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Although the tribal grantees in this study encountered challenges, they developed transition strategies and implemented tribal TANF operations that ultimately succeeded. Important elements of these strategies were gradual transitions to tribal program operation, continuation of state involvement in program operations for an interim period, maintenance of good working relationships with state and local TANF agencies, and adjustment of policies and procedures as needed. Tribes used the flexibility provided under the Act to address a range of challenges related to limitations in resources and infrastructure, and to tailor their operations to tribal needs and values.
When DHHS approves a tribal TANF plan, it confirms the tribe's specification of when it will take responsibility for the TANF program, but the transition is often gradual rather than abrupt. The grantees in the study worked closely with the states to ensure a smooth transition, often involving an interim period of continued state involvement. For example, the Torres Martinez consortium's agreement with the state provided for a 90-day period for the transfer of clients to the tribal program. The Navajo Nation began the implementation phase in March 2002, with an anticipated completion in September 2002, including specific transition timetables for portions of the reservation in Arizona, New Mexico, and Utah.
Tribal grantees can also smooth the transition by making it incremental. Eight of the 10 study grantees developed an approach that allowed the tribe/consortium to take over the operation of program components gradually while the state continued to provide some services and to operate other program components. For example, a tribal grantee might begin by enrolling and serving new TANF participants while the state continues to serve the existing caseload, turning over a specified number of participants to the tribe each month or quarter. Grantees reported that phased transfer of cases from the state was especially valuable when the tribe had few resources for TANF planning and implementation. A delay of 3 to 8 months in transferring cases helped tribal grantees to recruit and train program staff and to identify and correct problems while serving a manageable caseload..
After implementing the tribal program, grantees may choose to contract with states or other service providers for selected TANF services or operations on a long-term basis. For example, the Mille Lacs tribe contracts with the state of Minnesota for cash payments to tribal TANF participants and uses the state TANF information system to produce data which the tribe uses in preparing quarterly reports as mandated by the Act. The Torres Martinez consortium, through an arrangement with Wells Fargo Bank, issues payments to TANF participants through debit card accounts.
For tribes that plan to operate all aspects of the TANF program, good working relationships with state and local TANF offices can be important for a smooth transition. The Port Gamble S'Klallam tribe met with the county TANF staff to develop a Memorandum of Understanding (MOU). The county TANF office assigned specific workers to help in transferring cases and, after the tribe negotiated an agreement with the state of Washington, helped to speed up Medicaid and Food Stamp Program (FSP) applications for tribal members.
After timetables and tribal/state responsibilities are clarified, tribes must develop policies and procedures for their TANF plan. The tribal director of TANF or human services (or assigned staff) usually prepares a policy and procedures manual, and then presents the TANF policies to the tribal government for approval. Sometimes, differences between tribal and state TANF policies require special accommodations. For example, the Winnebago tribe uses the state's system for issuing TANF payments, but the tribe's sanction policy differs from that of the state. The state's payment system was set up according to the state's policy, so it could not be used to issue payments to tribal TANF participants who had been sanctioned. This problem was resolved by using an alternate payment mechanism for those who have been sanctioned, while the state issues all other tribal TANF checks.
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To operate TANF successfully, tribes must address problems that arise during program implementation and operation. They may encounter caseloads that differ from the original estimates, infrastructure and systems inadequate to support program activities, staff recruitment and training needs, and barriers to coordination with other programs. The following sections highlight some challenges reported by tribes in this study and their responses to them.
