Tribal Government & News

Tribal Council: 2012 enrollment audit 'cannot be relied on' regarding blood quantum

08.29.2019 Dean Rhodes Enrollment, Tribal Council

By Dean Rhodes

Smoke Signals editor

A 2012 enrollment audit that became the foundation for a divisive era of disenrollment proceedings within the Grand Ronde Tribe “cannot be relied on to confirm whether an individual’s blood quantum in the Tribe’s system is actually correct,” according to a July 24 Tribal Council memorandum.

The enrollment audit, conducted by New Mexico-based accounting firm Anuskewicz & McCabe, was declassified by Tribal Council in an Aug. 6 authorization to proceed. Six Tribal Council members approved the declassification and three Tribal Council members did not vote on the issue.

A copy of the enrollment audit and Tribal Council memorandum were provided to Smoke Signals on Monday, Aug. 19.

According to the Tribal Council memorandum addressed to Tribal members that accompanies the declassified enrollment audit, the Tribe’s 2010 Strategic Plan directed the Member Services Department to perform an audit of enrollment files. Member Services personnel reported back that there were numerous inconsistencies between enrollment files and not all files contained complete documentation.

An outside auditing firm, the now defunct Anuskewicz & McCabe, was subsequently hired to examine the enrollment files and found a plethora of problems, from missing documents in many files to blood quantum and lineal descent issues.

Among the items that Anuskewicz & McCabe was tasked with examining were determining whether all required documents are in each file and identifying deficiencies, recalculating blood quantum for each Tribal member using documentation available in the Tribe’s enrollment records and determining whether each Tribal member met all enrollment requirements in effect at the time of his or her enrollment.

Almost seven years after the audit was submitted to the Tribe in December 2012, its findings, which were used to begin disenrolling Tribal members for dual enrollment and lineal descent issues, are being questioned.

“The scope of A&M’s work … did not include looking at how an error or change in the blood quantum of one individual affected his or her family,” states Tribal Council’s July 24 memo. “As a result, A&M’s report cannot be relied on to confirm whether an individual’s blood quantum in the Tribe’s system is actually correct.

“In retrospect, the Tribal Council believes the A&M audit should have had a broader scope of work. As the audit was designed, it did not address many blood quantum errors that have existed since before Termination.”

The audit examined 6,108 enrollment files:

  • 1,101 files of Tribal members on the Restoration Roll;
  • 1,314 files of Tribal members enrolled between July 1984 and January 1989;
  • 809 files of Tribal members enrolled between February 1989 and December 1993;
  • 879 files of Tribal members enrolled between January 1994 and March 1997;
  • 824 files of Tribal members enrolled between April 1997 and November 1999;
  • 136 files of Tribal members enrolled between December 1999 and November 2000;
  • 327 files of Tribal members enrolled between January 2001 and March 2004;
  • 352 files of Tribal members enrolled between April 2004 and February 2008;
  • and 364 files of Tribal members enrolled between March 2008 and August 2012.

Numerous problems were found, including almost 1,200 files with lineal descent issues and concerns, according to a tabulation performed by Smoke Signals.

“Although the files of 1,200 or more members may be noted as having lineal descent concerns, that does not mean there is a problem with the member’s lineal descent,” said Deputy Press Secretary Sara Thompson in response to e-mailed questions from Smoke Signals about the enrollment audit. “These cases could have been flagged for missing documentation, inaccurate information or any number of other issues.”

According to the audit, among the 1,101 files of Tribal members on the Restoration Roll, 24.7 percent – 272 – did not have anything in the file supporting the person’s blood quantum other than a “possible” copy of the Restoration Roll and sheet that gave roll number and quantum.

Also among Restoration Roll files, 17.5 percent – 193 – had differences between the blood quantum listed in Member Services’ database, the enrollment file and/or the Restoration Roll that were not supported by documentation.

In another time period examined, for the 1,314 people enrolled between July 1984 and January 1989, 31.9 percent – 419 -- did not have “definitive evidence” for blood quantum amount listed in the database and/or did not have support for blood quantum changes or differences that are present in the file and/or database. “They may also be the descendants of persons whose blood quantum amounts are in question,” the audit states.

In more recent times, among the 364 files examined between March 2008 and August 2012, 30.4 percent – 111 -- might have incorrect blood quantum listed because of discrepancies with an ancestor’s blood quantum.

