In the past several years the modern repatriation movement has accelerated compliance with the Native American Graves Protection and Repatriation Act (NAGPRA; 25 U.S.C. 3001 et seq.), but the return of Native American Ancestral (human) remains and cultural items are not the movement’s only result (Fine-Dare Reference Fine-Dare2002; National Congress of American Indians 2024). Repatriation can have a transformative effect on institutions and associated academic disciplines (Bradley Reference Bradley, Blusteain, Wheeler, Darnell and Murray2018; Nash and Colwell Reference Nash and Colwell2020; Preucel Reference Preucel2011). One area of concern the movement has highlighted is the continued lack of Indigenous perspectives in curating collections containing cultural items and sensitive information (Jaffe et al. Reference Jaffe, Hudetz, Ngu and Brewer2023). The duty of care provisions in the 2024 NAGPRA regulations (43 CFR Part 10) serve as an important first step for many institutions in recognizing and responding to stewardship responsibilities. The required changes to institutional policies and practice have clear potential to create a long-term ripple effect, underscoring the authority of Tribal stakeholders. Less apparent is how institutions can effectively navigate the new provisions while grappling with other ethical considerations outside of the scope of the law.
This article is a reflective case study and a “start from scratch” guide on how to approach policy- and practice-making for Indigenous collections at non-Native institutions, such as federal and state agencies, universities, and museums. The need for self-assessment and reporting of successes and failures is demonstrated in the growing number of Indigenous curation-specific topics in collections management guides and working groups (IARC Guidelines for Collaboration, Indigenous Collections Care Working Group, SAA Native American Protocols Forum Working Group, and School for Advanced Research [2023]), the emergence of an Indigenous-oriented content management system (https://mukurtu.org/), and thematic conference sessions (Society for American Archaeology 2024a). We aim to summarize what NAGPRA requires regarding collections management, address ethical considerations outside of the requirements of the law, and problematize challenges that institutions face. Drawing on our experience as the NAGPRA staff at the Alabama Department of Archives and History (ADAH), we offer guiding principles and practical advice for Indigenous collections care that can result in deep institutional change. These experiences are not posited as a “one-size-fits-all” solution or the only pathway to success—and we acknowledge that our work is not complete. Indigenous collections care is an ongoing practice based in continuous collaboration and transparency with Tribal Nations.
NAGPRA Requirements and Ethical Questions: What Problems Do Institutions Face?
Histories and overviews of cultural resource preservation laws (Highet Reference Highet2005; King Reference King2013), the historical relationship of Native Americans and the US government (Echo-Hawk and Echo-Hawk Reference Echo-Hawk and Echo-Hawk1994), and the legislative and social history of NAGPRA and the broader repatriation movement (Chari and Lavallee Reference Sangita and Lavallee2013; Fine-Dare Reference Fine-Dare2002) are well summarized in other works and will not receive treatment here. Instead, this section will cover what is required by NAGPRA regarding collections management and data stewardship, raise ethical issues not addressed by the law, and identify challenges that institutions face.
The 2024 NAGPRA regulations include two areas that pertain to collections management and data stewardship. The most notable are the new duty of care provisions (10.1[d]):
These regulations require a museum, Federal agency, or DHHL [Department of Hawaiian Homelands] to care for, safeguard, and preserve any human remains or cultural items in its custody or in its possession or control. A museum, Federal agency, or DHHL must:
(1) Consult with lineal descendants, Indian Tribes, or Native Hawaiian organizations on the appropriate storage, treatment, or handling of human remains or cultural items;
(2) Make a reasonable and good-faith effort to incorporate and accommodate the Native American traditional knowledge of lineal descendants, Indian Tribes or Native Hawaiian organizations in the storage, treatment, or handling of human remains or cultural items; and
(3) Obtain free, prior, and informed consent from lineal descendants, Indian Tribes, or Native Hawaiian organizations prior to allowing any exhibition of, access to, or research on human remains or cultural items. Research includes, but is not limited to, any study, analysis, examination, or other means of acquiring or preserving information about human remains or cultural items. Research of any kind on human remains or cultural items is not required by the Act or these regulations.
In addition to the regulations, the National NAGPRA Program office has published a duty of care FAQ (https://www.nps.gov/subjects/nagpra/policy.htm) that further explains the requirements. These provisions provide protections that cover the baseline of culturally sensitive curation of Ancestral remains and items covered by the law. They mandate a negotiated process mirroring consultation (43 CFR 10.2 “Consultation or consult”).