In recent years, the number of TANF participants has been significantly lower than the number of AFDC recipients for most states (GAO-02-768, 2002). Five of the tribal grantees in this study had similar experiences, and two grantees (Mille Lacs and Winnebago) served roughly the expected number of families based on the 1994 AFDC estimates. However, for three tribal grantees (Lac du Flambeau, White Mountain Apache, and Tlingit and Haida), the number of TANF participants exceeded the number of tribal members receiving AFDC in 1994, as estimated by the state. Consequently, these tribal TANF programs lacked sufficient resources to implement their TANF plans fully (Table IV.1). Fortunately, the grantees were able to revise their TANF plans and rescue the program with assistance from DHHS and the state. For example, working with DHHS and the state of Arizona, the White Mountain Apache tribe changed the definition of its service population to include only members of its own tribe, whereas its original service population had included all American Indians residing in the service area. The state of Arizona agreed to serve American Indians other than White Mountain Apaches living on the reservation. In addition, through negotiation with the State and DHHS, the tribe was able to modify its TANF plan, changing the 1994 AFDC estimate from 633 to 770, reflecting the actual number of eligible tribal members applying for TANF benefits and resulting in a corresponding increase in funding.(1) The Tlingit and Haida negotiated similar revisions of their TANF plan, resulting in increased funding; in addition, Alaska appropriated a portion of its MOE funds to the consortium (and to three other grantees). According to tribal officials, without the changes in their TANF plan and associated additional funding, both White Mountain Apache and Tlingit and Haida would have been forced to retrocede the TANF program to the respective states.
| Grantee | Number of Assistance Units in TANF Plana | Mean Assistance Units Served/Montha | Contracted Services to State |
|---|---|---|---|
| Hopi | 206 | 160 | Yes |
| Lac du Flambeau | 20 | 50 | No |
| Mille Lacs | 130 | 130 | Yes |
| Navajo | 9,000 | 6,000 | Yes |
| Port Gamble | 125 | 40 | No |
| Red Cliff | 50 | 34 | No |
| Torres Martinez | 5,169 | 146 | Transitioning |
| White Mountain Apache | 633 | 715 | Yes |
| Winnebago | 87 | 90 | No |
| Tlingit/Haida | 200 | 350 | No |
| a TANF "assistance units" can range from one person as a "child-only" case, to a single parent with one or more children, to a two-parent family with one or more children. | |||
Three factors, alone or combined, seem to account for most of the overenrollment problem: (1) undercounts or low estimates of tribal members receiving AFDC in 1994, (2) population and socioeconomic changes since 1994, and (3) removal of barriers to program access. We have already discussed undercounts and low estimates of the 1994 AFDC counts. Even if the 1994 estimates are correct, more tribal members may seek enrollment, because unemployment and poverty may have increased from 1994 to the present, or some tribal members may have returned to the reservation. For example, some tribal members may return to the reservation as their time limit on the state TANF program approached. Alternatively, many tribal members who were eligible for AFDC in 1994 but could not participate because of lack of transportation or language-cultural barriers may apply to the tribal TANF program. Those tribes that reported an upward trend in TANF participants since they took over the TANF program attributed the increase to outreach efforts, the convenience of access to the program, and the cultural affinity of tribal members for the tribally operated program.
Two tribal TANF grantees, the Navajo Nation and the Torres Martinez consortium, were serving far fewer persons than projected based on estimates of 1994 AFDC participation, but perhaps only temporarily. These two grantees, which are among those with the largest TANF service populations, were in the process of opening TANF offices and enrolling participants when this study was conducted; this ongoing transition may have accounted in large part for the low tribal TANF participation observed at that time. When the study data were collected, the Navajo Nation had just begun to enroll new TANF participants, and Arizona, New Mexico, and Utah were continuing to provide TANF services to existing participants during a transition period. American Indians and Alaska Natives in the Torres Martinez service area, which includes urban, suburban, and rural areas (Los Angeles and Riverside counties) have the option of participating in the tribal or state TANF programs.(2) Torres Martinez was in the early stages of enrolling participants in its program when the study was conducted.
