlBR   Special Education   for Indian Children
                                          Appendix N
                                          Diagnosed Handicapping   Conditions   Among
                                          Indian Preschoolers




Figure IV.l: Diagnosed Handicapping Conditions


         GM            Diagnosed Handicapping
                       Conditions

                       Primary Handicapping                                             Condition

                       Speech Impaired                                                                   501
                       Developmentally Delayed                                                           267
                       Multihandicapped                                                                   80
                       Other Health Impaired                                                              42
                       Specific Learning Disability                                                       26
                       Mentally Retarded                                                                  22
                       Miscellaneous                                                                      47
                       Total                                                                             985




                                           Page 47                              GAO/HRIMOSlBR   Special Education   for Indian   Children
Appendix L

GAO’sData Collection Instrument


                                                                                                                  -




                                                                                   UNITED       STATES  GENERAL                   ACCOUNTING      OFFICE
                                                                                    SURVEY       OF HANDICAPPED                     INDIAN   CHILDREN

       The       U.S.      General          Accounting                  Office           (GAO).         an agency            of      Congress.            is  required           by P.L.           loo-297
       (Hawkins-Stafford                      Elementary                  and      Secondary              School         Improvement               Amendments            of    1988)        to     conduct            a study      of
       handicapped               Indian         children.                    Specifically                 we were          asked        to     determine          the       number       of      handica           pod      Indian
       children            ages       3 through              4,       from      federally               recognized              tribes         who     are eligible              for     services             t I: at     are
       provided            by the        Bureau           of       Indian          Affairs           (BIA).           In     addition.             YO are       required           to collect               information            on
       the       scope       and     nature          of      existing              preschool              special          education             services         available            to this           grou
       children.                GAO is working                     in     cooperation                with       BIA’s        Office         of     Indian       Education            Pro       rams      tn      t R-of.x”dia”
                                                                                                                                                                                                                      IS amportant
       offort.             Please        read        the        information                  below        and     the      instructions                before        comnletina             s he attached                 forms.
       Your        help      in    this       effort            is      greatly            appreciated.


       OBJECTIVES:                   This         survey           is       divided           into        three       sections.

                                     SECTION        11 CHILD            IDENTIFICATION               FORM -                       The     objective                    of     this       section            is    to
                                     collect        information               on every        handicapped                             Indian         child                between          the     a      es of        3
                                     through        4 that         has     either      been        referred                        for       diagnostic                     evaluation,                %eon        identified
                                     as handicapped                for     purposes        of      preparin                          an      indrvidualired                          education              plan       (IEP),
                                     or    currently           has      a completed           or     partial                      9y         completed                IEP.         Specifically.                  we are
                                     interested             in   documenting           the       handicapping                                  condition                and      the     types         of     services
                                     the      child      is    receiving.

                                     SECTION       2:       ESTIMATE          OF TOTAL          HANDICAPPED                INDIAN        CHILDREN                                 - The    objective          of  this
                                     section       is    to     ESTIMATE        any      additional                handicapped              Indian                              children       residin
                                     in vow-       aeoaraDhic             area    of     reswnsibilitv                     that      wore       not                           identified          in    SEC 9 ION    1.
                                     You;-&:kafe-could                      be based          oh.       for      exa;plo,          the     current                                prevalency          rate    of
                                     all   handica          pod    Indian       children             in     your       area     in     certain                                elementary          grades      and
                                     your    first       R and     experience            with        the      tribes.

                                     SECTION      3: OVERALL                          VIEWS     -       The     objective               of       this      section               is     to     collect          the          views
                                     of  the    BIA      Special                      Education             Coordinators                     concerning                various             issues         relating
                                     to  the    delivery         of                   special           education           services                  to   preschool                  handicapped                 Indian
                                     chi Idren.


       Please          provide              the     name,          title,             and      telephone           number          of          the     primary              person          responsible                    for       completing           the
       attached            forms            in    the      event            that        further          information               is          required.

       Name       of    Primary              Contact            Person:

       Official            Title            and     Location:

       Telephone             Number:                Area        Code          (-1                                                                                or         FTS


       If     ou have     any      questions       concerning                                   any         section      of     this              document.         please       contact                       Edward             M. Zagalo         at
       <21x,    894-2509        or     FTS 798-2339.            You                             will          be provided            a         business        reply       envelope                      to     return              the    completed
       forms.        If this       envelope      is mis       laced.                                   return       the     forms              to     the   address        shown       at                the      end        of       this    document.
       Please     return      these        forms   by Fe R ruary                                     1.     1989.




                                                                                        Page 48                                                                         GAO/?%RIMO-6lBR                          Special Education                  for Indian Children
                                                                                                               Appendix V
                                                                                                               GAO’s Data Collection                   Instrument




                                                                                             SECTION                 1       -    INSTRUCTIONS            AND          DEFINITIONS

The       followi;&section                            asks                      for          a     count           of     the    number         and   type?        Of.3              through                 4 year           old      handicapped                        Inditn
children.                                   urposes       of                    this             survey,             we have         developed          defrnltrons                       rn           response          to         sono     of   your                  questrons.
Please          review                t   6 e-se prior                     to          completing                     any     of   the     attached         forms.


                               QUESTIONS                                                                                                                                                                    ANSWERS


  “Who      are          you          considering                          to          be        an     Indian                                          Any     child      who     is   oli      iblo     for       a “Certificate                                                   of      Indian
   chi     Ad?”                                                                                                                                         Blood”        from     a fedora          ly   reco       nired        tribe       who                                        is      living
                                                                                                                                                        “on     ol- n.aar”       a reservation4‘            t it at    has       BIA-operated                                                   or
                                                                                                                                                        -contracted            schools.

  “What            is    the          definition                      of          handicapped?”                                                         Any     of    the                 II       conditions                 listed           in     P.L.     94-142,                      the
                                                                                                                                                        Education                    of          the      Handicapped                     Act     and.      in   addition,                        we
                                                                                                                                                        are     including                          the      category                of      “Oovolopmentally                               Delayed”

  “For       SECTION                  1   ,    who      exactly                        do        we     count?”                                         Any    child     that   moots       the      above    definitions                AND
                                                                                                                                                        has    boon   referred        for     evaluation          and.        in     your       opinion,
                                                                                                                                                        is   likely      to be handicapped.                 OR has        been       evaluated
                                                                                                                                                        by a multidisciplinary                   evaluation           team       and      found       to
                                                                                                                                                        have     a handicapping           condition,          OR has         a completed                 IEP.

  “Do we            complet               e one         form               for           EACH           handicapped                                     Yes.   for       each                      child          you    can             idsntif         that  moots      the
    child           UQ can                identify?”                                                                                                    above    definitions,                                   complete                 one     “CH ‘f LD IDENTIFICATION
                                                                                                                                                        FORM”.

  “Would             we count                  a handicapped              Indian                                 child                                  YOS.           if      the      child                moots       the          above             definitions                       and.
    that           is  living                  off  the     reservation?”                                                                               in      your           opinion,                    is   living              “near”              the       reservation.

  “Will    we            count                a handicapped                                 Indian           child                                      Yes,        if         the             child        meets        all         the             above          conditions,
   regardlass                    of           who’s     providing                               the        sorvices?”                                   it      doesn’t                   matter            who   is          providing                      the      services.

  “When         you         talk       about              services.                       you     use                                                   Specially           designed          instruction               including.              but    not       limited
    the       torn           ‘Special                  Education                       Services’.                                                       to,     cognitive          and      social          development.                and     self     help         skills
    What         is       the     definition                     of               this?”                                                                provided          by or       under        the      direction           of      a person         certified
                                                                                                                                                         in   special         education            or      early      childhood             special        education.
                                                                                                                                                        This      includes         direct.            indirect          and      itinerant           service.