The decolonizing ethos and practices outlined in the duty of care provisions are not particularly groundbreaking. Both emerged in scholarly literature around the time NAGPRA was passed (Carter Reference Carter1995; Riding In Reference Riding In1996) and have been influential in shaping methodologies and approaches such as co-curation (Shannon et al. Reference Shannon, Atalay, Jisgang, Herewini, Hollinger, Horwood, Preucel, Shelton and Tapsell2017; Ward et al. Reference Ward, Arterberry, Aguilar, Patton, Cain, Jones and Taylor2024), collaborative exhibit design (Phillips Reference Phillips, Peers and Brown2003), descendant/community-based research (Atalay Reference Atalay2012; Silliman Reference Silliman2008), and descendant community–informed institutional integrity (Thompson et al. Reference Thompson, Thompson, Garland, Butler, deBeaubien, Panther and Hunt2023). In 2023, a few months prior to the publishing of a new Final Rule, NAGPRA practitioners from across the country gathered at the Association on American Indian Affairs’ 9th Annual Repatriation Conference to receive training on a draft of the revised regulations. A clear consensus among the group was that the law had finally caught up to “best practice” standards, a sentiment also expressed in scholarly discourse (Colwell Reference Colwell2014). Despite this, after the regulations came into effect, the media exploded with stories of well-known institutions “scrambling” to cover exhibits populated with NAGPRA cultural items (Jacobs and Small Reference Jacobs and Small2024).
It seems that while “best practice” guidelines for care and display of Indigenous cultural items exist, these ethical and practical frameworks are either unknown to many institutions or have not been applied on a large scale. While there are probably as many reasons for this as there are institutions, we suggest that two core problems may underlie many of the ongoing delays in implementing culturally sensitive collections management:
• the need for more education of decision-makers aimed at bolstering institutional capacity and commitment to NAGPRA compliance and culturally sensitive care
• the need for a practical process to aid collections managers in identifying and applying culturally sensitive collections care
The second area in the regulations pertaining to collections management addresses data stewardship, directing institutions to “protect sensitive information, as identified by the requestor, from disclosure to the general public to the extent consistent with applicable law” (43 CFR 1F0.9[g](1)[iii] and 43 CFR 10.10[h](1)[iii]). However, the regulations themselves are not an ultimate source for protection of sensitive information, a problem acknowledged in the 2024 NAGPRA Review Committee’s Annual Report to Congress as a “significant barrier to repatriation” with implications that are counter to the spirit of the law (Native American Graves Protection and Repatriation Review Committee 2024). In many instances, existing information (data) about cultural items subject to the law can be accessed through the Freedom of Information Act or other forms of public records requests, unless laws such as the Archaeological Resources Protection Act (ARPA) or the National Historic Preservation Act (NHPA) apply or appropriate institutional policies are in place.
Finally, the revised regulations have rekindled and intensified debate around practices and policies of stewarding Indigenous collections and data, mandated by law or not. Issues surrounding repatriation are polarizing (Angeletti Reference Angeletti2022; Guillory-Lacy and Visintainer Reference Guillory-Lacy and Visintainer2024; Rooney Reference Rooney2022), partially because of repatriation’s inseparable connection to a human rights movement and activism (Robenalt et al. Reference Robenalt, Farrell-Banks and Markham2022). This connection to social justice issues can result in the fear that changes in ethics and practice are a reaction to the swinging social pendulum, raising concerns and creating roadblocks and confusion for institutions attempting to identify appropriate actions for moving forward.
To summarize, we propose that some of the larger challenges faced by institutions trying to implement culturally sensitive collections care are (1) building institutional capacity and commitment, (2) identifying and applying policies and procedures that implement culturally sensitive care and comply with NAGPRA’s duty of care provisions, (3) understanding the protections and guidance for stewarding documentation and data containing sensitive information, and (4) navigating polarizing views and opinions regarding NAGPRA and culturally sensitive collections practices and policies. In the next section we will use experiences at the ADAH to propose approaches and solutions to these issues.