For tribal TANF operations to run smoothly, adequate office space, equipment, and computing and communications systems are critical. One respondent, noting the importance of adequate facilities to TANF operations, stated simply, "No place, no space, no services." Tribes sometimes find it difficult to create or allocate appropriate office space on the reservation for a TANF program. Space is needed for a waiting area, private interview rooms, staff offices, and meetings between businesses and prospective workers on the reservation. Although some reservations have empty buildings, the cost of converting them is often prohibitive. The Navajo Nation developed an innovative approach to financing the renovation of existing buildings and stimulating economic development at the same time. In addition to renovating office space in tribally-owned facilities, the tribe worked with a construction company owned by a tribal member to secure financing from a bank using leases from the tribe as collateral for a loan to finance the needed renovations. Using the loan funds, the construction company renovated a large, empty facility in the Shiprock community providing facilities for a fast food restaurant and other businesses as well as a satellite office for the TANF program.
Three grantees had difficulty securing enough space to manage a caseload that exceeded their enrollment projections. For example, the small Lac du Flambeau tribe needed to procure and deploy modular office facilities after enrolling more than twice the number of families it expected in its TANF program. When the study data were collected, the Lac du Flambeau TANF program was serving, on average, 50 families per month (rather than the 20 families anticipated in its TANF plan). Even at this small scale, enrollment beyond projection can be disruptive. Initially, the TANF program had been sharing office space with other tribal programs; however, as implementation of the program proceeded and the number of tribal members enrolled in TANF grew, the TANF program needed additional space to avoid disrupting other tribal programs. Since the building housing the TANF office had no more space to offer, the tribe deployed modular office facilities adjacent to the existing building.
Tribes find the lack of adequate computing/telecommunications systems particularly challenging. Much of Indian country lacks access to high-speed, high bandwidth landlines such as T-1, DSL, or ISDN. Often, cellular communication is unavailable on some, or all, of the reservation. The Navajo Nation has deployed a TANF information system using satellite-based telecommunications. Despite spending more than $1 million on this system, the Nation has encountered major problems. These include interfacing its system with that of the Wells Fargo Bank, which had been contracted to make cash payments to program participants through debit card accounts. The Torres Martinez tribal TANF program established a technology department and was building a network to serve its TANF program. The program plans to implement computer-assisted intake and related services at each TANF office in the two counties served (Los Angeles and Riverside) with program-wide data processed and stored at a central site. In order to increase the utility and value of the system, the consortium planned to make the system available to all tribal members and other tribal programs that wish to provide Internet access to computer-assisted training and education.
Because of limitations in their own information systems capacity and equipment, several tribes contracted with the states to operate tribal TANF information systems or obtained permission to use the state system on a permanent or transitional basis. These systems are used to record information on participants at enrollment through job placement and follow-up, including tracking participation in program activities, computing benefit amounts, and reporting to DHHS. Wisconsin has encouraged the Lac du Flambeau and Red Cliff, and Minnesota has encouraged the Mille Lacs, to use their state TANF information systems. These states have provided hardware at no cost or at a reduced cost, as well as software, technical assistance, and training in use of the state TANF information system. Two other grantees in the study used state TANF information systems — the Hopi and White Mountain Apache tribes subcontracted substantial portions of their TANF program to the state of Arizona and used its TANF information system.
Using state TANF information systems rather than developing their own can yield significant savings and efficiencies for tribal TANF programs, but the grantees in the study that did so experienced problems, particularly with respect to making required quarterly reports to DHHS. While the data elements and reporting format are similar for state and tribal TANF programs, tribal programs are not required to report some elements required of state programs (such as MOE, separate state programs), and some codes used by states (pertaining, for example, to waivers) are not used by tribal programs. Tribal grantees that used state TANF information systems (Lac du Flambeau, Red Cliff, and Mille Lacs) reported that the state system could not produce reports required by DHHS. Mille Lacs said that use of the state system facilitated their administration of Medicaid and Food Stamps (operated by contract with the state and a waiver from DHHS). Some tribal grantees that do not use state systems (Port Gamble, Navajo, and Torres Martinez) said that they developed their own information systems because, in their judgment, the state system could not meet their needs.