  “In      Section   1 you  ask                                for    a                child’s         “an?.                                            In      that           case              just     provide               the            other           information                   and
    If     the child   1s being                                  sawed                      by a publrc                                                 chock               “Name              Not    Available”.
    school              thy      nay            not         gtvo    us                 the     child’s                   name.”

  “What      about               requested                         information                          that         might        be                    Complete                 as            much        as    you     can             for         each          identified                child.
   missing?”

  “Who        is        considered                     to      be          a      3      or           4 year         old?”                              Any   identified                               handicapped                   Indian             child            born        between
                                                                                                                                                        December         1.                    1913       and     Novenbw                      JO,      1985.




                                                                                                               Page 49                                                                         GAO/HRDSO-GlBR                              Special Education                          for Indian Children
                                                                                                  Appendix V
                                                                                                  GAO’s Data Collection                    Instrument




                                                                              SECTION                   1          -       INSTRUCTIONS     AND          DEFINITIONS                            (can’t)


                         QUESTIONS                                                                                                                                                            ANSWERS


“What      if       wo    do        not       hrvo         a     date           of      birth                for       l                  If tho        date    of birth                             is     not     available                 AND      ou              bollovo
  chi Id?”                                                                                                                                the     child      is   3 through                               4,    indicate               the     chr .Y d’s
                                                                                                                                          approximate           age   and                           coaplets           the      other           items.

“Does        GAO     have           the       authority                   to         collect                                              Yes,           the         laws           that        govern         GAO      give           us access                      to       any
  information                from         l     child’s                 IEP?”                                                             rocorda                that          rolato               to    my     ongoing               study.

“How        vi11     YQ      report             this           information                       to          GAD?”                        First.               for
                                                                                                                                                                 oath      handica            od Indian         child       you       identify,
                                                                                                                                          CWWphte                     “CHILD
                                                                                                                                                                     WI0            IDE R !IFICATION            FORM”       0” which             you
                                                                                                                                          will           also  indicate          the      BIA    School       Code      for     the       attondanco
                                                                                                                                          boundary          in which           the     child       has   his      or hsr        primary
                                                                                                                                          rosi     dance.          When      you’ve         completed         all     tho     forms          for
                                                                                                                                          SECTION         1, you’ll            add     up all        the   handicapped               Indian
                                                                                                                                          children          living         in    EACH l ttondanco              boundary            for      which
                                                                                                                                             ou are       rosponsiblo.                 Totals        for oath attondmco
                                                                                                                                          1: oundary        will        be used        in     SECTION      2.

“What          if   a handicapped              Indian                         child             lives                                     In that                case,              assign       the  child         to             the        l    ttondrnco
  near        tho     rosorvation            and    not                       within             any                                      boundary                 which              is,     in your      opinion,                      closest                 to         his
  BIA       attendance            boundary?”                                                                                              or   her             primary                rosidonce.

“How        will      GAO      report      tho                 information                       it                                       Only           in      sunnary                   form      - no individual                         !nfornation                          will    be
  obtains           fron       the    IEPs?”                                                                                              in       our         report               and        no    individual                child          will           bo            idontifiod.

“Will       any      other            agency              have       access               to          this                                Yes,     so10                 of     tho     inform&Ion                      will        bo        given            to    BIA’s
  information?”                                                                                                                           Office      of                Indian         Education                 Programs.                     They           want      to start
                                                                                                                                          ,a=;~~mt                      dat?       base      similar               to   their                K-12           data      base.
                                                                                                                                                                     we 1.1811 not relome                              to BIA your                        responses         to
                                                                                                                                          Questi&                    11, Column 3 asking                               if l chrld                    is      actually
                                                                                                                                          receiving                     the         sorvicos              prascribed               in        the          IEP.

“If      I can’t       actually                   reviw                 the          children’s                                           Yes,    but     as                  you          at-o     roceivin          the     information                                  over     tho
  IEP,        can    I got    the               information                          by phone?”                                           phone,      record                        it       directly          on s Q the        form;      don’t                            summariro
                                                                                                                                          it    on a piece                          of       paper         and   then     record         it   later                            on the
                                                                                                                                          form.




                                                                                                  Page 50                                                                       GAO/I-IRD-SO-GlBR                         Special Education                                 for Indian Children
                                                                                                         Appendix V
                                                                                                         GAO’s Data Collection                                    Instrument




                                                                                                                                                    SECTION           1

                                                                                                                             CHILD            IDENTIFICATION                         FORM                                                                        ‘-f-‘-‘-/                     -‘-‘-‘-’
                                                                                                                                                                                                                                                             (Ploaso                  leave               blank)


  1.   Nemo                                                                                                                                                                                                                    Chock           if      Namo            Not          Available                        I-   .I
                                                                    Last                                                                                 First                                           in-

                                                              3.     O=to of            Birth               lRd-l                 la&l              ly~-l                 4.     Approximate                    ego        (ONLY          if         date         of         birth             unknown)                        l-l
  2.   sex           ‘ii’               ‘F’


  5.   Namo          of          Reservation                                                                                                                                                                                                                                   6.       St&o                  l-l-        .I

 7.    BIA       School                    Code             (Attendance                 boundary               in          which            child          has      primary             residence)                              1~1~1~1                -         1-l-l

 1.    Which              of         the          following                   BEST      describes                   this           child?                (CHECK           ONLY        ONE)

       1.      1-l             Reforrod                     for      diagnostic                 evaluation                     BUT          evaluation                NOT        conplotod/HAS                        NOT        occurrod                  yet         -->GO            TO        QUESTION                     10

       2.      1-1             Evaluation                         complotod             and       handicap                   identifiod                    BUT      tho        IEP      not           developed.

       3.      1-1             IEP         complotod.


 9.    What          is          this             child’s              PRIMARY               handicapping                      condition?                        (CHECK          ONLY         ONE)

       1.      l-1             Dovolopmont.lly                                Delayed               5.       1-l           tiltihandicapped                                                                           9.       1-1 Visually                       Handiceppod

       2.      l-1             Speech                Impoirod                                       6.       1-l           Seriously                 Emotionally                     Disturbod                     10.         l-1      Spociflc                  Loerning                     Disability

       3.      l-1             Hnntslly                     Rotordod                                7.       1-l           Hard        of        Hoaring                                                           11.          l-1     Orthopodically                                Impeirod

       4.      l-1             Other              Hoolth             Impoirod                       8.       l-1           Do*f                                                                                    12.          l-1     Do.f-Blind



10.    Currently,                          uhot     orgonizatjon                             or   ogoncy.    if any.   is providin          specie1                                                    educetion          sorvicos        AND/OR     roleted       sorvicos
       ;o,R;r;;wchild?                              If    the    chrld                       DOES NOT hove      an IEP     ?I+   IS NO 9 -receiving                                                        service.         ma-k     “NO    IEP-MDT       RECEIVING
                                           If   the     child      HAS                  .n      IEP    end IS NOT recorvlng        sorv~co,         ma-k                                                 “HAS       IEP-NOT       RECEIVING       SERVICE”.
       (CHECK                  ALL         THAT     APPLY)

       1.      1-l              NO         IEP-NOT                 RECEIVING                 SERVICES              --STOP                     YOU’RE             FINISHED                        6. l-1               Indian            Health               Smrvico                  (Ills)

       2.      1-1              HAS           IEP-NOT                RECEIVING                 SERVICES               -*GO                  TO      QUESTION              12                     7.       l-1         1.x.1           public               school
       3.      1-l              Ho.d              St.rt                                                                                                                                          8.       i-1         Local           socisl/heslth                            agency
       4.      1-1              BIA           (opor.tod                    OP     contracted)                                                                                                    9.       l-1         Privet0             profit/nonprofit                                     org*nir*tion