ADAH: Successes, Failures, and Pathways Forward
In 1901 the Alabama state legislature created the ADAH based on recommendations by Thomas McAdory Owen, a lawyer who served as the department’s first director. The ADAH was the first publicly funded, independently administered state historical agency in the United States and serves as the state’s government records repository, private collections library, and history museum (Alabama Department of Archives and History 2025). One of the department’s early primary objectives was to collect and preserve Alabama’s historical artifacts and documents for the benefit of the public, including Native American material (Waselkov and Sheldon Reference Waselkov, Craig and Sheldon1987). To achieve this goal, Owen helped found the Alabama Anthropological Society (AAS), an amateur excavators club, in 1909. The goals of the AAS included researching and documenting Native American sites, primarily in central Alabama, and securing a collection of artifacts for exhibition and research at the ADAH.
Establishing Foundations of Institutional Capacity and Commitment
The ADAH made NAGPRA compliance efforts in the 1990s but unknowingly did not fully meet the agency’s legal obligations. In 2018, inquiries from multiple federally recognized Tribes led staff to reevaluate the ADAH’s standing. Access to online educational resources and training that did not exist in the 1990s helped ADAH staff determine that the department’s previous actions did not satisfy the law. After determining that the agency needed to resume compliance work, ADAH staff provided an in-depth briefing on NAGPRA to its governing board of trustees. The report conveyed NAGPRA’s origins and requirements, provided a detailed description of ADAH collections history and previous NAGPRA work, and outlined the broad steps of an action plan and timeline for work. This briefing established staff’s understanding of the law, outlined the resources necessary for building capacity to complete compliance goals, and set a precedent of transparency and trust between staff and the board—a critical element moving forward.
As a result of the briefing, the board adopted a list of repatriation-positive desired outcomes:
1. legal compliance with all aspects of NAGPRA
2. enhanced appreciation for Native peoples’ perspectives on repatriation
3. sustained partnerships with Tribal Nations
4. improved understanding of the ADAH collections
5. enhanced resources for ongoing educational and research use
6. reputation for transparent, respectful stewardship of Native American materials
7. capacity to serve as a resource for other Alabama institutions with obligations under NAGPRA
At the same time, the agency also approved the creation of one full-time NAGPRA compliance staff position and an additional part-time position. These are both concrete examples of project investment at the highest institutional level and stand as a formal expression of the ADAH’s understanding that its ethical responsibilities extend beyond the letter of the law. Education on NAGPRA and repatriation issues that accompany regular project updates to the board and administrative leadership builds and bolsters institutional capacity and support to achieve project goals.
In the years since 2018, the particulars of our action plan and project timeline have changed. Building on the ethos set by the desired outcomes, and with support from an informed governing board and administrators, we have been able to shift gears and adjust our approach as necessary. This has been particularly applicable to our collections management strategies, which have developed significantly over the years because of consultation with Tribal Nations. If we were devising an action plan today, we would suggest keeping it broad and simple to accommodate change over time. We would also suggest using the National NAGPRA Program’s “Steps to Repatriation” as a starting framework and initiating consultation with Native Nations early in the process.
Identifying and Applying Policies and Procedures
Initially, the ADAH’s action plan prioritized collections updates to prepare for NAGPRA consultation and demonstrate our commitment to becoming trustworthy stewards. The archaeological collections had been catalogued and properly stored as part of a National Science Foundation grant project in the 1980s (Waselkov and Sheldon Reference Waselkov, Craig and Sheldon1987), but not much had been done since then to update or maintain the collections. Work beginning in late 2018 included enhancements to storage spaces such as new and additional storage containers (archival-quality bags, boxes, trays, ethafoam, and locking museum cabinets), solar/UV-blocking window shades, and new environmental monitoring devices. Work on cultural materials focused on assessing the collection and improving intellectual control. Staff sought to bring the collections up to current standards of best care, to reconnect artifacts with provenance and provenience information to facilitate implementing NAGPRA, and to conduct a re-inventory.
At the time, our primary means of communication with our Tribal partners (Table 1) was through biannual letters detailing our progress and outlining next steps. Tribal representatives were invited to provide feedback, but the ADAH did not request explicit consent for any work conducted on the collection. As staff began to directly interact and develop relationships with Tribal partners and participate in the NAGPRA Community of Practice, it became apparent that our “best practices” were not necessarily the preferences of Tribes. These new understandings led us to halt work that gathered more data than necessary to implement NAGPRA and prohibited new photography of funerary objects (except at the request of Tribal Nations). We also reconfigured storage spaces to keep certain materials separate from others and limited access to the collections.