Tribes have recruitment and training challenges because their members have limited experience working in TANF programs. Tribal programs addressed this problem in several ways. They hired staff with experience working for TANF programs regardless of their tribal membership, obtained training from state TANF staff, trained new hires, and provided ongoing staff development to retain staff and enhance their capabilities.
State training for tribal workers can help develop the tribal TANF staff, but there are limitations. Most of the states worked closely with grantees, providing extensive, often free, training to grantee staff. For example, Washington State sent workers to Port Gamble to mentor the tribe's case managers. Some states, such as Washington and Wisconsin, open training for state TANF staff to tribal TANF staff. Study respondents indicated that often this training was useful. Sometimes, however, the training pertained to specific state procedures and was not relevant to the tribal program.
Another way to deal with the limited TANF-related work experience of tribal members is to employ nontribal members in the TANF program. Tribal officials said there were concerns at first about not hiring more tribal members, and about the possibility of resulting tensions. However, grantees in the study that employed nontribal members reported few problems. After the program was implemented, tribal members tended to feel that the TANF staff were doing a good job, and that the tribe, in general, and program participants in particular, were benefiting from the work of the TANF staff regardless of their tribal status or race/ethnicity.
Tribal members who have participated in the TANF and/or AFDC programs have experience with the needs of program participants and know which TANF services and operations are most valuable. Most of the grantees in this study recruited former TANF participants with the needed skills and desire to work in the program. Tribal officials indicated that former TANF recipients tended to be good employees — they were motivated to do a good job and to make the program successful, and they were models for what program participants can achieve.
Despite ongoing efforts to recruit and retain staff, some tribes (for example, Navajo Nation, Torres Martinez, and White Mountain Apache) reported difficulty retaining staff, especially in employment services. Staff leaving for other jobs accounted for about half the turnover. The other half resigned because of personal problems, such as the need to care for an ill relative or handle a family crisis. Some tribal officials said that former TANF participants seemed to have high turnover rates. Tribal officials said that former TANF participants and their families tend to have few alternatives in dealing with crises. A former TANF participant who has left the program and secured unsubsidized employment is often seen by family members as the best person to help solve critical family problems and to minimize the negative effects of a crisis. Consequently, family members often turn to the former TANF client for support. Sometimes, providing personal support forces the former TANF client to resign her position, which contributes to staff turnover.
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Moving TANF from state to tribal administration changes the way that TANF interacts with other programs run by both tribes and states. The change is likely to facilitate coordination between TANF and tribal programs such as Welfare-to-Work (WtW), workforce development, and social services. Some study informants said that incorporation of TANF into the 477 program further enhanced program coordination. However, moving TANF administration to the tribe/tribal consortium may complicate coordination between TANF and programs still administered by states.
Tribal operation of TANF increases opportunities for coordination between tribal TANF and other tribal programs. When a tribe takes over TANF, it opens one or more offices on the reservation. Often, the tribal TANF offices are in the same facilities as other tribal programs — this improves access for tribal members and makes it more feasible to have TANF and other program staff in close communication. In some tribes, several programs may even share staff, with one or more staff partially funded by TANF, WtW, and NEW. Tribal operation of TANF may increase awareness of needs that can be met from multiple program resources. For example, Mille Lacs staff, recognizing tribal TANF clients' needs for child care and transportation, have planned cross-program initiatives to address them. They are writing an application for a grant to support reservation-based licensed child care — coordinating with Head Start and with the tribal housing program to make sure homes that provide child care comply with building and safety codes. They are also working with a local car dealership on a car ownership program; the dealership will buy used cars at auction, repair them, and sell them to tribal members at little or no profit. Port Gamble TANF clients are encouraged to participate in a two-month budgeting and credit management course offered by the tribal housing authority to help families clean up their credit so they can purchase a manufactured house. Those who finish the training receive a housing bonus that they do not have to pay back.