       5.      I-1              Tribo                                                                                                                                                         10.         l-1         Other           (specify)




                                                                                                         Page 51                                                                                    GAO/HRD-90-6lBR                                 Special Education                             for Indian                   Children
                                                                                                                                            Appendix V
                                                                                                                                            GAO’s Data Collection                                     Instrument




11.   Please                          indicate         below       if    this    child     is   receiving            any                                                                          services                      in     e “home           besod”      Setting        (e.g.                            physical           therepis
      trevols                           to     the   child’s          home    to   provide      the      sowIce),                                                                                 rocoiving                        services            in    o “center         besod”
      thorapist                             provides         services         at   a Head     Start        preschool)                                                                                 AND/OR                   receiving               sorvico       in     en
      _--------------_----____________________-------------------------
                           SETTING                                                                                                  “Is     the         child              rocoiving                    an
          I                                                                                                              II           sorvicos             in         this             setting?               I!
                                                                                                                                                                                                                                 II
          ‘--------------------------ii---~~~---~--~-----i---~~---~--~---l                                                                                                                                                            1
          I 1. Home                     boso          sotting
          I--------------------------------------------------------------l’
       I 2.          Cantor                bosod           setting                                                       II           Yes           (       1
       ‘-------------------------------;;;---;----~--~---~i
       I 3. Institution*1                                    rotting                                                     II
      -____-__--__-___-------------------------------------------------



12.   For              oath                   service                             liatod                        below,              please          indicate                   in:

      Column                         I:            Is           this          service      included          in                                     tho      child’s          IEP                     or,          for         those        childron            uhooo              IEP           is         not      complete,              is
                                                  this                  child       CURRENTLY       receiving                                              this      sorvico?

      Column                         2:           For     ooch                          sorvico                         that          is     included                 in        tho         child’s                     IEP    or    is   CURRENTLY                   being                  rocoivod                 by tho        child
                                                  without                             en IEP                        (“YES”            in     Column             I),          at-e        BIA          funds               usod    to    fund   any              er       rll            of       that             service?

      Column                         3:           For     oath    sorvico        chocked        “YES”       in Column                                                                       1.     mark          “FULL    SERVICE”         if                   the       child                 is    rocoiving                   the     IEP
                                                  proscribed          level      of   sorvico         (or     for     thoso                                                                   without              en IEP.     rocoiving,                             in your                   opinion,                  the       o   propriot
                                                   love1     of   sorvico);          mark     “PARTIAL          SERVICE”                                                                      if     tho         child    is rocoiving                               SOI-VICO                 but      it    is           less  t It an
                                                  “FULL      SERVICE”;         and    for     ONLY      those       children                                                                      WITH           AN IEP,      mark      “NOT                    RECEIVING                        SERVICE”                 if tho sorvico
                                                  is   proscribed           in   tho     IEP    but     tho     child                                                                  IS     NOT           rocoiving       the sorvico                          et  all.
                                                                                                                                    Colunn   1                      Colunn     2                         Column                                                                                         3
                                                                                                                              --_____-----__---_---------------------------------------------------------------
                                                                                                                              I I   “Is      this       service                   I I         “At-o           BIA            funds                        “If     this             sorvico                   is      in     the
                                                                                                      in                                     tho      IEP     -        OR         II              usod             to        provide            ii          child’s                IEP.           whet   level      of                             II
                                                                                           !I         being                                         rocoived?“ll                                  any         Ql- ill1            of                        sorvico                is          the child       currently                           II
                                                                                           II                                                                                     II              the         service?”                         II          rocoiving?”
      -----------------------------------------------------------------------------------------------------~-----~                                                                                                                                                                                                                                      f

      I                                           SERVICES
                                                                                                                                                                                                                                                                                                                                                        I

          1.
      I -----              Special                             Ed.               Services                                     II
      ‘-----‘---------------------~~--------~---------~~----------~---------~~---------~---------~---------------l
      I 2.           Speech              Thor.py
      l-----------‘---------~---------------i---------ii----------i---------ii---------i---------i---------------l
      i 3.                 ~ch:~~~~lon*l/Phys~cal                                                                             I\                                                                                                                                                                                                                   I
                                                                                                                                                    I                             II
      ,_______________________________________--------------------!---------!!---------!---------!---------------~
      1 4. Pa-on?     Counseling     and    II                                                                                                                                                                                                                                                                                                     I
                     Tralnrng                                                                                                                       I                            II                                      I                      II                             I                              I
      l‘------‘----------‘--------ii--------i---------ii----------i---------ii---------i---------i---------------/
      I   5. Audiology
      l---------------------------ii------;---------ii----------i---------ii---------i---------i---------------l
      I 6.           Transportation
      l----------------“-------------------i---------ii----------i---------ii---------i---------i---------------~
      ! 7.                 Psychologicel                                                 Services                             II
      I------------------------------------------------------------------------------------------~---------------

      I       8.           Other                      (specify)
      I                                                                                                                       II                    I                            II                                      I                      II                             I                             I




                                                                                                                                           Page 52                                                                                        GAO/HRD-9061BR                           Special Education                              for Indian                Children
                                                                                                             Appendix V
                                                                                                             GAO’s Data Cokction                               Instrument




r                                                                                            SECTION                           2         -      INSTRUCTIONS      AND     DEFINITIONS

    FM;         so&ion                     .sks     for     your      ostiF.to             of   hrndiceppod          1ndi.n        childron             NOT included              in  SECTION       1: CHILD       IDENTIFICATION
              .    As              in       SECTION       1, wo .ro             lntorostod            rn handrcoppod             Indien          children          ages       3 through       4.      Bolou    a-0    some                                                                               1
    .x.mplos                    of      different           methods          you      could       uso     to devolop        your        ostinato.              Tho    definitions           we used         in SECTION       1
    .lso       .pply                  her..         Pleas0       ro.d        the      questions           and  anwers         bolow          boforo        you     comploto          SECTION     2.


                                        QUESTIONS                                                                                                                                                            ANSWERS


      “Should          m               estin.to              include                  .ll        the           reservations                                     Yes,     but      we       would         like       you    to     dovolop        AND roport
        for     whit     rl            I an          responsible                      thst           have          BIA-operated                                    our   estin.te                 by School           Codo      attendance           boundary.
        or    -contr.ctod                            schools?”                                                                                                  i bet    is,       for          each     School         Codo       in your       gee     ra     hit    aroa,
                                                                                                                                                                estimate           tho          number        of    3 through           4    o.r     o?d      ! andicappod
                                                                                                                                                                 Indian       children               you      boliovo         reside       r n tho        attendance
                                                                                                                                                                boundary           for          that     school.
     “Whet               are    somo              accoptablo                    wsys           for          me            to         estimate                   No one         method        will       work     in ell          geographic          areas        end
       those               numbers?”                                                                                                                                        ‘udgnent         is      important.             If you knew,             for      example.
                                                                                                                                                                K;’        i he overall              handicapped            r.to      anon       Indian         chi ldron
                                                                                                                                                                 in kinder            arton        was     13X.    you      could       l pp 7 y that         percentage
                                                                                                                                                                to    tho       to ‘i al number            of   3 through           4 year       olds      in     en
                                                                                                                                                                attendance              boundary           then    subtrect           out    those       children
                                                                                                                                                                you      idontifiod              in    SECTION       1.

     “Do.=               th.t          l ssume    we             know           the          tot.1             number                                           This       oxanplo            doos            -      you    might           be      sblo       to        got        that
       of      3         through            4 yea-               olds?”                                                                                         inform.tion                 from           I.H.S.,            trib.1              records,               or       your       state’s
                                                                                                                                                                vital       statistics                     offic..