Table 1. The ADAH’s Primary Consultation Partners.
The ADAH’s understanding of the stewardship expectations and preferences of Tribal partners has developed over time. Two integral steps for receiving guidance on appropriate care included familiarizing Tribal partners with the collection and developing mutual respect. While we had some success discussing collections by sharing digital data and photos, we found that in-person visits are irreplaceable for information-sharing. Acknowledging and respecting Tribal knowledge greatly enhances and nuances (and, in some instances, corrects) available information and interpretation of items and collections as a whole. As others have described (Shannon Reference Shannon2017), collections visits with Tribal partners can quickly turn the notion of who the “experts” in the room are on its head. These interactions can help museum staff see objects, collections, and cultures from a different perspective, and gain a new understanding of how to provide and implement respectful care.
Today, some of the ADAH’s early collections management steps, taken with good intentions, would not be staff’s selected course of action. However, by prioritizing communication and transparency with Tribal partners, and by respecting Tribal knowledge and guidance, the ADAH met the requirements of the 2024 duty of care before the provisions became law.
Ancestral Remains
Sometimes, culturally sensitive stewardship can include actions that are counter to existing policies or traditionally agreed upon museum practices. For example, the ADAH has sought and accepted control of Ancestral remains to facilitate repatriation. Until the 1980s, the ADAH held Ancestral remains as part of its archaeological collection. In 1986, lacking facilities and staff trained to steward the remains, the agency transferred them to the University of Alabama (UA), where they were curated by staff with osteological expertise. Unfortunately, because they were separated from documentation held at the ADAH, they were listed on a NAGPRA inventory submitted by the university in the 1990s as culturally unidentifiable.
As a result of NAGPRA collections management efforts beginning in 2018, staff determined that the Ancestors likely could be culturally affiliated using information available at the agency. In consultation with Tribal partners, it was determined that the most ethical and expedient course of action was to reunite the Ancestors with their belongings for consultation and repatriation at the ADAH. In preparation for the transfer, we consulted with Tribal representatives and worked with UA staff to appropriately rehouse the Ancestors. We also created a separate space and collections management plan specifically designed to steward Ancestors with their belongings while they await repatriation. We were honored to have a representative of the Muscogee (Creek) Nation present to accompany the Ancestors to the ADAH, alongside agency and university staff.
As we worked to reunite Ancestors and belongings long associated with the ADAH, we were approached by a private citizen with a potential donation of Ancestral remains and cultural items (removal of these individuals and items predated applicable burial laws). Although the potential donation was not associated with the ADAH and would require additional compliance work under NAGPRA, we recognized that we were in a unique position to facilitate repatriation. Our greatest concern was that these Ancestors and their belongings would remain in private hands or be disposed of if we did not act. Staff brought this situation to the attention of our Tribal partners and assured them that we intended to accept the materials for the sole purpose of repatriation via NAGPRA. Tribal partners and the donor agreed that the ADAH facilitating repatriation was the best outcome for the situation at hand.
We have since accepted two additional private donations of Ancestral remains and funerary objects for the express purpose of repatriation. This approach highlights the importance of consultation and the diversity of Tribal perspectives. While our Tribal partners have been appreciative of our efforts to remove Ancestral remains from the private sector, we have also encountered perspectives held by other Tribal Nations that found our actions, made in consultation, to be highly controversial. This affirms the notion that there are few explicitly prescriptive actions that institutions should take when approaching decision-making surrounding cultural items—with perhaps the only exception being that institutions should consult to determine appropriate pathways forward.
Research and Access: Museum Collections
As a state agency, the ADAH’s research policies have always centered on transparency and providing collections access for scholars and the public. Access is defined here as the ability to examine or obtain information pertaining to museum or archival holdings for professional or personal research. Keeping this in mind, and realizing that our understanding of the sensitive nature of collections subject to NAGPRA would continue to develop with time, we saw the need to reevaluate access policies and prioritize compliance tasks. For guidance, the ADAH looked to the NAGPRA Communities of Practice, along with standards and ethics set by professional organizations.
