# Frequently Asked Questions ## expand\_more Information about the Peabody’s history and current implementation of NAGPRA is described this [Harvard Gazette article](https://news.harvard.edu/gazette/story/2021/03/peabody-museums-repatriation-efforts-encounter-complications/) with Professor Philip Deloria, Leverett Saltonstall Professor of History and Chair of the Museum’s [NAGPRA Advisory Committee](/peabody-museum-nagpra-advisory-committee). We also invite you to listen to a podcast interview with Professor Deloria produced by the Harvard Museums of Science & Culture on the importance of NAGPRA and ongoing work at the Peabody. Read the [transcript](https://websites.harvard.edu/hmsc/2021/07/14/reflections-on-repatriation-with-philip-deloria%EF%BF%BC/). ## NAGPRA Open all sections Close all sections ### What is covered by NAGPRA? How can I find out more about NAGPRA? expand\_more NAGPRA requires the Peabody Museum and other museums to repatriate Native American human remains, funerary objects, objects of cultural patrimony, and sacred objects. The statute, along with subsequent administrative regulations, sets forth a detailed administrative process that museums must follow, including the inventorying of relevant holdings, communications and consultations with Indian Tribes, publication of notices in the Federal Register, and eventual transfer of human remains and cultural items to lineal descendants or Tribal Nations. Details of the statute, regulations and process is available at [National NAGPRA](https://www.nps.gov/subjects/nagpra/index.htm), National Park Service, U.S. Department of the Interior. To learn more about NAGPRA please visit National NAGPRA’s [training website page](https://www.nps.gov/subjects/nagpra/training.htm) and their [Frequently Asked Questions website page](https://www.nps.gov/subjects/nagpra/frequently-asked-questions.htm). ### Why does the museum have such large collections from the United States? expand\_more Most of the collections arrived at the museum during the late nineteenth and early twentieth centuries through archaeologists, academics, and others, who sought to understand “America’s past” through large-scale excavations. Some of these efforts were supported by the Federal government, and the [Antiquities Act of 1906](https://www.nps.gov/subjects/archeology/antiquities-act.htm) specifically directed that universities and public museums were the repositories for these collections. Harvard was at the center of American archaeology and among the most frequent recipients of collecting permits at that time. Therefore, the collection grew with the growth of anthropology, an academic discipline. For more information, please see [NAGPRA at the Peabody](/nagpra-peabody). ### Does the museum allow research on collections under NAGPRA? expand\_more Research involving collections under NAGPRA is governed by the 2024 [updated regulations](https://www.federalregister.gov/documents/2023/12/13/2023-27040/native-american-graves-protection-and-repatriation-act-systematic-processes-for-disposition-or) for the implementation of NAGPRA which include duty of care requirements that require the free, prior, and informed consent of authorized Tribal representatives before allowing any exhibition of, access to, and research on ancestors, funerary items, and cultural items. The Museum had already introduced a research policy requiring consent in 2021, with the goal of encouraging knowledge generation in a manner founded on respect for, and in partnership with, descendant communities. ### How do you know how many ancestors there are in the collection? expand\_more Under NAGPRA, the number of ancestors is described by the term “minimum number of individuals” which is estimated using catalog records in the museum’s database. Determining the actual number of individuals can be challenging as different skeletal elements from the same individual may have been assigned different catalog numbers in the past. This is particularly true for individuals from complex archaeological contexts. An explanation of definitions used in the NAGPRA legislation can be found on the [National Park Service NAGPRA Glossary](https://www.nps.gov/subjects/nagpra/glossary.htm#lindes). ### What has been repatriated? expand\_more The Museum’s Federal Register Notices can be found on our [Published Notices](https://peabody.harvard.edu/nagpra-federal-notices) page. As of January 1, 2026, the Museum has published 328 Federal Register Notices and repatriated 5,465 ancestors to Tribal Nations. To date, more than 250 Tribal Nations have completed NAGPRA repatriations at the Peabody Museum. In 2024 and in agreement with Tribal guidance, the Museum began reporting funerary and cultural items in “lots” rather than as individual items. One “lot” of items in a Notice can include many thousands of individual items, for example, a repatriation was reported as fewer than 40 lots representing more than 10,000 items. ### What is the Peabody's decision-making process for NAGPRA? expand\_more The Harvard Corporation has delegated decision-making for NAGPRA to the Peabody Museum director. The [NAGPRA Advisory Committee](/peabody-museum-nagpra-advisory-committee) provides critical guidance to the director on all aspects of NAGPRA implementation. ### How long does it take to make a decision for a NAGPRA repatriation? expand\_more Each NAGPRA request is distinct and the time to effect repatriation through