     “*.t                if      we      h.v.          .     good         est1n.t.                   .lr.ady                         -       from               If you a1ro.d                       he”.             counts           from    roforr.1,                     and
       r.f.rr.1                       lists?*                                                                                                                   r;;u,;. goner.1                 z nowlodge                 of       the    geographic                    .ro.         -    use


     “If       w.             h.ve       ov.1u.t.d        .nd                   identified                          .ll             childron                    No,  for    th.t                .ttond.nco                      boundery            thero           would           be
       in      .n             .ttond.nco           boundary.                        do we              still                       make                         no ostin.to                 -      your           tot.1          count           would       be       your          number
       l n     estim*to?”                                                                                                                                       from    SECTION                 1.

     “C.n           w.         combine               different                  methods                to           come                 up                     Yes,      you      could            us.,             for        oxunple,            information                     from
       with              on.      ostlm.t.?”                                                                                                                    I.H.S..          public             schools,                    soci.1           sorvicos,               etc.
     “Ha            should               w.       d.scribe                the         mothods                  w.              used?”                           Doscribe           .s     conplotol~                      .s     iou      c.n     (I 1 the     procedures
                                                                                                                                                                you      used      to     develop                    t  e .c        u.1 ostim.to           snd     (2)    .ny
                                                                                                                                                                spocrfic            inform&ion                        source          you     usod    such     es I.H.S.,
                                                                                                                                                                handic.ppod               counts                  from       public          schools,      etc.

     “Do       you             wult           thlr       .stim.to                 for         o.ch             of              tho                              No,     you      do       not      h.ve              to    brook           out      the      different
       h.ndic.pping                             conditions?”                                                                                                    h.ndic.pping                    conditions.




                                                                                                            Page 53                                                                       GAO/HRD-90-61BR                                  Special Education                       for Indian Children
                                                                                      Appendix V
                                                                                      GAO’s Data Collection                                Instrument




           INSTRUCTIONS:                     Column          1 :      List      all          BIA         School           Codes     (and           the          name        of         the       reservation)              whose         attendance
                                                                      boundaries                   are      in      the      geographic                     ares(s)              for         which        you    are     rssponsiblo.

                                             Column          2.        Indicate             the          total       number       of   handicapped           Indian                               children              ou identified                 In
                                                                       SECTION             1 for           each      BIA     School      Code     attendance                                   boundary.             ‘f f you     did    not
                                                                       identify             any          children         from       a particular           School                               Code      attendance          boundary,                   ENTER        “0”.

                                             Column          3:        For   EACH      BIA   School                       Code.          estimate                 the      number              of  an     additional               handicapped
                                                                       3 through         4 year     old                     Indian           children                   that    ou             DID   N z T include              in   Column           2.
                                                                       If  you    lncludod        them                      all        in Column                  2,      ENTE&   ‘0”.

                                             Column          4:        Briefly             describe         the            method(s)               you            used     to          develop           your      estimate             and
                                                                       identify              any    information                   sources                   you      used.

               Column           1                                     Column           2                                              Column            3                                                                  Column             4
            School         Code                           Identified                                                                 Estimated                                                     Description             of    Estimation                 Method(s)
               and                          Handicapped                       Children                           Additional                    Handicapped
        Reservation                                  From          SECTION                1                                          Chi   ldron
________________________________________----------------------------------------------------------------------------
                                                                                                                                                                                                                                                                                 I
      1.      1~1~1~1          -     l-I-1                                                                                                                                             I
                                                                                                                                                                                                                                                                                 I

________________________________________---------------------------------------------------------------------------l
                                                                                                                                                                                       :                                                                                         I

      2.      1~1~1~1 - l-l-1                                                                                                                                                          I                                                                                         I
                                                                                                                                                                                        I
________________________________________---------------------------------------------------------------------------,                                                                                                                                                             1

      3.      1~1~1~1 - l-l-1                                                                                                                                                          I                                                                                         I
                                                                                                                                                                                       I                                                                                         I
                                                                                                                                                                                       I
________________________________________---------------------------------------------------------------------------

      4.      1~1~1~1 - l-l-1                                                                                                                                                          I
                                                                                                                                                                                                                                                                                 /
                                                                                                                                                                                       I
                                                                                                                                                                                       I
________________________________________---------------------------------------------------------------------------

      5.      1~1~1~1 - l-l-1
                                                                                                                                                                                                                                                                                 I
                                                                                                                                                                                                                                                                                 I




                                                                                      Page 54                                                                               GAO/HRIMO-GlBR                             Special Education                   for Indian          Children
                                                                                                      Appendix V
                                                                                                      GAO’s  Data Collection                    Instrument




                                                                       SECTION              2:      ESTIMATE            OF   TOTAL        HANDICAPPED               INDIAN      CHILDREN             (can't)


                    Column             1                                            Column            2                                     Column         3                                                      Colunln      6

                                                                              Identified                                                  Estimated                                    Description                of   Estimation   Method(s)
          Scho~fidCode                                         Handicapped                        Children                   Additional               Handicapped
          Reservation                                                   From          SECTION                 1                           Children
___________________--------------------------------------------------------------------------------------------------

          6.      1~1~1~1              -     l-l-1


  ________________________________________---------------------------------------------------------------------------

          7.      1~1~1~1 - l-l-1

                                                                                      I
  ________________________________________---------------------------------------------------------------------------
          8.      1~1~1~1 - l-l-1                                                                                                                                                I

                                                                                                                                                                                 1

          9.      1~1~1~1 - 1~1~1

  ____________-_--________________________---------------------------------------------------------------------------
       10.        1~1~1~1 - l-l-1                                                                                                                                                I

                                                                                                                                                                                 i
  ________________________________________---------------------------------------------------------------------------
                                                                                                                                                                                 I
        11.        1~1~1~1 - l-l-1

                                                                                                                                                                                 I
  ________________________________________---------------------------------------------------------------------------
        12.        1~1~1~1 - l-l-1                                                                                                                                               I
                                                                                                                                                                                 I




                                                                                                      Page 55                                                                GAO/~!Ml-GlBR                     Special Education    for Indian   Children
                                                                                                    Appendix V
                                                                                                    GAO’s Data Collection                      Instrument




                                                                       SECTION              2:      ESTIMATE            OF   TOTAL        HANDICAPPED               INDIAN   CHILDREN             (can't   1


                    Column             1                                            Column 2                                                Column         3                                               Column 4
                                                                              Identified                                                  Estimated                                 Description            of   Estimation     Method(r)
          Scho:fidCodo                                         Handicapped                        Children                   Additional               Handicapped
          Reservation                                                   From          SECTION                 1                           Children
_________________-__-------------------------------------------------------------------------------------------------

        13.       1~1~1~1 - l-l-1                                                                                                                                            I

  ________________-_______________________--------------------------------------------------------------------------- /

       14.        1~1~1~1 - l-l-1                                                                                                                                            \
                                                                                                                                                                             I


  _____________------------------------------------------------------------------------------------------------------                                                        I




       16.        1~1~1~1 - l-l-1                                                                                                                                            I

                                                                                                                                                                             I
  ____________---__--------------------------------------------------------------------------------------------------

       17.        1~1~1~1 - l-l-1                                                                                                                                            I
                                                                                                                                                                             I
                                                                                                                                                                             I
  ___________----____------------------------------------------------------------------------------------------------
                                                                                                                                                                             I
       18.        1~1~1~1 - l-l-1                                                                                                                                            II

                                                                                                                                                                             I
 ____________________----------------------------------------------------------------------------------------------.
                                                                                                                                                                             I
       19.        1~1~1~1 - l-l-1
                                                                                                                                                                             I
                                                                                                                                                                             I
 ___________--_-___------------------------------------------------------------------------------------------------.

