Audit Recommendations Disclosure

When an audit is completed and a report is issued, auditees must provide the State Auditor with information regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year. Additionally, Senate Bill 1452 (Chapter 452, Statutes of 2006), requires auditees who have not implemented recommendations after one year, to report to us and to the Legislature why they have not implemented them or to state when they intend to implement them. Below is a listing of each recommendation the State Auditor made in the report referenced and a link to the most recent response from the auditee addressing their progress in implementing the recommendation and the State Auditor’s assessment of auditee’s response based on our review of the supporting documentation.

Recommendations to the University of California Office of the President

Recommendation 1

To provide more information and clearer detail to stakeholders, the Office of the President should update the university’s NAGPRA dashboard by June 2025 to include the following information:

• A count of potential cultural items systemwide and by campus.
• The number of accessions or sites systemwide and by campus.
• Details about the counting approach campuses use and the effect that approach has on how the data can and cannot be interpreted.

Recommendation 2

To ensure that it has a strong system for identifying all undiscovered collections, the Office of the President should direct campuses to develop detailed schedules for searching all locations for undiscovered collections. The campuses should base their schedules on the likelihood that certain areas will house undiscovered collections, with campuses searching the highest risk areas first. Searches should begin no later than June 2025 and all high-risk areas of each campus should be fully searched by June 2026.

Recommendation 4

To ensure that it has a strong system for identifying all undiscovered collections, the Office of the President should, as soon as practical, amend the systemwide policy to direct NAGPRA staff to conduct searches of any campus area that they have a reasonable belief may be the location of undiscovered remains and potential cultural items.

To provide assurance that the university is properly caring for all collections, the Office of the President should direct university campuses by June 2025 on the proper storage of potential cultural items. This direction should establish that campuses treat such items in accordance with the federal standards that the university has already adopted for remains and associated funerary objects.

To provide assurance that the university is properly caring for all collections, the Office of the President should ensure that, by April 2026, each campus has stored all collections according to the federal standards. The Office of the President should obtain this assurance through visits to campuses and inspection of storage conditions.

To provide assurance that the university is properly caring for all collections, the Office of the President should, by June 2025, instruct its campuses to identify all cases in which they have loaned NAGPRA collections for which the university has legal responsibility, notify tribes about the loan status, share as much information with them as possible about the location of the remains and items, and begin retrieving remains and items.

To provide assurance that the university is properly caring for all collections, the Office of the President should assist the campuses as necessary to relocate all loaned NAGPRA collections by January 2026, unless the campus knows that relevant tribes object to the relocation.

To address the outdated nature of the campus repatriation plans, the Office of the President should, by June 2025, take the following steps:

• Direct campuses to amend their plans so that they include clear timelines for finishing specific actions, such as dates by which campuses expect to be done with specific repatriations or consultations.
• Establish an annual update process by which the campuses would amend their timelines to reflect updated expectations.

To effectively monitor and direct the university’s compliance with NAGPRA, the Office of the President should do the following by October 2025:

• Establish systemwide performance goals and metrics for key repatriation activities such as searches, consultation with tribes, and repatriation of remains and cultural items.
• Require at least biannual reports from campuses regarding the performance goals and metrics.

Along with each biannual reporting cycle, the Office of the President should assess the university’s progress in meeting its goals. If necessary, the Office of the President should take action to remedy the areas in which the university is not on track to achieve its goals.

To maintain the relevance of the university’s performance goals, the Office of the President should annually assess the goals and update them as necessary by revising existing goals and by adding or removing goals.

To facilitate transparency about its performance and promote greater accountability, by no later than the timing of the first performance goal and metric reports from campuses, the Office of the President should post the university’s performance goals and associated metrics to its public website, and it should include supplementary explanation that would assist stakeholders in understanding the metrics and the university’s progress in meeting its goals. If the Office of the President updates its goals or metrics, it should maintain information about the former goals and metrics on its website so that they remain accessible as a record of its performance.

To ensure that campus budgets are sufficient to achieve repatriation in an efficient and effective manner, the Office of the President should, beginning for fiscal year 2026–27 and annually thereafter, consider campus performance relative to the systemwide goals when reviewing campus budgets. For areas in which the campus is not meeting the performance goals, the Office of the President should document its consideration of whether changes to the campus’s planned spending would help the campus achieve the goals and, if so, direct the campus to change its budget.

To ensure that all campuses provide adequate support to tribes for the expenses related to repatriation, the Office of the President should engage tribes to study the costs the tribes incur, and by January 2026, it should provide a report to the Legislature that includes at least the following information:

• A full list of the types of tribal costs for which the university proposes to provide funding and the total amount of funding that the university would need annually to pay for such costs.
• The total amount of funding required annually to compensate tribes for the time they spend in consultation.
• The total amount of funding required annually to compensate tribes for reburial costs.
• An accounting of the amount of funding the university has available to provide toward these costs and the amount of funding it needs, if any, from the Legislature.

To align its systemwide policy with revised federal regulations, as soon as practical, the Office of the President should engage stakeholders to revise the policy to acknowledge that repatriation of remains and associated funerary objects with no affiliation to a federally recognized tribe to California tribes is no longer allowed by NAGPRA. The revisions should also specify that in cases where the only affiliations are to California tribes, the campuses should initiate consultation with those tribes regarding reinterment of the remains and associated funerary objects.

Recommendations to UC Santa Barbara

To ensure that Santa Barbara provides information to tribes on all potential cultural items in its collections, by June 2025, the campus should review its collections and determine whether it possesses potential cultural items about which it has not notified the national NAGPRA program or the NAHC. If the campus determines that it has not provided information on all potential cultural items as required, it should submit this information.

Recommendations to the Legislature

To ensure that the university appropriately prioritizes NAGPRA, the Legislature should consider appropriating to the university funding specifically for NAGPRA and CalNAGPRA compliance while also placing conditions on that funding. Such conditions could include the following:

• The university must maintain information on its public website about its progress in repatriation that includes counts of sites or accessions, counts of potential cultural items, and disclosures about counts of remains, cultural items and potential cultural items that would be necessary to properly understand its progress.
• Campus repatriation staff must conduct searches of high-risk areas of campus within a certain period of time.
• Specific handling and storage requirements.
• The university must develop and maintain a system of performance goals and related metrics about which it publicly reports.