For example, the American Alliance of Museums Code of Ethics for Museums states that “the unique and special nature of human remains and funerary and sacred objects is recognized as the basis of all decisions concerning such collections” (American Alliance of Museums 2000). Similar guidance has been provided by the Principles of Archaeological Ethics of the Society for American Archaeology (2024b) and other professional resources (e.g., American Anthropological Association 2024; Register of Professional Archaeologists 2025). While specific practical advice varies, restrictions and temporary research moratoriums are becoming common across institutions working toward compliance with NAGPRA (e.g., Harvard University 2023; University of Georgia 2021; Universities of Wisconsin 2024). Considering those precedents, along with the knowledge that the majority of the ADAH’s collections were amassed by a twentieth-century amateur group that targeted burials, staff and administration decided to restrict access to the bulk of its archaeological collections.
Our hope is that, as consultation proceeds, the ADAH will be able to develop research and access policies with Tribal Nations to provide pathways for research to resume. Access policies that encourage or require communication with Tribal representatives are also becoming more common (National Science Foundation 2024; University of Georgia 2021). The duty of care provisions have made Tribal consent for research on NAGPRA cultural items a requirement. Whether this will lead to normalizing similar requirements for non-NAGPRA Indigenous collections remains to be determined. Tension exists between Native Nations and some academic researchers regarding access, research, and representation of cultural collections (Rooney Reference Rooney2022). These issues are complex, and the further refinement of best practice in the coming years will depend on a great deal of additional work in considering stakeholders, perspectives, and pathways.
Research and Access: Museum Collections Documentation and Archival Collections
In the short term, navigating the ethical considerations pertaining to accessing museum collections subject to NAGPRA was relatively straightforward. However, a stewardship pathway for sensitive records and data has been less clear. Like many institutions, the ADAH’s core responsibilities are to preserve records and provide access for the benefit of the public. Culturally sensitive information challenges collections managers to negotiate our responsibilities to various stakeholder groups and requires the development of guidelines and policies regarding appropriate access. There are a few terms and distinctions that are important to understand for the sake of clarifying this section.
First, there are two types of information that will be discussed: archaeological site data and culturally sensitive information. Archaeological site data characterize an archaeological site or its location and are generally considered to be inappropriate for unvetted public access, as they can be used to loot or damage sites. Culturally sensitive information is determined by Tribal representatives on a case-by-case basis and may include NAGPRA-related information, such as photos of or information regarding cultural items, but can also include traditional knowledge, oral histories, or descriptions of ceremonies, songs, et cetera. Determining what qualifies as sensitive information must be done in consultation with culturally affiliated Tribal Nations (see NAGPRA regulations [43 CFR 10.9(g)[1](iii)] and the “Protocols for Native American Archival Materials” [Northern Arizona University 2006] for more information on “sensitive information”).
It is also important to understand the distinction that we are drawing between collections management data and documentation, which are internal documents related specifically to museum objects, and archival material, held as part of the ADAH’s archival collections and typically open to the public for research. First, we address collections management data and documentation. For archaeological collections these often include catalog information (descriptions of objects and sometimes photographs or drawings), provenance documentation (or donor/acquisition information), archaeological provenience information (spatial data and specifics about archaeological sites), and research/analysis data and results. These physical or digital records typically include site locations and characterize archaeological assemblages at a level of detail that is not appropriate for unfettered public access, as they can pose a threat to site preservation.
Effectively stewarding sensitive data is not always clear-cut. NAGPRA’s duty of care restrictions on access and research apply only to NAGPRA cultural items themselves and not to any existing associated data or to compliance documents submitted to the Department of the Interior. This can be particularly difficult to navigate when collections documentation is so robust that access to records, including photographs, site and burial descriptions, and catalog records, is effectively a proxy for access to the Ancestral remains or items themselves. Understanding existing institutional policies on internal records and applicable state and federal law is important for setting appropriate levels of access. These are also imperative considerations for determining the types of information that should be included (or purposefully excluded) in internal records and NAGPRA documents. For existing precedence and policy, institutions should look to current professional codes of ethics and applicable law (such as the ARPA and NHPA; https://www.nps.gov/subjects/historicpreservation/laws.htm) aimed at preserving and protecting archaeological sites, data, and the interests of descendant communities.
Turning now to archival collections, access to records at the ADAH is generally available to any member of the public who visits the agency’s research room or submits an online request for research assistance. At the outset of our NAGPRA compliance work, we advocated for restrictions on only archival materials that contain information pertaining specifically to the ADAH’s archaeological holdings, as these records were known to contain sensitive information regarding archaeological sites and funerary contexts. Over time, staff recognized that additional archival holdings contained a wealth of information regarding southeastern Indigenous communities and regional archaeology.