      20.         1~1~1~1 - l-l-1                                                                                                                                            I




                                                                                                  Page 56                                                               GAO/HRIHO-6lBR               Special Education       for Indian Children
                                                             Appendix V
                                                             GAO’s Data Collection                     Instrument




                                                                          SECTION        3:     OVERALL        VIEWS


Please      usa    the     space    below        to      write         any   additional            comments        you    h&w       concwnln          tlm   &livery          of     wecial
education        and     related      sorvicas             to      3 through          4 year       old    handicapped           Indian       chll   & M.      Tha     vlu,        yeu
express      hero      should      reflect            your       experiences            in    your    current          position and the             g.yr@vlc          .I-.. you
COYa-.




                                                             THANK      YOU    FOR YOUR           COOPERATION
                                                             Return      the    completed            forms    to:

                                                             E&a-d       M.    Zagalo
                                                             U.S.   General          Accounting             Office
                                                             350   South       Figusroa         Street
                                                             Suit*     1010
                                                             Los   Angeles,         CA         90071




                                                             Page 57                                                     GAO/HENO-61BR                  Special Educntion             for Indian Children
Appendix VI

CommentsFrom the Department of the Interior’




                                     United States Department of the Interior
                                                       OFFICE OF THE SECRETARY
                                                        WASHINGTON,  D.C. 202~)                                          I        n


                                                                 NOV I - 1989




              Mr. William   J. Gainer
              Director,   Education   and Employment                      Issues
              U.S. General Accounting     Office
              441 G Street   N.W.. Room 6854
              Washington,   D.C.    20548
              Dear Mr. Gainer:
              Thank you        for    the        opportunity        to      comment on the           draft     report         to the
              Congress       entitled        Special           Education:        Estimates      of Handicapped                Indian
              Preschool      Children       and       Sufficiency           of Services.        The      Department           of the
              Interior       agrees       with       many of        the     findings        of the      General      Accounting
              Office,     however,        there       are several           sections     of the       report      that       require
              further     clarification            and explanation.                The Department        of the      Interior's
              comments are included                in the enclosed              document.

                                                                   Sincerely,


                                                                    @LxAzA
                                                         &ding     Assistant        Secretary     - Indian        Affairs
              Enclosure




                           Page58                                         GAO/BRD80-61BRSpecial Education for Indian (‘hildrrn
                                                 Appendix VI
                                                 Comments From the Department                of
                                                 the Interior




                                                                    U.S.           DEPARTMENT OF INTERIOR
                                                                RESPONSE            TO THE GAO DRAFT   REPORT

                                             “SPECIAL    EDUCATION:                       ESTIMATES    OF HANDICAPPED     INDIAN
                                                  PRESCHOOL   CHILDREN                     AND SUFFICIENCY      OF SERVICES”

                             The      Department           of     interior        agrees       with         much      of   the     GAO’s       analysis
                             Of the         eStimateS          of     handicapped           Indian          preschool          children          and     the
                             sufficiency             of    services           for   these      children,              however,         several         sec-
                             tions       of     the     report        require       further         clarification                and/or        comment.

Now on p 3                     1.      Executive              Summary             (page     5)

                             “On      the       reservations               with      8IA      schoo      Is ,   2.110         of       the      estimated
                             2,948         handicapped                 Indian        preschoolers              may     need      but     were       not      re-
                             ceiving            special          education           and/or       related       services....Most                      of     the
                             2.110         children              who we         believe         may       need     services          have       yet      to    be
                              individually                 identified           or     diagnosed          as handicapped               by the         mutti-
                             disciplinary                 evaluation            teams.          Consequently,              we cannot            provide          a
                             precise           estimate             of   the       number         of      chi ldren          who       actually            need
Now on pp. 18-23.            serv      i ces.         <See       pp.     27-34.      )”

                                       Department               of     Interior            Response

                             8IA     Special               Education           Coordinators                  provided        an       estimate          of     the
                             number        of       children           who       may be            handicapped.                 In all          cases,         the
                             estimate           represented                  children          who         are     suspected          of    being       hardi-
                             capped.             It      is not        an estimate              of     children          who      are     not     receiving
Nowon pp. 15, 18, 19,21,     services.                  Other        references              to      this        estimate         are     made      on pages
22, 25, and 38.              10,     22,      27,       29,     33,      37,      38,    60,       and      61 of      the   report.

Nowon   p. 5                   2.          Executive          Sumnarv             (page     6)

                             “Enro       I lment          and       population               data         were         unavailable                     from        8IA
                             national            or        local      officials               to     estimate            rel.iably           the       number        of
                             handicapped                preschoolers               who       might,             upon       reach       i ng      school          age,
                             attend           reservation                  schools            rather            than       the     public           or     private
                             schools          located            on     or        near        these          reservations.                       However,            20
                             reservations                  provided           data      indicating              approximately                50 percent              of
                             the      total        eligible           kindergarten                   and     first         grade         Indian          students
                             actua       I Iy       attend          8IA         schools            rather           than        public           or        private
Now on pp. 34-35.            schoo       I s.       (See       pp.    40-42.)”

                                           Department           of     Interior            Response

                             Interior              is     not     required        to      collect         or    maintain           data    on      the    num-
                             ber      of         Indian         children          who       attend        public          or   Private        schools       nor
                             does      it       have        ready       access       to        such     data         or    other        sources        of   in-
                             formation                including             birth       records.               Similar         references          are    made
Nowon   pp. 16and   34-35.   on pages              24 and         40-42      of   the       report.




                                                Page 59                                           GAO/HRD4KMlBR            Special Education        for Indian Children
                                Appendix VI
                                Comments From the Department                  of
                                the Interior




Now on p. 4      3.      Executive              Sumnarv             (page     8)

               “In     our       view.        EHA       requires        8IA     to assure          that    all       handicapped
                Indian       children             receive        an appropriate          education          on reservations
               with      BIA      schools         and     states      to    assume     Similar          responsibility                                   on
               reservations               without         8IA    schools.”

                         Department               of     Interior            Resbonse

               To the        best        of     our      knowledge,               there        is no part              of      any      reservat           on
               that      is     not       included             within           a     public         school             district            boundar        Y.
               This      is       true       whether             or      not      there        is an         Interior            school          I ocat ed
               on the        reservation.                           On       many         reservations,                      port     ions         of    the
               kindergarten                   through            grade            twelve           cant      i nuum         may      be served             by
               either         “B IA schoo            I s”    and/or           public         schools.                 In       many       cases,         the
               public        schools              are      actually             located          on the          reservation.                    Some of
               the     larger          reservations                 may       have      several           different               public         schools
               and    state           education              agencies               serving           the      same       reservation.                   For
               example,           the       boundaries                of        the       Navajo             reservation                  cross        four
               state          I i nes         CAr i zona,             New         Mexico,          Colorado,              and      Utah)         and     the
               Standing           Rock        Reservation                 includes           portions            of        both       South        Dakota
               and    North         Dakota.

Now on p. 4.     4.       Executive             Sum-nary             (page     8)

               “On     the       other       hand,        8IA   believes          that                it    is   responsible                 Only     for
                Indian       children          enrolled          in 8IA       programs                     and   that        other           agencies
               (such       as Head         Start        program       operators)                     are     responsible                 for     Indian
               children           enrolled          in the      programs          they               operate.”

                          Department               of     Interior           Response

               Interior          does       not   have       general        supervisory               authority          of    programs
               serving        handicapped                 Indian       preschool            children           and    it    is not       the
               only     provider              of  early          childhood          special           education          services           to
               handicapped                 Indian           chi ldren         on        reservations               with         Inter     ior
               SChOO I 5.          Programs,           such        as Head          Start,         operate         under       specific
               federal         legislation               and must          implement          the      programmatic             require-
               ments      of     applicable            statutes.