Opportunities for coordination between tribal TANF and other tribal programs can be amplified if TANF is included in a 477 program. For example, 477 grantees can use a portion of their 477 plan resources to promote economic development which, in turn, can address what is probably the most serious threat to the success of tribal TANF programs — the lack of unsubsidized jobs in much of Indian country. Section 1103(e) of Public Law 106-568 (which amends Public Law 102-477) allows 477 tribes to use 10 to 25 percent of their total 477 plan resources, including TANF (if it is part of the 477 plan) on economic development, depending on their unemployment rate. One tribal grantee noted that program coordination and continuity of service was facilitated by the pooling of funds in a 477 program because agencies no longer have to refer clients from one program to another if one has exhausted its funds. Two tribes reported that the integration of funds and services in their 477 programs is a key ingredient in their training, education, support services, job development and placement, and other services for TANF participants. At Mille Lacs, for example, the 477 program, including TANF, is in the tribe's education division, which includes the workforce center and adult education and community technology grants. Program staff said that the co-location of TANF with tribal education programs and the integration of TANF and other programs under 477 helped to coordinate training of TANF participants and other tribal members. Despite the program's flexibility, there are clear limits to the discretion allowed 477 grantees — Section 14(a)(1) of Public Law 102-477 provides, "program funds shall be administered in such a manner as to allow for a determination that funds from specific programs (or an amount equal to the amount attracted from each program) are spent on allowable activities authorized under such program."
Despite potential advantages in service delivery, some tribes that incorporated TANF into a 477 program reported disappointment with the degree to which management integration was achieved. Four of the study grantees operate a 477 program that includes TANF, and they are enthusiastic about how the program works, but officials of some of these tribes reported problems related to funding and how it is distributed. All federal funding that is part of a 477 program is usually made available to tribes through the BIA; however, from late FY 2001 to late FY 2002, pending the signing of an updated interagency memorandum of understanding (MOU) between DHHS, the Department of Labor, and the Interior Department, TANF funds were disbursed directly by DHHS to tribal grantees. The "477 tribes" in the study said that the disbursement of TANF funds separate from other 477 funds created administrative problems. One tribe found that the TANF program was in effect a drain on resources from other programs once their resources were pooled, because the integrated program ended up serving many more people after the tribe began operating TANF.
Enthusiasm for the service integration possible under 477 is also dampened by concerns the 477 tribes voiced about TANF reporting requirements. Under the 477 program, tribes and tribal consortia annually submit a single set of reports (statistical, narrative, financial status, and audit) for the integrated program to the BIA, which forwards the reports to other federal departments and agencies that fund programs incorporated into the 477 program. However, the Act requires that tribal (and state) grantees submit quarterly TANF reports. Thus, incorporating TANF into 477 does not streamline reporting. Whether for these or other reasons, the majority of tribal TANF programs do not incorporate TANF into the 477 program — 26 out of 38 current grantees do not administer TANF in 477. DHHS staff reported that of 6 plans currently under review, 8 plans pending submission, and 18 tribes and consortia deliberating whether to develop plans, none envision including TANF in 477 programs.
Which tribal programs are coordinated varies across the grantees in this study. For two of the four study grantees that participated in the 477 program (Mille Lacs and Port Gamble), TANF was integrated into the 477 program along with other programs such as WtW, NEW, WIA, and vocational education. For the other study grantees, TANF tended to be closely coordinated with the WtW program. Since tribes' WtW funding is substantially smaller than their TANF funding, WtW funds are often used to supplement services provided under TANF. For example, in one case WtW funds are used to pay for a portion of the salary for one or more staff employed by the tribal employment and training or workforce development program. WtW funds are also used to support child care, special training, and job-readiness activities for TANF recipients.