To develop an interim access policy for potentially sensitive, or “flagged” collections, we relied heavily on resources endorsed by the Society of American Archivists, including “Protocols for Native American Archival Materials” (Northern Arizona University 2006) and a draft of Repatriation Meets the Protocols Workbook (Posadas et al. Reference Posadas, Hummel-Colla, Gaeta, Fodor and Posas2021). Access requests on flagged collections by scholars, Tribal Nations, or the public are evaluated on a case-by-case basis. The requested materials are reviewed for a baseline of potentially sensitive information before access is granted. This allows research to continue while protecting data from being accessed inappropriately. The primary goal is to protect sites from potential looting, and to redact or deny access to data explicitly concerning burials and funerary objects/customs, until other sensitive topics can be identified through consultation. This interim policy exists to provide a stopgap that allows access to continue while prioritizing NAGPRA compliance.
Challenges also exist in carrying out appropriate sharing of information. In preparation for NAGPRA consultation, we realized we needed to relay large amounts of information clearly and succinctly to our Tribal partners, who were not familiar with our collections. To accomplish this, we developed a format to summarize collections information, state lines of evidence used to suggest cultural affiliations, document evidence brought forward by Tribal partners, and record the outcomes of consultation. The result is a comprehensive and color-coded consultation workbook designed to provide information and summarize the results of consultation. Tribal responses to the workbook have largely been positive. Representatives have commented on its effectiveness as a communication tool, its clarity, and its demonstration of our agency’s desire to be transparent. We turned the workbook format into a template and have provided it as a resource to other NAGPRA practitioners via NAGPRA Communities of Practice (https://www.nagpracommunityofpractice.com/). In doing this, we hope to free institutions from having to create a format for consultation materials from scratch and encourage transparency in sharing collections information with Tribes.
Changing Views
Before 2022 the ADAH’s exhibitions largely utilized funerary objects for interpreting Native history. Not long after we embarked on compliance work in 2018, we recognized that the museum displays would need to be redesigned to rely on non-funerary objects or other interpretive strategies. However, we did not realize the unintentional disrespect and harm the exhibits communicated to Indigenous communities. When Tribal partners raised concerns about the ongoing use of funerary objects, we organized a meeting to provide an opportunity for Tribal perspectives to be formally heard and responded to. We also used this opportunity to express our institutional desire to begin consultation on redesign efforts and expressed our commitment to include southeastern Tribal voices and perspectives into the new exhibits. The conversation resulted in new understanding of Tribal perspectives, which ultimately led the ADAH to close one gallery and obstruct the view of objects in another. In this instance, the administration’s participation in consultation and willingness to hear Tribal voices spurred our agency to change our approach.
To address changes to the exhibits, we formally announced the closure and obstructions in a press release that included an FAQ aimed at engaging with the media and the public on NAGPRA issues and the problematic history of the archaeological collection at the ADAH (Alabama Department of Archives and History 2022). Agency Director Steve Murray acknowledged our past, while emphasizing our commitment to interpreting the Native histories of our state and underscoring our responsibilities to stakeholder communities:
Our exhibitions have long sought to strengthen public awareness of the richness of Native American culture, and they have done so successfully. Now, we recognize that the origins of most of our archaeological collections were deeply problematic and disrespectful of Alabama’s Indigenous community. We can do better while maintaining our dedication to growing public awareness, and we will [Alabama Department of Archives and History 2022].
In addition to engaging with the media and the public, ADAH staff have also worked to be a resource for other Alabama institutions with NAGPRA obligations and to students interested in repatriation work. Our efforts include founding and facilitating the Alabama NAGPRA Practitioners. Like larger Communities of Practice, the goals of the group are to help NAGPRA practitioners connect with one another and to provide a means of pooling intellectual and procedural resources. We have also provided one-on-one guidance for other professionals who are navigating compliance issues. We are committed to the next generation of professionals, engaging with students via guest lectures, participation in professional societies, and through running a NAGPRA summer internship program aimed at providing real-life experience with compliance work. We see these collective efforts as ways in which we influence the next generation of NAGPRA practitioners, archaeologists, and museum professionals to be more conscious and inclusive stewards of cultural collections.