                 Interior         does       not    operate         Head     Start       programs          nor      does       it  operate
                a preschool             program         for     nonhandicapped               Indian        children.              However      ,
                handicapped              Indian       children         enrolled          in Head           Start       programs,           who
                reside         on     reservations              served       by schools            funded         by   Interior.          may
                be served           by     Interior          if   no other         agency        is available                 to provide
                the       needed     special          education          and     related         Services.

Now on p. 5       5.       Executive             Sumnarv             (page         11)

                “We       recommend          ihat                the      Secretary                 of       the       Interior          direct         the
                Assistant          Secretary                 for     Indian         Affairs                to        identify,             on       a re-
                curring        basis,        al I            Indian         preschool               children             suspected           of     being




                                  Page 60                                                GAO/HRD9041BR             Special Education      for Indian Children
                                    Appendix VI
                                    Comments From the Department                      of
                                    the Interior




                handicapped            in order        to              better           ensure        that              al        I    potential                handi-
                capped       preschool        children                     on        Indian     reservations                           with      BIA          schools
Now on p. 36    are    screened          and  evaluated.                            (See     p.   58.1”

                          DeDartment               of     Interior                 Response

                 Interior           has        successfully                implemented                 annual       Child           Find        activi-
                ties,         as       required             by       EHA,      for         many      years.         All      Area        and      Agency
                Special            Education               Coordinators                    conduct          annua      I     Chi Id          Find       and
                screening              activities                 on the            reservations              they       serve         to     identify
                children            suspected                of     being          handicapped.                   These        activities               are
                ongoing              and         may        include:                   interagency            Screening,               handicapped
                awareness             activities,                 training            Child        Find     Technicians,                 presenting
                 information                at      tribal          and      public          meetings,          newsletters                and       post-
                 ing      notices.

                This      year      for      the      first        time,        the     states          and      Interior              are      re-
                quired           to     report           the       number      of     handicapped             preschool              children
                being       served.              On      December          1,      1989      Interior           will         collect          such
                data      and       report        the        information            to    the      Department             of      Education,
                Off ice       of      Special            Educat       ion     Programs         _        The        results             will       be
                published           in      the     Annual           Report       to Congress             by the          Department              of
                Education.

                  6.       Special             Education:                            Estimates                    of         Handicapped                        Indian
Nowonp.   10               Preschool            Children                and        Sufficiencv               of        Services        (page                  15)

                “In    addition,              the     law     encouraged                       the      states               to       serve       handicapped
                preschool           children,           those      children                          ages      three                  to    five,        by pro-
                viding        incentive           grants.”

                           DeDartment              of     Interior                 Response

                While    states                receive           incentive                    grants       to serve                     preschool               handi-
                capped     children,                 the         Department                     of     Inter   ior                    is      ineligible                   to
                rede i ve these                  grants.               Interior                 uses       EHA Part                       8 funds             for        the
                early    childhood                 special           education                  program.

                  7.       Special             Education:                           Estimates                     of         Handicapoed                         Indian
Nowonp.   11.              Preschool            Children                and        Sufficiencv               of        Services        (page                   15)

                “The      amendments            a 1 so                   require            the          states             to        begin        serving            all
                handicapped        children,                           birth           through             age           five,                no      later         than
                October        1,  1990.     ‘I

                           Department              of       Interior               ResDonse

                The      amendments,            which                   became                I aw      on        October        8.     1986,      allowed
                states      four     years      to                imp I ement                 preschool                 handicapped             Services.
                whi   le    the      Department                      of      interior                was          required          to    provide         Pre-
                school      services        by or                 before       the            1987-1988               scnool        year.




                                    Page 61                                                GAO/ZZRIMMlBR                     Special Education          for Indian Children
                                   Appendix VI
                                   Comments From the Department                     of
                                   the Interior




Now on p. 11     0.        BIA’s         Role            in        Sbecial      Education            (page        17)

               “BIA’s           policy            is         to       ensure      that         special          education               services            are
               available                 to       all             handicapped            Indian      children,             ages       three         through
               21, who                I ive       on        reservations                with         BIA      schools.                BIA     officials
               told         us       that         ‘ensuring’             special             education            services            are     available
               means         working              with        other       local         service          providers              to    determine             how
               best           to       meet            the        needs          of       handicapped                Indian         children.               The
               officials                further             stated       that,          in some             instances,              agencies            other
               than         BIA         should           either          pay        for        or    provide           the      services           needed,
               but        in no            case          will         a     child            be      denied            services             because           of
                jurisdictional                       disputes.”

                          Department                    of         Interior       Response

               State         education              agencies            also        receive             Part         I3 funds      and     Section
               619       preschool             incentive            grants        to      provide            services         to   handicapped
               preschool             children,              including           Indian           children.               The    EHA restricts
                Interior’s             use       of    the      set-aside            funds         to     the         need    for    assistance
               for       the       education             of       handicapped               children               on reservations              ser-
               viced         by elementary                  and       secondary               schools              operated          for     Indian
               children            by the          Department             of    Interior.

               State      education                          agencies.           Irterior,            and    other       service       providers,
               must     work      together                        to      provide            services            to      handicapped          Indian
               preschool          children.                           The     following            case      exemplifies           the    need      for
               agencies        to work                       together         to     provide         services:

                          Parents           Of a four             year-old              Severely             handicapped                Indian        ch        ia
                           live      in       the      town          of      Dunseith,             North         Dakota.            They     wanted            to
                          enroll         their         child          in       a     Tribal             Head          Start           program         wh       ch
                          serves          I nd i an        children              from          the      reservation.                      Dunsei      th       is
                          not     within          the         boundaries                  of        the        Turtle             Mountain          Ina        an
                          Reservation               or        the       closest           Interior             school           (Dunseith           Indian
                          Schoo      I 1.       Both        Interior                and      public            schools            are       located            on
                          the       reservation.                             The         Head           Start           boundaries                include
                          Dunseith,               however,                 al I       school-age                 chi ldren              in      Dunse      i   th
                          attend         Dunseith               Public           Schools.                 Indian           children           represent
                          approximately                    85%          of       the         enrollment                  in       Dunseith          Public
                          Schools.                Dunseith              Public          Schools           also        operates            a preschool
                          handicapped               program.

                          Interior’s                Agency            Special             Educat         ion      Coordinator                    has       an
                           interagency                 agreement              with          the         Head         Start           Center          which
                          specifies             that       the      Agency        will        provide           special            education             ana
                          related            services               to      the      those          handicapped                Indian          children
                          enrolled           in the          program          who      reside           on the            reservation.                   The
                          Head         Start           Handicapped                 Coordinator                  approached                the      Agency
                          Coordinator                and       requested             a      full-time              aide          for      this       child
                          because            of        the        nature           and      severity            of      the      child’s            hanal-
                          capping          condition.                 Head         Start’s            rationale               for       the      request
                          was      based        on the          interagency               agreement             with        the       Agency.




                                 Page 62                                                  GAO/HRD-90-61BR          Special Education        for Indian Children
                                   Appendix VI
                                   Comments From the Department                of
                                   the Interior




Now on p. 12.     9.       8IA’s        Role       in   Special          Education               (Table       2,    page       18)

                “(b)         In      schoo       I   year         1988-09,           437  handicapped        Indian                       three       and
                four       year-olds            were      served,          but      an   unknown      number       of                  five        year-
                olds       were      also       served.”

                           Department             of     Interior             Response

                Children            Served        Preschool            Program           1986-1987                                                    100x
                                                                                         19874988                                                 1.200*
                                                                                         1988-1909                                                1 .600*

                *These         estimates                include            three         and        four        year-old           handicapped
                 Indian      children,                as well            as.     those         five        year-alas               who     did   not
                reach      their          fifth         birthday           by December              31st.            Children           must   meet
                this     age      requirement                to     be enrolled            in an            interior           kindergarten.
                Handicapped             Indian             chi Idren.          who     do not         meet         these      criteria,          are
                served       by     Interior             in     its   early        childhood             special             education         pro-
                gram.          The      GAO study              was     limited         to    collecting                data      on three        and
                four     year-old             children.

