Operating TANF: Opportunities and Challenges for Tribes and Tribal Consortia

V. Lessons Learned and Implications

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Contents

1. Lessons for Tribes and Tribal Consortia
   1. Deciding Whether to Operate TANF
   2. Developing a TANF Plan
   3. Implementing and Operating the TANF Program
2. Implications for Federal and State Consideration
   1. Federal Policies and Procedures
   2. State Policies and Procedures

Endnote

Pride of ownership was evident in the tribal TANF programs — it was expressed by program staff and participants, staff in other programs, and tribal officials. The TANF offices, shown with pride, were decorated with tribal cultural motifs and artwork expressing aspirations of personal responsibility and self-improvement for one's self, family, and tribe. Despite heavy workloads, staff welcomed the opportunity to show what they were accomplishing. These results are similar to those found in the first phase of the Welfare-to-Work evaluation (Hillabrant et al. 2001).

Consistent with tribal goals of self-sufficiency, tribal TANF officials strongly support moving tribal members from welfare to work. Tribes have adopted strategies that include making TANF participants ready for employment (when such employment becomes available), by improving their educational attainment, job skills, and work experience, and by eliminating barriers to employment, such as a lack of child care, transportation difficulties, and untreated alcohol/substance abuse. Significant challenges remain, however. No matter how well a tribal TANF program is run, it cannot place participants in unsubsidized employment that does not exist. The lack of unsubsidized employment on reservations is the greatest threat to the success of tribal TANF programs. One of the greatest concerns is that the 60-month lifetime limit on TANF benefits will pass before enough jobs become available in Indian country. If the needed economic development fails to take place, tribes will probably lack the resources to serve their most needy members.

While the grantees in the study had some disagreements or problems with the state concerning aspects of planning, implementation, and operation of the tribal TANF program, they also reported mutually satisfactory resolution of most of these disagreements, as well as positive contributions from the states. Furthermore, the tribal grantees in this study were able to tailor their programs to improve access to tribal members and address the unique economic and cultural circumstances in Indian country.

The experiences of the 10 tribal grantees in the study suggest lessons that other tribes and consortia, state and federal officials, and others interested in tribal TANF programs may be able to learn from. Based on the study findings, implications are offered for federal, state, and tribal consideration.

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A. Lessons for Tribes and Tribal Consortia

1. Deciding Whether to Operate TANF

The tribes in this study made it clear that no single answer is right for every tribe. The lessons noted here will help each tribe arrive at the best solutions for its circumstances. In making the decision, tribes may want to consider the following principles:

• Consultation with Many Stakeholders. Ongoing consultation with tribal agencies and community members may help to ensure broad community support for the decision on whether to operate a tribal TANF program. Through such consultation, the tribal council, tribal program staff, TANF participants, and tribal members in general can provide input and come to support the decision. Such consultation may be especially valuable to, and challenging for, tribal consortia. Because of the complexity of the decision, the tribe or consortium should expect the process to take six months or longer.
• Needs Assessment for TANF Planning and Implementation. Because of the size and scope of the TANF program, tribes need to conduct an especially thorough needs assessment; determining the resources that are available and the resources needed to successfully implement and operate the program may be critical to the development of a sound TANF plan. Consultation with the state, DHHS, and tribes operating successful TANF programs can make this task easier.
• Input and Guidance from Experienced Tribal TANF Grantees. Learning from the experiences of other tribes can help new grantees avoid mistakes and develop solutions to problems in planning, implementing, and operating TANF. Tribal planners can benefit from the advice of experienced tribal TANF grantees. Some of these grantees have formed regional organizations to help other tribes as they decide whether to take over the program, develop a plan, and implement tribal TANF.

2. Developing a TANF Plan

Good estimates that help to ensure adequate funding, clear goals for tribal TANF, and planning that includes broad input from other tribal programs facilitate the production of a TANF plan that serves as a blueprint for smooth operations.