Long-Term Policy Development
Many of our collections management strategies have been created “as needed” to serve as interim policies while we focused on compliance efforts. While not the norm for a state agency, this model has been guided by the desire to hear and include Tribal voices and has ensured that policies and practices can continue to be flexible to accommodate and incorporate culturally sensitive care. These interim practices and policies are rooted in and performed largely as outcomes of collaborative efforts between Tribal officials and ADAH staff. However, the goal of ongoing consultation should be formalized policy that will persist past NAGPRA compliance work and beyond the present generation of agency staff.
None of us are paving these roads alone—other institutions have been developing long-term Indigenous collections care and access policies for NAGPRA and non-NAGPRA collections. Via the NAGPRA Communities of Practice, practitioners across the United States have utilized each other’s policies as frameworks and, when necessary, cited each other as precedent. We developed many of our policies by pooling information from various Communities of Practice and co-opting a framework that serves the specific needs of our institution and the preferences of our Tribal partners.
Takeaways
In short, we have identified some common problems in developing and implementing culturally sensitive collections care and have discussed pathways and approaches that have been successful at the ADAH. To summarize, we offer the following takeaways for institutions aiming to meet, as well as go beyond, what is required by NAGPRA.
First, codifying a repatriation-positive ethos at a high institutional level encourages not only capacity and commitment to meet the requirements of NAGPRA but also a desire to build and maintain productive and collaborative relationships with Tribal Nations. The ADAH board of trustees’ desired outcomes provide a foundation for staff to continue to educate themselves, the broader administration, and the board itself. This has given our institution the ability to be flexible and change our practices as we better understand Tribal perspectives—a critical element of sensitive collections care.
Second, as collections managers we need to interrogate standard curation practices and be open to Tribal perspectives to identify new practices and protocols. We also need to acknowledge that plans, policies, and practice will change and develop as we build trust with Tribal partners over time through transparent and reciprocal information-sharing.
Third, because NAGPRA and repatriation can be polarizing topics, we need to do our part to engage and educate all stakeholders, including the media, the public, other professionals, and students. Part of engaging in and normalizing this work is advocating for it.
To close, the NAGPRA 2024 duty of care provisions have mandated a baseline of culturally sensitive collections care for NAGPRA collections. However, institutions need to address the need for Tribally informed stewardship policies and practices for Native collections as a whole—not just those subject to NAGPRA. We argue that prioritizing the integration of Indigenous perspectives into collections care can effectively change the culture of our workplaces and our disciplines at large.
Acknowledgments
The authors would like to thank the ADAH’s Tribal partners who are representatives of the following federally recognized Tribal Nations: Absentee-Shawnee Tribe of Indians of Oklahoma, Alabama-Coushatta Tribe of Texas, Alabama-Quassarte Tribal Town, Cherokee Nation, Chickasaw Nation, Choctaw Nation of Oklahoma, Coushatta Tribe of Louisiana, Eastern Band of Cherokee Indians, Eastern Shawnee Tribe of Oklahoma, Jena Band of Choctaw Indians, Kialegee Tribal Town, Miccosukee Tribe of Indians, Mississippi Band of Choctaw Indians, Muscogee (Creek) Nation, Poarch Band of Creek Indians, Seminole Nation of Oklahoma, Seminole Tribe of Florida, Shawnee Tribe, and Thlopthlocco Tribal Town. Their contributions to this work are immeasurable. The authors would also like to thank the ADAH staff and board of trustees for all their support. This article was developed as a result of the authors’ participation in the 89th Annual Meeting of the Society for American Archaeology in New Orleans, Louisiana. The authors are grateful to all participants and sponsors for the conference’s Day of NAGPRA, entitled “In Search of Solutions: Exploring Pathways to Repatriation for NAGPRA Practitioners.” The authors would also like to thank and acknowledge the National Endowment for the Humanities and the National Parks Service for awards that have helped fund NAGPRA compliance efforts at the ADAH. On a personal note, the authors would like to thank their spouses and families for their love and encouragement. Special thanks are also due to Kellie’s long-time best friend, Jessica Craft, who translated the abstract and keywords into Spanish.
Funding Statement
The authors received no financial support for the authorship of this article.
Data Availability Statement
Visit the ADAH’s website for information pertaining to the agency’s NAGPRA program or to contact staff if interested in information pertaining to materials developed for NAGPRA consultation.
Competing Interests
There are no competing interests to the best of the authors’ knowledge.
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