State Audit Recommendations

Implementation of Recommendations in CSA Report 2024-047

CSA Report 2021-047 was released on April 15, 2025. UC is actively working to implement all recommendations to UC, which are summarized below:

  • UC’s Repatriation Dashboard should provide more information and clearer details to stakeholders, including counts of potential cultural items, accessions or sites, and details about the counting approach used.
  • UCOP should establish a strong system to identify all undiscovered collections. UCOP should direct all campuses to develop detailed schedules for physically reviewing all locations for undiscovered collections, prioritizing areas most likely to house undiscovered collections. UCOP should also ensure such reviews are unfettered, performed by NAGPRA staff and qualified individuals, and assist campuses that report encountering resistance. UC should also amend its systemwide policy directing NAGPRA staff to perform these reviews.
  • UCOP should ensure that all collections are being properly cared for. UC’s policy adopts federal standards for collections storage. Noting that these standards currently only apply to ancestral remains and identified cultural items, CSA recommended that UCOP amend systemwide policy to ensure these standards also apply to campus storage areas for potential cultural items. UC should also recall and ensure the return of all outstanding loans.
  • UC Santa Barbara (UCSB) should notify tribes of all potential cultural items. UCSB should review all its collections to ensure all potential cultural items are reported to the National NAGPRA Program, NAHC, and potentially culturally affiliated tribes.
  • Campus Repatriation Implementation Plans should be updated. UCOP should direct campuses to amend their plans annually and include clear timelines for repatriation and consultation.
  • UCOP should establish systemwide performance goals and metrics for its repatriation activities. UCOP should require biannual campus reporting on these goals, assess progress, and remedy areas where UC is not on track to achieve its goals. These goals be assessed and updated annually, and be posted to UC’s public website.
  • UCOP should review campus budgets in relation to systemwide performance goals. Where campuses are not meeting performance goals, UCOP should direct campuses to change their budgets if changes in spending would help meet the goals.
  • UC should provide adequate support to tribes for expenses related to repatriation. UCOP should study costs that tribes incur and report to the legislature a full list of costs and funding needed.
  • UC should acknowledge that NAGPRA no longer allows for the repatriation of ancestral remains or associated funerary objects that have no affiliation with a federally recognized tribe. UCOP should amend its systemwide policy (PDF) accordingly and should specify that in these cases, campuses should consult with non-federally recognized tribes on reinterment of the ancestral remains and associated funerary objects. 

Implementation of Recommendations in CSA Report 2021-047

CSA Report 2021-047 (PDF) was released on November 17, 2022 and made six recommendations to UC regarding:

  • Monitoring UC Santa Barbara’s efforts to identify and review its collections by July 2023,
  • Issuing guidance by Feb. 2023 on appropriately responding to remains or cultural items found in the future and proactively working with partner institutions to facilitate repatriation,
  • Establishing a uniform process for the campuses to consult with tribes by July 2023,
  • Hiring full-time campus repatriation coordinators by July 2023 (for campuses with greater than 100 sets of remains),
  • Requiring detailed campus repatriation plans by July 2023, and
  • Ensuring that campuses identify adequate funding sources for NAGPRA implementation.

As of June 4, 2024, CSA assessed all six recommendations as fully implemented.

Implementation of Recommendations in CSA Report 2019-047

CSA Report 2019-047 (PDF) was released on June 11, 2020 and made four recommendations to UC regarding:

  • Publishing the final systemwide NAGPRA policy no later than Aug. 2020,
  • Requiring biannual reports from campuses to the UC Office of the President no later than Jan. 2021,
  • Ensuring appropriate tribal representation on systemwide and campus committees no later than Nov. 2020, and
  • Informing tribes about all known missing remains and artifacts no later than Aug. 2020.

As of January 2022, CSA assessed all four recommendations as fully implemented.