• Valid 1994 AFDC Counts (or Estimates). Because the 1994 AFDC counts determine the amount of the tribal TANF grant, planners should validate state counts or estimates of the number of tribal members participating in AFDC in 1994. The tribe or consortium may wish to develop independent estimates. Such estimates can be based on data from other programs with low-income eligibility requirements, such as Head Start, WIC, and BIA social services. In some circumstances, it may be useful to conduct a survey to identify tribal members who received AFDC in 1994. It may be valuable to try to determine or estimate the number of tribal members who were eligible but did not participate in AFDC as well as the number eligible for TANF but not participating because of access barriers, such as lack of reliable transportation. While the tribal TANF plan must be based on the number of members receiving AFDC in 1994, estimates of the number of persons eligible for and likely to apply for services provided by the tribal TANF program can be valuable for planning purposes.
• Developing a Strategy for Negotiations with the State. Goals of tribal grantees in negotiating with the state could be to ensure adequate funding in the TANF grant, ensure access to resources and information, and preserve and enhance tribal sovereignty. The negotiation strategy might include efforts to (1) determine the number of tribal members participating in AFDC in 1994, (2) obtain a portion of state MOE funds, (3) obtain access to and use the state TANF information system, (4) obtain excess state computers and other resources, (5) obtain training and technical assistance from the state TANF program, (6) maintain and enhance tribal sovereignty, and (7) minimize conflict and maximize mutual goals and objectives shared with the state. Tribal grantees in the study suggested that tribal negotiators should focus on TANF issues and avoid discussion of matters over which state staff have little influence, such as water rights, treaty rights, and taxation.
• Obtaining Input and Participation of Relevant Tribal Programs in the TANF Planning Process. Tribal programs that affect the TANF program or are affected by it include social services programs, workforce development, education, facilities and maintenance, strategic planning, and economic/ business development. As part of TANF planning, the responsibilities and relations between TANF and these programs should be articulated.
• Sharing or Renovating Existing Facilities for the TANF Program. Several of the grantees in the study renovated existing facilities to use as tribal TANF offices, or used space available in facilities housing related tribal programs. Compared to new facility construction, such approaches can reduce the costs of implementing the TANF program. In some circumstances, facility renovation can be used to promote business and economic development; tribally-owned or Indian-owned businesses can play a role in managing or performing renovations, and tribes can identify businesses that are likely to thrive when co-located in the same facility as or adjacent to the TANF program.
• Federal or State Funding for TANF Planning and Implementation. The Act does not provide funds for TANF planning, and implementation costs must be funded from administrative expenses. Tribes can apply for funding to support TANF planning and implementation from federal agencies such as ANA and DOL (WtW if available). Some states have either provided funding to tribes and tribal consortia for TANF planning, from existing appropriations (generally discretionary funds provided by the executive branch) or from new appropriations made by the legislature.
• Using Economic Development Provisions in 477 Programs. Tribes participating in the 477 program can use up to 25 percent of their total 477 plan resources, including TANF, for economic development. If successful, such development efforts could produce jobs needed by TANF participants to move from welfare to work.

3. Implementing and Operating the TANF Program

Tribes offered practical suggestions for easing the transition to tribal TANF. These lessons address challenges tribes face, including limitations in staff experience operating TANF, in their information systems infrastructure, and in economic development/job creation.

• Participant Recruitment Dilemmas. One of the advantages of operation of TANF by tribal grantees is that these grantees are able to remove barriers to participation in the program by tribal members through better advertisement of the availability of the program and more effective enrollment activities. However, successful removal of access barriers may result in the enrollment of more participants than planned. On the other hand, tribal grantees with a large service area and a heterogeneous service population may find enrollment to be slow and below planned levels.
• Training by State TANF Programs. Study grantees said that state TANF programs provided valuable training to tribal staff, usually at no charge. Tribal officials said that shadowing staff at state/county facilities helped tribal TANF staff learn approaches, techniques, and strategies the state uses. Even when the tribal program decided to do things differently, the experience of shadowing state staff helped to inform the approaches the tribal program adopted.
• Subcontracting Some TANF Operations to the State During a Transition Period. Taking over operation of all aspects of a TANF program on a specified date can be especially difficult for tribes or tribal consortia. It can be much easier for a tribal grantee to take over specific program operations gradually, while the state continues to provide the remaining operations and activities.
• Use of the State TANF Information System. If the state TANF information system is compatible with the needs of a tribal program, the tribal grantee can significantly reduce expenditures and efforts in developing a new information system. As an alternative, some tribal grantees have found systems developed by private-sector commercial firms to be useful.
• Creation of a Reserve Fund for Emergencies. Tribal grantees can maintain part of their TANF funds as a reserve to help contend with unexpected circumstances, such as natural disasters. The negative effects of disasters are worsened when a grantee lacks such a reserve fund.
• Coordination with Other Tribal Programs, State and Federal Programs, and Private-Sector Firms and Organizations. Tribal grantees in the study reported working with federal departments and agencies (and associated programs) that promote business and economic development in Indian country. TANF job development efforts can be enhanced through coordination with other tribal, state, or federal programs and agencies such as WtW, WIA (Department of Labor), NEW, SEDS (DHHS), Vocational Education and Vocational Rehabilitation (Education Department), the 477, Loan Guarantee and other BIA programs, the Small Business Administration, and rural development (Agriculture).⁽¹⁾