                Many     Area/Agency                 offices         provided            early        childhood              special          educa-
                tion     services              before        the     mandate,            such        as,    Papago.          Pima,         Southern
                Pueblos,         and         Standing          Rock.

Now con p 33    10.        Aqenc     i es ’     Resoonsibilities                     for   Educatina                Handicapoed                   Indian
                           Preschool            Children            Unclear          (page    35)

                “In     our       view,        EHA       requires       BIA       to             assure        that     all      handicapped
                 Indian       children           receive         an appropriate                      education          on reservations
                with        BIA       schools.                 On   the       other                  hand,     states         should      assume
                similar         responsibility                 on reservations                       without        BIA     schools.”

                “The      Department              of     Education             believes           that        under       EHA’s       section
                611(f).          BIA        is       responsible               for        providing              a free      appropriate
                education           to   those         Indian         children           who         I ive      on      the     63      reser-
                vations        with         SIA      school5.                In this        regard,          Department         officials
                told      us BIA       has      sole        responsibility                    for        the     handicapped            Indian
                children         on       the     63        reservations             with       8IA      schools,         even     if      local
                public       schools          are      also       on the       reservation.”

                           Department              of    Interior             Response

                 Interior           disagrees              with       the    GAO and           Education.                   The     educational
                delivery            system            for       Indians            on reservat          i on5       is very         complex          ana
                varies          from       reservation-to-reservation,                                 state-to-state,                        ana may
                differ            within            a      single          reservation.                    Indian          parents          exercise
                their        right         to    enroll           their       children         in the           school        or      program          of
                their        choice             and      the        opportunities              will        differ          depending            on the
                age       of    the      child,         where          the      reservation             is        located,          and whether
                or      not     the      child         is handicapped.                    Determination                 of     responsibility
                cannot          be made           conclusively                without        exception.




                                   Page 63                                          GAO/BRD-90-61BR          Special Education         for Indian Children
                  Appendix VI
                  Comments From the Department                    of
                  the Interior




The       following             examples        iI lUStrate        a few     of    the     many                     ways         in which
 Interior            and/or          public       schools      serve     Indian        children                         on       reserva-
tions          where        Interior        operates        or   funds     schools:

         The    Standing          Rock   Reservation            includes                            areas            of       both     North
         Dakota      and      South    Dakota.          An Indian        child                         may         live         on a part
         of   the       reservation         which         is in      South                          Dakota                but    attend      a
         school       located        in North        Dakota.

         On the         Rocky         Boys       Indian         Reservation              in Montana,             the    follow-
          ing   are      all        located          adjacent             to       the       same        Playground:                a
         tribal         Head          Start        center,          a public           school        (grades         K-B),      and
         an      Interior-funded                       tribal           cant     ract        school       ,    grades        9-12.
         Some      of        the      secondary               Indian         students          choose        not     to attend
         the    tribal            Contract           school         and      attend        the     public        high      school
         which        is      located        off       the      reservation.

         The      following                 are     all        located          on the        Gila       River        Reservation
          in Arizona:                  one      public           school         (K-B).        two        parochial             schools
          (K-B),            two         BIA        operated              SCh00lS            (K-4        61 K-61,         one     tribal
         contract             school             (preschool-21.                   one       public         alternative                high
         school,            seven           Head Start                 centers,           and      one     tribal          preschool
         center.              All      secondary-age                     students             attend            public         schools
         off      the         reservation                 with         the      exception            of    those         who     attend
         the      alternative                 high        school.            Some         parents          who         I ive     on the
          reservations                    work          in       nearby           Tucson           and        they       take       their
         preschool               children            and       place       them        in     day care              or     preschool
         programs              in the         city.

         The      Turtle            Mountain             Agency            has      had       a cooperative                     agreement
         with        the      Belcourte              Public         School          District              #7.       since          1981,        to
         provide            for        the      education             of      Indian          children              who       live        on or
         near        the      Turtle        Mountain              Reservation.                     Under          this        agreement,
         public           school         employees              teach         in     Interior             schools            and public
         school           teachers           are          supervised                by         Interior             administrators
         &nd vice             versa.             Interior’s              Agency          Special            Education               Coordi-
         nator          interviews              all       prospective               special             education                employees
         and      recommends                 candidates               to        the      public           school           board.            Al I
         of     the         special          education                 teachers             in        the      Agency’s             schools
         are      public             school          employees,                 and      most,          but       not      all,        of     the
         aides         are      also       public             school          employees.                     Interior’s                Turtle
         Mountain             Agency            Special           Education                 Program            is      recognized               by
         the      North         Dakota          Department               of      Public          InStrUCtiOn                  as a State
         multidistrict                     special              educat        ion        unit        and       it      receives             some
         state         funds         for      the       program.            in addition                 to     Interior              funds.

         The    Seminole              Tribe        of      Florida            has        five          separate         reserva-
         tions       only         one     of     reservation             has      an      Interior-funded                 school.
         Ahfachkee              Elementary             School        (grades             K-6)        is      located        on the
         Big    Cypress               Reservation.                 All     of     the       Seminole           children          from
         the      other             reservations                 at tend          either             publ    ic      or   private
         schoo     I S.            Many         elementary               chi ldren               from      the      Big   Cypress

                                                                                                                                                     -



                  Page 64                                               GAO/HRD-!%61BR              Special Education          for Indian Children
                                     Appendix VI
                                     Comments From the Department                     of
                                     the Interior




                            Reservation             attend               Hendry        County       Public       Schools                  rather       than
                            attend         Ahfachkee                   Elementary           School.            All    of            the     secondary-
                            age      Indian       children                 I iving      on this        reservation                    attend      county
                            or    private         schools.

                            On the             Cherokee            Reservation                 in North              Carol      ina.        two       county
                            public           school        systems           divide          the     reservation,                     The        Cherokee
                            Centra         I     Schoo      I      (K-12)           is       operated             by     Interior              while         the
                            school’s             special           education           and       Chapter           I     programs              are      oper-
                            ated        by       the     Cherokee              Boys       Club,           Inc.,       under         contract               with
                             Interior.                Some      of       the      teachers             are      employees                of       Interior
                            while         others         are      employees            of      Cherokee           Boys       Club,           Inc.          Many
                            of      the        Cherokee              chi ldren            attend            Cherokee              Central             School
                            whi le           others           attend           one        of       the        county           public            schools,
                            depending               on which           side      Of the          reservation               they        live         on.

                            On some      reservations,              Interior              operates           a  schoo      I    that        is
                             I imited      to      certain         grade            levels,           such     as,    kindergarten
                            through      grade       two   or    grades          nine       through        12.     On     these        res-
                            ervations,         publ     ic    school         systems            serve      the   Indian       children
                             in the    other       grades.

                These        are      but      a       few      of       the    many           ways        in       which          Interior         and/or
                public         schools               serve         Indian          chi Idren.                   In spite               of   these       com-
                plexities,               Interior,              through          its      Area        and      Agency           Offices,          assures
                a free           appropriate                  public           education              for         all      handicapped               Indian
                preschool             children              on reservations                    served          by        its      schools.              Many
                times,         services                and      actual         service            providers             are       determined            on a
                child-by-child                     basis,          in order             to meet              the      individual                needs       of
                the        chi Id,           and          these          wi I I      vary           depend        i ng       on the         nature        and
                severity           of        the       hand i cap.               I nter      i or       believes             it         is the      handi-
                capped         child            and       his        or    her       specific             needs         that         determines           how
                agencies           should             work           together             to        provide             the          needed       special
                education             and       related            services.