Tribal operation of TANF opens possibilities for improved coordination between TANF and other tribal programs, but it can also complicate links with programs still administered by the state. Coordination between a tribal TANF program and the state-run Food Stamp Program, Medicaid, and State Children's Health Insurance Program (SCHIP) can actually become more difficult than when TANF was also operated by the state. Most of the tribal grantees had to negotiate and work with the state(s) to develop procedures to facilitate the enrollment of tribal TANF participants in the three state-run programs. Although developing effective procedures was not easy, tribal officials acknowledged that access to TANF, FSP, SCHIP and, to a lesser degree, Medicaid, was also a problem before the tribe took over TANF. Two of the grantees in the study (Lac du Flambeau and Red Cliff) avoid the divide between TANF and the three other programs by administering all of them for their tribal members, under an agreement with Wisconsin and a federal waiver.
However, coordination and agreements between tribal TANF and state programs can help deal with a variety of problems experienced by tribal members. Members of the Port Gamble S'Klallam tribe had to travel 30 miles to the county service office (CSO) to enroll in FSP, SCHIP, and Medicaid. The tribe argued that federal law does not require state staff to interview applicants in person for these programs. With support from the governor's office, an agreement was reached that allows tribal members to complete applications at the tribal TANF office, which faxes them to the CSO for processing. State staff come to the reservation weekly to conduct face-to-face interviews as needed. Electronic Benefit Transfer (EBT) cards are mailed to recipients, unless they wish to go to the CSO to get them more quickly, in which case the tribe provides either transportation or a voucher for it. The agreement also provides for special attention at the CSO for tribal members when they do seek assistance there, so they are not "lost in the shuffle," the county assigned one worker at the CSO to be the FSP/Medicaid liaison for tribal TANF clients. Other tribes have achieved similar accommodations. For example, Torres Martinez tribal TANF staff help clients deal with the county social services offices for FSP and Medicaid, and they transport clients to county offices when necessary. Los Angeles County Department of Public Social Services staff are on-site at the tribal TANF offices at scheduled times to process clients' FSP and Medicaid applications and to provide other assistance.
The tribal grantees in this study sought to improve services to tribal members by adapting the services to fit the circumstances of the tribe. The grantees tried to improve access to services, adjust services and work requirements to the particular needs of tribal TANF clients, and reinforce tribal values of personal and family responsibility despite limited opportunities for unsubsidized employment. All the tribal grantees in the study opened at least one program office on the reservation, and three grantees opened several offices. The Navajo Nation has opened eight TANF offices (one central and seven satellite offices) and will open eight more satellites. The Mille Lacs tribe operates two offices. The Torres Martinez consortium, because it serves American Indians and Alaska Natives residing in Los Angeles and Riverside counties, has established offices throughout these counties. Most of the tribal grantees said that they conduct home visits and provide services outside their offices at libraries, schools, and other places easily accessible to program participants. Each of the tribal TANF offices in the study is staffed by tribal members and others who live on the reservation; are familiar with the social, economic, and cultural conditions on the reservation; and, when needed, speak the tribal language. The Navajo Nation uses laptop computers to conduct TANF intake in many locations, and the data are then uploaded to a central server.
Tribes have also used the discretion that comes with operating their own TANF program to define benefit levels and issuance procedures that serve program goals. Two of the grantees (Navajo Nation and Torres Martinez) pay higher benefits than the state TANF program. The Torres Martinez consortium differentiates benefit levels for its urban and rural clients, paying the former $100 more than the county TANF program and the latter $75 more. The consortium also makes higher payments than counties for foster care TANF cases. The consortium encourages adults to serve as foster parents to related children to minimize placement of Indian children in non-Indian families. One tribe (Red Cliff) pays lower benefits than the state because the families can get no-cost tribal housing and because of some concern that the tribe's TANF funds are insufficient to serve all tribal members eligible for TANF. Port Gamble S'Klallam issues benefit checks twice a month, because this is more convenient for clients and it mirrors the pay schedule of many employers. State officials interviewed for the study were generally supportive of the goals and policies of tribal TANF programs, indicating that they recognized that tribes generally understand the circumstances and needs of their members better than county, state, or federal agencies. Despite this general support, some state officials interviewed said that tribes sometimes do not fully appreciate the efforts of state programs, and that tribal policies and procedures, when they diverge from those of the state, are likely to evolve closer to those of the state as tribal programs gain experience.
