State Audit Recommendations

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


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 or (510) 587-9850.

Lourdes G. DeMattos
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."