the NAGPRA process varies widely. The foundation of the NAGPRA process is respectful consultation, and staff aim to be responsive and sensitive to Tribal timelines and priorities. ### What is a Federal Register Notice? expand\_more The Federal Register is published daily by the National Archives and Records Administration and is the “official newspaper” of the U.S. Federal Government. When a repository determines the appropriate lineal descendant or Tribal Nation culturally affiliated to the ancestors or cultural items, a [Federal Register Notice](http://www.federalregister.gov) is published. Ancestors and associated funerary belongings are published in a Notice of Inventory Completion, while unassociated funerary belongings, sacred objects, and objects of cultural patrimony are published in a Notice of Intent to Repatriate. In some cases, a correction notice will be published to update information provided in the initial notice. Publication in the Federal Register is required under NAGPRA and provides an opportunity to publicly announce a repatriation decision. An explanation of definitions used in the NAGPRA legislation can be found on [National Park Service NAGPRA Glossary](https://www.nps.gov/subjects/nagpra/glossary.htm#lindes). ### What is the Museum doing to facilitate expeditious repatriation under NAGPRA? expand\_more The Museum has hired new staff, more than doubling the number of people focused on implementing NAGPRA and now has one of the largest departments dedicated to NAGPRA in the country. The Museum has significantly reduced or stopped other activities so that we can proactively move forward with NAGPRA implementation. Our commitment centers on Tribal consultation and follows the process outlined in the NAGPRA regulations. The Museum is currently consulting with more than 200 Tribal Nations. ### What is the Museum’s duty of care responsibility? expand\_more The NAGPRA regulations include duty of care responsibilities that require the Museum to care for, safeguard, and preserve ancestors, funerary belongings, and cultural items. The Museum consults with Tribal Nations and makes a reasonable and good faith effort to incorporate and accommodate Native American traditional knowledge in these activities. Free, prior, and informed consent is required before we allow any exhibition of, access to, and research on ancestors, funerary items, and cultural items that are or could be under NAGPRA. In line with the Peabody’s broader commitment to the [ethical stewardship](https://peabody.harvard.edu/ethical-stewardship) of all the holdings in our care, the Museum had policies already in place that were aligned with and, in some cases, go beyond current regulatory requirements. ### Does the Museum return cultural items to Tribal Nations outside of NAGPRA? expand\_more Yes. For more information on the Peabody’s broader repatriation policies, see [International and Domestic Returns Beyond NAGPRA](https://peabody.harvard.edu/international-and-domestic-returns). ### Does the Museum help support Tribes with the financial costs of NAGPRA? expand\_more Yes. Harvard University provides travel funding for two Tribal representatives to travel to the Museum to facilitate the physical return of ancestors and their belongings. The funding generally includes transportation, hotel accommodations for up to three nights in Cambridge, and meals for direct round-trip travel. More details can be found on the [Repatriation Visits](https://peabody.harvard.edu/repatriation-visits) web page. We recognize that Tribes face many barriers to the reburial of ancestors and hope that providing these funds will help lessen the burden. ### What happens to repatriated items after a notice is published? expand\_more Once the notice period of 30 days has ended, if no other claims have been made, the Peabody will transfer control of the items to the intended tribe(s), regardless of whether physical transfer is possible at that time. Peabody staff will continue to care for the items according to the wishes of the tribe(s) until they can be physically repatriated. ### What is a correction notice? expand\_more If certain facts in a published Federal Register notice change prior to the repatriation or transfer of the human remains or cultural items, the museum must draft a correction (or “amendment”) notice. Amendment notices are used to change: - the number of human remains, - the number of associated funerary objects, - the number of other cultural items, or - the cultural affiliation or aboriginal land determination. ### How do I contact the Peabody? expand\_more For NAGPRA related questions, please email - this inbox is closely monitored by our NAGPRA team daily. Meet the team doing this work on [Getting Started](/nagpra-gettingstarted). ## Glossary The language used throughout this glossary reflects the direct legal terminology laid out in the Native American Graves Protection and Repatriation Act of 1990 and its subsequent regulations. We acknowledge that some terminology employed by this legislation is contested and harmful to individuals and communities. We engage with this terminology and the associated legal definitions below not as an act of intentional harm but to increase accessibility in understanding the intricacies of the law. Open all sections Close all sections ### Native American Graves Protection and Repatriation Act (NAGPRA) expand\_more NAGPRA requires the Peabody Museum and