The broader range of acceptable work activity and other participation requirements in tribal TANF programs is reflected in tribal procedures for approving and monitoring client compliance. The case manager is generally responsible for determining whether an activity meets the tribe's requirements. The Port Gamble S'Klallam tribe requires biweekly time sheets to report participation (at the time of the site visit, the tribe was planning to move to weekly time sheets). To monitor Port Gamble's school attendance requirement for children age 16 and under, schools submit attendance information monthly on a form the TANF office provides by fax.
Tribal values and circumstances are also reflected in decisions to create incentives for positive behavior and sanctions to discourage negative behavior. For example, the Torres Martinez consortium gives cash grants to TANF participants to defray some of the cost of getting married. Although the cash grant does not require a traditional marriage ceremony, the tribe encourages one. The consortium gives a cash bonus to families when their children earn good grades in school. When clients are sanctioned, the consortium issues vouchers for food, utilities, and shelter instead of cash benefits. Port Gamble's sanction policy starts with a warning, then loss of the adult grant. If the client is still not compliant after 60 days, a full family sanction is implemented. Since the program's stated goal is to protect children, clients know that, when a full family sanction occurs, they will be referred to the Indian child welfare program and will have to show that they can still provide for their child. Sometimes the community gets involved. For example, tribal elders have supported the agency and have encouraged noncooperative family members to comply with agency requirements.
Many tribal TANF grantees have found it difficult to submit complete quarterly reports to DHHS as required by Sections 411 and 412 of Title IV-A of the Social Security Act as amended. At the time the study data were collected, tribal TANF grantees submitted their quarterly reports to DHHS for review and approval (see Appendix 2). Grantees used an information system provided by DHHS, state TANF reporting systems, systems they developed independently, or commercially available systems. Most grantees noted difficulties in preparing the mandated reports, whichever system they used.
DHHS provided free computer software (Families in Tribal TANF Programs, or FTANF) designed to make the TANF reporting process easier. However, most grantees found the software cumbersome to use and of little help. Some of the tribal TANF programs have agreed to be included in state TANF information systems instead. As reported earlier in this chapter, 5 of the 10 grantees in this study, including the 2 that contract operations to the state, use the state data systems. However, DHHS found the reports generated by the state systems to be incomplete for the tribal grantees. Other grantees developed their own information systems (Navajo, Torres Martinez) or purchased a tribal TANF information system developed by a private-sector vendor (Port Gamble). These grantees, too, had problems in preparing quarterly TANF reports acceptable to DHHS. The grantees indicated that they needed to maintain two databases (one for benefit issuance and one for FTANF reporting) or had to hand-key information into the FTANF system.
Reporting difficulties and information system incompatibilities are not unique to tribes, but the burden is greater for tribes, for several reasons. First, unlike the FTANF system, states are not limited to one software system or reporting format when providing their data to DHHS. Second, because tribal governments are small relative to states, many tribes do not have separate administrative/programming staffs or information system structure to redesign reporting systems. Finally, a tribe that wishes to provide medical and food support, as well as TANF, must use both the state system and FTANF.
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1. Under the Act, funding of both state and tribal TANF grants is based on 1994 AFDC counts rather than the numbers of eligible persons requesting TANF services. The increase in funding of the tribe's TANF grant, in effect, represented a transfer of federal TANF funds from the state to the tribe.
2. When the study data were being collected, Torres Martinez was negotiating with Orange and San Bernadino counties to expand its service area to those counties. Because counties in the state of California administer the TANF program, Torres Martinez was negotiating agreements with these counties before submitting a modification of its TANF plan to DHHS.
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