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B. Implications for Federal and State Consideration

1. Federal Policies and Procedures

The study results suggest some aspects of federal policy or procedures that can impinge on tribal TANF operations. Some might affect how readily tribal TANF participants can get access to other federal programs, and some can influence tribes' decisions to take over operation of TANF.

• Use of State TANF Information and Reporting Systems by Tribal Grantees. To help tribal TANF grantees produce the required reports, DHHS developed and disseminated the FTANF reporting system for tribal grantees. Some tribal grantees found the system to be inflexible, however, in part because it cannot easily export or import data to and from other systems. To reduce costs and promote efficiency, some tribal grantees have adopted or attempted to adopt state TANF information systems to track and report services provided and participant accomplishments. Study grantees said that they were unable to produce required quarterly TANF reports using the state systems. A review of ways to facilitate the use of state TANF information systems by tribal grantees and identification of technical assistance needed by tribal grantees may be warranted.
• Coordination of Tribal TANF Programs and State-Administered Programs. States administer the Medicaid, SCHIP, and Food Stamp programs used by many tribal TANF participants. Working with states and tribes, DHHS could develop ways to facilitate the enrollment and participation of tribal TANF participants in these programs, possibly through the waiver process, as in the state of Wisconsin.
• Enhanced Technical Assistance to Tribes for TANF Planning and Implementation. DHHS has provided extensive technical assistance to tribes and tribal consortia in developing TANF plans and implementing TANF programs. The tribes and consortia that were among the first to implement the TANF program benefited from this assistance, but the next waves of tribes and tribal consortia developing and implementing TANF programs may have even greater needs for guidance. Tribes that have experience operating TANF may be able to help those starting out, but providing that help will strain tribal resources. Providing funding to tribal grantees that have successfully implemented TANF programs to mentor others may be worthy of consideration.

2. State Policies and Procedures

States can help tribes successfully operate tribal TANF through training, provision of services for a transition period, sharing of state information systems and equipment, and ensuring of access to other state services.

• Provision of Training and Technical Assistance to Tribal Staff. Almost every state in the study provided extensive training and technical assistance to tribes taking over the TANF program. This was critical to the success of the tribal programs, and new tribal TANF grantees will need similar help, as indicated above.
• Providing All, or a Portion of, TANF Services and Activities During a Transition Period. Almost all the states in the study continued to provide all, or a portion of, TANF activities and services to the tribal service population during a transition period. Without this gradual transition, the burden on tribal grantees can be insurmountable.
• Use of the State TANF Information System by Tribal Grantees. Some states have allowed tribal programs to use the state TANF information system in the same way counties do. While not every tribal grantee can use the state information system, many can do so and thus avoid the need to develop or procure another system and its associated costs.
• Donation of Excess Computing and Telecommunications Equipment to Tribal TANF Programs. Some states, as they upgraded their systems, donated excess computing and telecommunications equipment to tribal TANF programs. Such donations can help tribes overcome the problem of having to improve the infrastructure needed to operate the TANF program.
• Provision of State MOE Funds to Tribal TANF Grantees. The Act does not require states to transfer any of their MOE funds to tribal TANF programs; however, some states have transferred all or a portion of these funds to tribal TANF grantees. Without state MOE funds, participants in many tribal TANF programs will have only a part of the resources available to participants when the state operated the program.
• Ensuring Access of Tribal Members to All State TANF Services. Some tribal members elect to use the state TANF program, and others may live outside the service area of a tribal program. While serving tribal members in remote locations with few employment opportunities represents a difficult challenge to state TANF programs, it is important that states apply comparable expectations and offer comparable services to them. American Indians and Alaska Natives (regardless of their tribal affiliation or the location of their residence in the state) are citizens of the state and are entitled to equal access to all state programs.

Endnote

1.  As part of the evaluation of the WtW program in Indian country, a paper addressing tribal economic and business development activities in relation to welfare reform is being prepared and is scheduled for completion in the spring of 2003.

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