The communication below was sent to campus Chancellor's Designees (PDF) on December 14, 2022, regarding the 2021-2022 Report of the California State Auditor on UC's repatriation efforts:

December 14, 2022

CAMPUS CHANCELLOR’S DESIGNEES FOR NAGPRA/CALNAGPRA MATTERS

RE: 2021-2022 Report of the California State Auditor on UC’s Repatriation Efforts

Dear Chancellor’s Designees:

On November 17, 2022, the California State Auditor released the report of its 2021-2022 audit as required under the California Native American Graves Protection and Repatriation Act (CalNAGPRA)[1].

The Office of the President will be sending separate guidance regarding other findings and recommendations in the audit report, but I wanted to draw your attention to the following two items and request your assistance in implementing them on your campus:

Completion of Campus Repatriation Implementation Plans

The UC Native American Cultural Affiliation and Repatriation Policy (PDF) ("UC Policy") requires each campus with known NAGPRA/CalNAGPRA-eligible Human Remains or Cultural Items to develop a Repatriation Implementation Plan describing the campus’s plan, timeline, and budget needed to ensure timely and proactive repatriation of Human Remains and Cultural Items.

According to the Auditor, "To ensure that campuses fully repatriate their collections in a timely and consistent manner, the Office of the President should require the campuses to complete and submit detailed repatriation plans by February 2023 for review and approval by the campus NAGPRA committees and review by the systemwide NAGPRA committee. The repatriation plans should include a detailed budget."

To allow sufficient time for review and approval by your Campus Committee and the Systemwide Committee before February 28, 2023, please ensure your campus Repatriation Implementation Plan is completed no later than January 31, 2023. Please also ensure that your campus budget plans include sufficient background and detail to clearly identify the resources and funding that will be needed to meet the stated repatriation goals. Please note this deadline is set in order to meet the Auditor’s deadline.

Section VI of the UC Policy includes more specific information on the required content of the campus Repatriation Implementation Plan. The attached template document has previously been distributed to all Repatriation Coordinators to aid campuses in drafting their plans.

Appointment of Full-Time Repatriation Coordinators

The audit report notes that "the Office of the President does not require campuses to hire full‑time repatriation coordinators even though the university’s NAGPRA policy specifies that these coordinators carry primary responsibility for a campus’s compliance with the university’s NAGPRA policy. As a result, some campuses with large NAGPRA collections have not hired individuals full‑time in this position." To that end, the Auditor states, "To ensure that campuses provide appropriate resources and oversight to the administration of NAGPRA and CalNAGPRA, the Office of the President should require campuses with more than 100 sets of remains or cultural items to have full‑time repatriation coordinators by July 2023."

To fully address this finding, all campuses with more than 100 sets of Human Remains or Cultural Items are hereby instructed to take all necessary steps to have in place a full-time Repatriation Coordinator, meeting all requirements of the UC Policy[2], no later than July 31, 2023.

Thank you for your continued assistance in UC’s efforts to bring Native American ancestors and their cultural items home. If you have any questions regarding the above matters, please contact me at Lourdes.DeMattos@ucop.edu or (510) 587-9850.

Sincerely,
Lourdes G. DeMattos
Director
Research Policy Analysis & Coordination

Attachment: Sample Repatriation Implementation Plan Template (DOC)

cc:        Provost and Executive Vice President Brown
            Vice President Maldonado
            Executive Director Motton
            Chief Policy Advisor McAuliffe
            Senior Principal Counsel Auriti
            Research Policy Manager Miller
            Research Policy Manager Perkins
            Campus Repatriation Coordinators

[1] Ca. Health & Safety Code § 8028: "The California State Auditor…shall conduct an audit commencing in the year 2019 and again in 2021 regarding the University of California’s compliance with the federal Native American Graves Protection Repatriation Act (25 U.S.C. Sec. 3001 et seq.) and this chapter. The State Auditor shall report its findings to the Legislature and to all other appropriate entities."

[2] Section IV.B.4 states, "The Repatriation Coordinator must have an in-depth, demonstrated understanding of and direct experience with: (a) Consultation practices and processes, building and maintaining positive working relationships with Tribes; and (b) NAGPRA and CalNAGPRA."