Report 2022-107 Recommendation 1 Responses

Report 2022-107: Native American Graves Protection and Repatriation Act: The California State University Must Do More to Ensure the Timely Return of Native American Remains and Cultural Items to Tribes (Release Date: June 2023)

Recommendation #1 To: University, California State

To ensure that campuses have identified all of the remains and cultural items in their NAGPRA collections, the Chancellor's Office should monitor campus efforts to review their collections and require the completion of their inventories by December 2024.

1-Year Agency Response

In October 2023, the Chancellor's Office (CO) provided all 21 campuses with NAGPRA collections with the Campus Repatriation Implementation Plan (Plan). The Plan outlines specific steps to help the campuses identify all the ancestral remains and cultural items in their collections.

The Plan required each campus to provide a response to the CO, by December 2023, with the status of their inventory assessment. The CO received and reviewed the responses from all 21 campuses, met with each campus to discuss their Plan, and will require updated Plans from each campus that will be due before the end of the year.

In response to feedback received at the systemwide policy listening sessions, the CO is considering additional ways to ensure all campuses continue to conduct searches of all campus facilities to make certain that all ancestors and cultural items are identified and accounted for in the repatriation process. For example, some campuses have sent out additional surveys to all staff and faculty asking them to search for any items that should be accounted for.

Further monitoring is being conducted by the systemwide CalNAGPRA project manager via monthly meetings with campus NAGPRA coordinators to answer their questions, help ensure they are following the necessary steps, and offer any additional guidance or support that is needed to comply with this recommendation. The CO NAGPRA team also meets with the presidential designees monthly to ensure communication is happening at all levels.

In addition, the CO sent memorandums to all campus presidents in December 2023 and February 2024, reminding them of the requirement to review their collections and complete inventories by December 2024. This requirement was also reiterated at the Board of Trustees meeting on March 26, 2024.

AB 389 requires the CSU to report to the legislature the CSU's progress on reviewing its collections by December 31, 2024.

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

On October 30, 2023, the Chancellor's Office provided all 21 campuses with NAGPRA collections with the Campus Repatriation Implementation Plan (Plan), which was also reviewed by the Native American Heritage Commission. The Plan provides a framework to guide the campus's repatriation work, including the establishment of timelines and budgets, and outlines legal requirements and specific steps to help the campuses identify all the ancestral remains and cultural items in their collections.

In addition, the importance of reviewing collections was discussed at a December 5, 2023, meeting of all presidents and a memorandum reiterating the importance of reviewing collections was sent to each president on December 13, 2023. That memorandum included an inventory survey template.

The Plan required each campus to provide a first response to the Chancellor's office by December 15, 2023, with the status of their inventory assessment. The Chancellor's Office is reviewing the campus responses and will determine intervals for ongoing reporting and monitoring.

Further monitoring is being conducted by the systemwide CalNAGPRA project manager via monthly meetings with campus NAGPRA coordinators as well as one-on-one meetings with campus coordinators to answer their questions, help ensure they are following the necessary steps, and offer any additional guidance or support that is needed.

California State Auditor's Assessment of 6-Month Status: Partially Implemented


60-Day Agency Response

The Chancellor's Office plans to issue a Repatriation Implementation Plan to campuses. The Chancellor's Office will use the Repatriation Implementation Plan to monitor campus progress by establishing deadlines for completion of the inventories. The Repatriation Implementation Plan will guide the campuses' repatriation work and require the campuses to describe their compliance with NAGPRA and CalNAGPRA. All campuses are currently working towards the completion of their inventories, and many are engaged in the consultation process.

California State Auditor's Assessment of 60-Day Status: Pending


All Recommendations in 2022-107

Agency responses received are posted verbatim.