“Throughout the review of the files, the applications had many errors,” the audit’s general findings state. “A major issue not discussed elsewhere was that the application at times failed to ask for information required by the ordinance of name and address, aliases, date of birth, name of parents, ancestral descendant, if under 18 or incompetent the name of person doing the application, and certification the information is true.”

The audit’s recommendation states that the “major areas of concern” identified within the enrollment files were deficient supporting documents relating to establishing linear descent and blood quantum amounts, as well as a general lack of supporting documentation.

“Due to the nature of enrollment and the dependency on the information of one generation affecting the enrollment of future generations, the critical nature of the documentation is exposed,” the audit states. “A missing document for an ancestor may lead to all of their descendants missing the critical link to the Tribe.”

Among Anuskewicz & McCabe’s recommendations was that blood quantum calculation errors within the line of descent be reviewed and recalculated to ensure all changes are supported and reflected in all of the files that are affected.


Audit reassessment

Individual enrollment issues are protected by confidentiality, but the enrollment audit’s findings do not identify individuals and are, instead, cumulative in nature.

Cracks in the quality of the 2012 enrollment audit started showing last year when Tribal Council member Michael Langley criticized it during a Sept. 26, 2018, Tribal Council meeting.

Langley, who was not on Tribal Council when the audit was authorized and performed, expressed concerns about what might have been missed in the auditing process in an effort to save money.

According to Thompson, one of the enrollment audit proposals initially received was priced at more than $300,000. During a second request for proposals process, four firms responded and were interviewed. In the end, Anuskewicz & McCabe was selected because it was 51 percent Indian-owned and less expensive at $90,000.

“When I personally look at the audit, the original bid for that audit came in at like $300,000 and some, and we didn’t like that price tag,” Langley said. “But if you think about it, to do a thorough audit of our enrollment files would take an incredible amount of hours. That is essentially what we are doing right now. We are auditing all of those enrollment files in a way that it should have been done.

“At that time, because of that high price tag, and I don’t think everybody recognizes this but they will tonight, we negotiated those audit procedures down, which means lessening the amount of work that was going to be involved. … And you have to think to yourself, ‘What was missed?’ If we’re going to change our whole audit process and change our procedures of what we’re going to look at, change the scope of what we’re going to look at … and now that I’m on council, we missed a lot. And our enrollment files are a mess. It’s going to take a big fix.”

In February 2018, the top two employees in the Member Services Department were removed from their positions and a subsequent press release from Tribal Council stated that enrollment audit findings were not properly inputted into Tribal member enrollment files.

Enrollment files have subsequently been re-examined by the Tribe’s Member Services staff members and Legal Department personnel in Room 204 of the Governance Center.

“Issues surrounding enrollment can be traced back to the earliest rolls and census records,” Thompson said. “Additional issues came to light just after the 2012 audit. Since then, Tribal Council as well as Legal and Enrollment staff have been working to understand the magnitude of these issues.”

Tribal Council issued a special edition of Tilixam Wawa in August that addressed enrollment and the Tribe’s enrollment records, as well as the enrollment audit.

In response, an advisory vote has been placed on the Sept. 7 Tribal Council ballot asking the membership its opinion on banning disenrollments unless they are based on fraud by the individual.

Disenrollments started in August 2013 when 13 Tribal members were initially disenrolled for violating the dual enrollment clause in the Tribal Constitution, meaning they were a member of another Native American Tribe when they enrolled in the Grand Ronde Tribe.

Few Tribal members can forget the divisiveness caused by the enrollment audit and the subsequent disenrollment proceedings, particularly those regarding descendants of Cascades Chief Tumulth, a signer of the Willamette Valley Treaty of 1855.

The Tumulth descendants were provisionally disenrolled in July 2014 pending the outcome of legal proceedings, which they finally won in August 2016 when the Tribal Court of Appeals ruled that the Tribe had waited too long to disenroll them. The Enrollment Board reinstated them as Tribal members in October 2016.

Chief Tumulth descendants were identified for disenrollment because of lineal descent issues -- they did not have an ancestor who appeared on an official roll or record of Tribal membership compiled by the federal government because Tumulth was executed by the U.S. Army before reaching the Grand Ronde Reservation. Tribal Council never made a decision if a treaty attains the status of an official roll or record of Tribal membership.

Tribal members wanting a copy of the enrollment audit should fill out a Public Records Request Form that is available at or at the Central Phones in the Governance Center. The completed form can be submitted to or dropped off at the Central Phones.

“Tribal members are still requesting copies of their files,” Thompson said. “The content of those files and whether or not they contained errors remains confidential.”