other museums to repatriate culturally affiliated Native American human remains, funerary objects, objects of cultural patrimony, and sacred objects. The statute, along with subsequent administrative regulations, sets forth a detailed administrative process that museums must follow, including the inventorying of relevant holdings, communications and consultations with tribal nations, [publication of notices in the Federal Register](/nagpra-federal-notices), and eventual transfer of human remains and cultural items to tribal nations. Details of the statute, regulations and process is available at [National NAGPRA](https://www.nps.gov/subjects/nagpra/index.htm), National Park Service, U.S. Department of the Interior. ### Repatriation expand\_more In NAGPRA (25 USC 3005 and 43 CFR 10.10), the term repatriation means return of possession or control of Native American cultural items to lineal descendants, culturally affiliated Indian Tribes, and Native Hawaiian organizations. ### Returns expand\_more Since terms including “repatriation,” may have very specific, sometimes legal, meanings we use the more generic term “return” throughout the website to cover all circumstances. ### Associated funerary objects expand\_more Objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later, and both the human remains and associated funerary objects are presently in the possession or control of a museum or Federal agency, except that other items exclusively made for burial purposes or to contain human remains shall be considered as associated funerary objects. \[25 USC 3001 (3)(A)\] ### Unassociated funerary objects expand\_more Objects that, as a part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later, where the remains are not in the possession or control of the Federal agency or museum and the objects can be identified by a preponderance of the evidence as related to specific individuals or families or to known human remains or, by a preponderance of the evidence, as having been removed from a specific burial site of an individual culturally affiliated with a particular Indian tribe. \[25 USC 3001 (3)(B)\] Those funerary objects for which the human remains with which they were placed intentionally are not in the possession or control of a museum or Federal agency. \[43 CFR 10.2 (d)(2)(ii)\] ### Disposition expand\_more As used at 25 USC 3002 and 43 CFR Subpart B, the term refers to the return of cultural items excavated or inadvertently discovered on Federal or tribal lands after November 16, 1990, to lineal descendants, Indian Tribes, and Native Hawaiian organizations. The term disposition is also used at 25 USC 3006 (c)(5) with respect to the Review Committee's charge to recommend specific actions for developing a process for the disposition of culturally unidentifiable human remains. ### Sacred objects expand\_more Specific ceremonial objects which are needed by traditional Native American religious leaders for the practice of traditional Native American religions by their present day adherents. \[25 USC 3001 (3)(C)\] ### Objects of cultural patrimony expand\_more An object having ongoing historical, traditional, or cultural importance central to the Native American group or culture itself, rather than property owned by an individual Native American, and which, therefore, cannot be alienated, appropriated, or conveyed by any individual regardless of whether or not the individual is a member of the Indian tribe or Native Hawaiian organization and such object shall have been considered inalienable by such Native American group at the time the object was separated from such group. \[25 USC 3001 (3)(D)\] ### Minimum number of individuals (MNI) expand\_more The phrase “minimum number of individuals” is determined using catalog records in a museum database. For archaeological collections in particular, this counting method tends to overestimate the actual number of originating individuals, as different skeletal elements from the same individual may have different catalog numbers. However, the term is widely used for its consistency in approach including in NAGPRA inventories submitted to the Department of the Interior. ### Notice of Inventory Completion expand\_more A Notice of Inventory Completion is published in the Federal Register when a museum or Federal agency has made a determination of cultural affiliation for human remains and associated funerary objects, or has determined it will transfer control of culturally unidentified human remains and associated funerary objects. Such notice is required pursuant to 25 USC 3003 (d), 43 CFR 10.9 (e), 43 CFR 10.11(d), and 43 CFR 10.13. The National NAGPRA program is responsible for publishing notices of inventory completion on behalf of museums and Federal agencies. ### Notice of Intent to Repatriate expand\_more A Notice of Intent to Repatriate is published in the Federal Register when a museum or Federal agency receives, reviews, and accepts a claim by a tribe for sacred objects, unassociated funerary objects, or objects of cultural patrimony. Such notice is required pursuant to 43 CFR 10.8 (f). The National NAGPRA program is responsible for publishing notices of intent to repatriate on behalf of museums and Federal agencies. For other terminology related to the Native American Graves Protection and Repatriation Act, see the following: [NAGPRA Glossary](https://www.nps.gov/subjects/nagpra/glossary.htm), National Park Service.