Personnel Security (PerSec) created this page for Tribally Controlled Schools to provide the resources needed to meet Personnel Security Requirements under 25 CFR 63, Indian Child Protection and Family Violence Prevention, along with recommendations to enhance TCS schools' personnel security program.
Background
Under 25 CFR 63.13(b), all Indian tribes or tribal organizations receiving government funds under the Indian Self-Determination and Education Assistance Act or the Tribally Controlled Schools Act of 1988 must conduct a background investigation on individuals with regular contact or control over Indian students and employ only individuals who meet the standards of character that are no less stringent than those prescribed for the Bureau of Indian Affairs.
Regular reviews of these schools are conducted as part of the Grant Assurance Review to ensure they meet regulatory requirements. Effective November 1, 2019, the responsibility of the background investigation portion of the Grant Assurance Reviews was transferred from the Grants specialists to the Bureau of Indian Education's Personnel Security Branch.
November 1, 2019, Memorandum Transferring TCS Audit Authority to BIE Personnel Security (118.9 KB)
Under the assurances of Public Law 100-297, Tribally Controlled Schools sign and authorize the BIE to access and examine all records, books, papers, or documents related to the award. In signing this form, TCS also confirm they will comply with existing Federal Laws pertaining to background investigations, including PL 101-630, the procedures in 25 CFR 63, and PL 101-647. None of the provisions in the assurance statement are intended to impinge on tribal sovereignty but are intended to maintain program integrity and ensure accountability.
Regulatory References
25 CFR 63, Indian Child Protection and Family Violence Prevention
Public Law 101-647, Crime Control Act of 1990
Public Law 101-630, Indian Child Protection and Family Violence Prevention
TCS Audit Process
BIE Personnel Security will contact any TCS/facility identified as requiring a review for the school year and assign a Personnel Security Specialist (PSS) as the primary point of contact for the review. For questions on the review process, schools can contact their assigned PSS or Sara Shoemate Cameron at sara.shoematecameron@bie.edu.
Audit Materials
In-Briefing Program Review Presentation
File Maintenance Certification
TCS Np2 Two-Factor Authentication Log-on (virtual audits only)
Uploading documents into the DCSA Secure Portal (virtual audits only)
Adjudication References and Sample Forms
TCS are not required to use these forms. They are provided as sample wording for security questions, etc.
Guidance for Adjudicating Bogus Education Credentials
Sample SF 85 – Security Form Questionnaire
Sample SF 85p – Questionnaire for Public Trust Positions
OF-306 – Declaration for Federal Employment
National Sex Offender Registry
Tribal Court Clearing House - Locating tribal courthouses
U.S. Department of Education - Verifying school accreditation