                11.         Aaenc     i es ’ ResDonsibilities                                for    Educatina              HandiCaDDed                Indian
Now on p. 33.               Preschool        Children         Unclear                      (page     36)

                “For     example,               BIA      believes              that      HHS       is     responsible                   for    providing
                an appropr        i ate               education              to       Indian         children            in     local         Head     Start
                programs.       ”

                            DeDartment                of    Interior             ReSDOnSe

                Head      Start        is a national              program,         administered                            by HHS,       whose      goa            I
                 is to      provide          comprehensive              developmental             serv                     ces   to    low     income,
                preschool           children         and     their          fami    I ies.        Head                     Start    accomplishes
                this        goa I        through         the         implementation               of       f               our     major      program
                components:                hea I th      (medical         I    denta       I ,  nutrition,                          and mental),
                social        services,           parent        involvement,               and  education.

                 Interior            does          not      operate           Head         Start      programs,               however,           eligible




                                     Page 65                                               GAO/HRD-SO-GlBR           Special Education         for Indian Children
                                           Appendix VI
                                           Comments From the Department                   of
                                           the Interior




                        handicapped               Indian           preschool            children              who     are        enrolled           in Head
                        Start        programs             may      be       served        by        Interior           if     no other          agency      is
                        available           to      provide           the       needed           special            educat        ion       and     related
                        services.               Interior,              in receiving              EHA Part           B funds,            has     assured       a
                        free      appropriate               public            education              to       al I        handicapped            children
                        enrol      led       in       Schools             and      preschool               programs           funded        by    Interior
                        consistent            with        the      requirements                  of     34      CFR 300             and     the     special
                        education           standards              of     the     Bureau         of      Indian       Affairs.

                        12.        Services            Provided              to       Handicapoed                Indian         Preschool             Children
Now on pp. 23-24.                  are      Insufficient                 (page         43-44)

                        “Service             information           provided         by      the            coordinators                     shows      that       at
                         least     24        percent         Of the      791     handicapped                    Indian          preschool            children
                        with     IEPs          were      receiving          less    service                than      their          IEPs       prescribe.”

                                   Department              of      Interior            Resoonse

                        This        situation               is not            unique       to      Interior.               While            Interior           pro-
                        vided            services               to        437        of  the     791      handicapped                Indian          preschool
                        Chi ldren.             the       remaining              children           were      served           by other               agencies.
                         Interior            makes            a good          faith      effort        to     provide         all        of     the       special
                        education              and       related              services           which          handicapped                   children            may
                        need.              However,              insufficient               funds,        lack      of    Certified                staff,         and
                        geographic               accessibility                    are    examples            of     obstac        I es       which         hamper
                         Interior’s              efforts             to     provide        needed        services.

Now on pp. 32-33.       13.        Fundina           Shortages                (page      55-56)

                        ” In     discussing               funding           difficulties,                        Branch        officials           told      us
                        that     the       special        education               program               experienced               a severe          funding
                        shortfal         I in       school        years           1987-1900                 and       1988-1989.              Because        of
                        this     shortfall,             the     Branch         provided                 Only      52.3     Of the         $4.3     million
                        field      offices            requested          to       provide               special        education           services          to
                        handicapped                Indian         preschoo           I    chi         ldren         in     schoo        I   year         1988-
                         1989..     . .I@

                        “Branch         officials                told       us that       they   are              uncertain          of     the     cost      of
                        providing            special           education         services           to             al I       handicapped             Indian
                        preschool            children            on the       63 reservations                      with       BIA    schools.             They
                        have      never           developed              an    overal       I  cost                estimate            because          their
                        program         funding              level        is    determined          by            and     limited        to     the     EHA’s
                        1.25      percent           set-aside.”

                                   Department              of     Interior             Response

                        The        funding         shortfall           was      due        to       the      i ncrease          in    the    service
                        population               and         because        Interior              had no other            funding       source        for
                        these            handicapped                Indian             preschoo         I      chi Idren.               School-age
                        handicapped                   Indian          chi Idren,              enrol     led       in    schools       operated          by
                         Interior.             are      supported          by        base         funds        provided           by    the     lnaian
                        School           Equalization                 Program          (ISEP),            as authorized             by the      Indian

                    L

                                         Page 66                                               GAO/HRD!+OH)SlBR           Special Education         for Indian Children
                                  Appendix VI
                                  Comments From the Department                    of
                                  the Interior




                Self-Determination                  and      Education           Assistance                         Act      (P.L.      95-56    1) .
                When      ISEP      funds     are      insufficient            to meet          the                needs     of    handicapped
                 Indian      children,          Part      0 funds         may    be used          to               supplement,          although
                not     supplant,          ISEP      funds.          Preschool         children                      are   not     included        in
                the     ISEP      formula.

                 Interior         is       mandated         to       provide          services           to     handicapped                Indian
                preschoo       I      chi Idren.            however,              it      is       not   required           to operate            a
                program        for       their       non-handicapped                  peers.             Because            there            is no
                source      of      base       funding         for     Interior’s              preschool          special          education
                program,          Interior             must        fund         the       entire         handicapped               preschool
                program        with        Part      B funds.            The      lack      of     base     funds       for      Interior’s
                handicapped              preschool          program           has     adversely          affected            the     program.

                Interior           has      not      developed              an overall                  cost      estimate              for    serving
                handicapped                  Indian            preschoo           I    chi ldren              for        several          reasons           in
                addition           to     the      set-aside              limitations.                    Many       agencies           serve        these
                children           which         makes          it  difficult               to      determine            Costs.             It  is also
                difficult             to    develop            a    formula            that          will       yield          a reliable              cost
                estimate.                   There            are      many           components                 which        would        need       to     be
                factored            into       the     formula            including:                  nature         and       severity           of     the
                handicapping                     condition;                    type     I        frequency               and        intensity               of
                services:             and      accessibility                  and      availability                  of    services.

Now on p. 36.    14.      Recorrrnendation                  to       the      Secretarv            of    the      interior             (page       58-59)

                “We recommend              that          the               Secretary           of        the           Interior             di rect       the
                Ass i stant           Secretary              for               Indian        Affairs              to        identify,          on a re-
                curring        basis,         al I Indian                     preschool           children                 suspected           of    being
                handicapped             in      order        to             better        ensure         that          all      potential           handi-
                capped       preschool            children                  on     Indian      reservations                     with      BIA     schools
                are     screened          and evaluated.”

                          Deoartment               of     Interior              Response

                 Interior          has      successfully          implemented         annual          Child       Find    activi-
                 ties,      as     required        by El-IA,   for     many   years.         Interior           also     collects
                 data       for        the     December        1     child    count     which         is    reported         to   the
                 Department            of   Education,       Office        of Special       Education             Programs.

                 This      year,       for       the       f i rst              time,           state          educat        ion      agencies            and
                  Inter     ior    are        required          to           report          the    number         Of      handicapped               Indian
                 preschool           children          served.                   Interior           will       submit          its       data       to    the
                 Department               of      Educat      ion              which          will       publish           the     results           in the
                 Annual         Report        to    Congress.




                                   Page 67                                                  GAO/HRD-SO-GlBR       Special Education            for Indian Children
Appendix VII

Major Contributors to This Report


                        Fred E. Yohey, Jr., Assistant Director, (202) 245-9623
Human Resources         David D. Bellis, Social Science Analyst
Division, Washington,
DC.

                        Edward M. Zagalo, Evaluator-in-Charge
Office                  Lawrence Johnson, Site Senior
                        Alexandra Y. Martin, Site Senior
                        Victoria A. Hughes, Evaluator




                        Page 68                       GAO/HRD-90-61BR   Special Education   for Indian   Children
(104618)