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7.

The negotiation procedures as presently practiced by the Bureau

of Indian Affairs are in fact clarification sessions on rules and

regulations therefore, the Minnesota Chippewa Tribe recommends negotiation procedures be redefined to reflect actual and real negotiations at the contractual level.

8.

The portion of the contract component commonly referred to as the "boilerplate" be modified to represent current education standards applicable to the contracting Indian tribe.

9.

Current Bureau practices allow for "penciled changes" in Johnson O'Malley required procedures for contractors resulting in program confusion and inconsistency, therefore, the Minnesota Chippewa Tribe recommends manual changes including the so-called "pencil changes" be required to follow the Federal Register process now practiced by the government for new rules and regulations for federal programs.

10. The Minnesota Chippewa Tribe recommends contracts and contract negotiation be processed at the Washington level thereby saving millions of dollars now spent at the area level.

11.

The Minnesota Chippewa Tribe recommends action be taken immediately to stop the $1 Million (plus) administrative costs illegally

expended by the Washington BIA office. Section 102 subcontractor

is to be commended for finding and documenting this BIA illegal

expenditure.

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12. In that the State of Minnesota has several separate Tribal bodies within its boundaries therefore, the Minnesota Chippewa Tribe recommends contractor plans be required in lieu of state plans, and further such contractor plans reflect documented needs with appropriate evaluation procedures required in the plan and with the necessary additional appropriations made for the needs assessment and evaluation.

13. The Minnesota Chippewa Tribe supports Section 103 (Jones) statement regarding community schools, in that the Tribe unequivocally

supports community schools regardless of cost, and further,

recommends efforts be made to obtain the full support from State and Local educational agencies for community schools.

14. The Minnesota Chippewa Tribe recommends if basic support criteria remains as presently stated (in the new regulations) that is that school districts must show a 70% Indian student population to be eligible for basic support funds, a change is recommended in wording from school "districts" to school attendance areas.

15. The Minnesota Chippewa Tribe recommends that BIA records be standardized with assistance and consultation from contracting Tribes and further the standard form thus devised reflect actual activities as carried out in the field.

16. The Minnesota Chippewa Tribe recommends administrative costs be redefined and stated as program costs, when the contractor is an

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Indian tribe. Justification for this position is available in the JOM study commissioned by the Tribe and conducted on the six reservations. The study results and report will be made available to the contractor for the national study, the National Indian Education Association.

17. The Minnesota Chippewa Tribe recommends a legislative change be considered in Title IV, the Indian Education Act, P.L. 92-318, in that the Tribe recommends the Title IV fund available under

Part A of the act be contracted to Tribes for the administration of and dissemination to (of funds) the Local Educational agencies.

18. The Minnesota Chippewa Tribe recommend Title IV interpretation of rules and regulations be in writing and disseminated on a regular basis to Indian tribes and organizations. The oral

interpretation presently carried out by Part A, Title IV staff causes confusion between tribal groups and LEA representatives.

19. Title IV rules and regulations ought to be revised to include
"definition of teacher", further, parent committee eligibility
requirements shoudl be clearly stated regarding eligibility

of white parents of Indian children, a clear definition of "foster
parent" is needed and additionally the rules and regulations
ought to limit teacher voting participation for parent committee
members to a specific percentage point of not more than ten percent
(10%) of the total voting constituency.

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20. The Minnesota Chippewa Tribe recommends the regulations for Title

IV be changed to show Indian Tribes' guidelines for tribal elections
as the recommended way to elect Parent Committees and further,
that Indian tribes be designated as the Official election board
for Title IV eligible districts within their jursidiction.

21. Title IV rules and regulations should state "there shall be annual

elections" (of parent committees); as the rules are presently stated regarding elections, it is not clear to Parent committees and LEA's that yearly elections must be held if the proposal cycle requirements are to be met, in the public hearings must be held each year after which the committee is to be elected.

22. The authority of the Parent committee should be clearly defined regarding parent committee recommendations and basic guidelines as promulgated by parent committees on LEA personnel selections for Title IV positions.

23. The Tribe recommends Title IV Washington Office be instructed by Congress to write and disseminate a "layman's" version of the rules and regulations for Part A and B and C of the Indian Education

Act.

24. As HEW permits under its regulations, a written interpretation of the rules and regulations show a clear mentod of automatic carry-over provisions for Title IV fiscal year-end funds. If

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HEW regulations do not permit automatic carry-over provisions

the Office of Indian Education should be directed to study HEW regulations to permit a change to allow such a procedure.

25. Indian preference interpretation by the Office of Indian Education

as being appropriate or inappropriate for Title IV personnel

be released through the Federal Register mechanism with the necessary supporting data.

26. The Office of Indian Education should be instructed by Congress to promulgate measures for the LEA's to provide documentation signed by Parent Committee members showing spending of Title IV funds are carried out as stated in the proposal or revised proposal.

27. The Minnesota Chippewa Tribe recommends congress instruct the Office of Indian Education to show consistency within the Office of Indian Education regarding interpretations of the rules and regulations. For example, recent rules and regulations interpretation as provided by the present acting manager of Part A are from time to time inconsistent with previous interpretations as promulgated by the past manager of Part A. These inconsistencies cause anguish, confusion and hardship at the tribal, parent committee and LEA

level.

28. The Tribe recommends the Office of Indian Education offer a clear written interpretation regarding precedence of the LEA or the parent committee on personnel recommendations for Title IV positions.