The National Evaluation of the Welfare-to-Work Grants Program, Final Report:

Appendix A:
Summary of the WtW Tribal Study

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Contents

1. Evaluation of Tribal WtW Grants Programs (Hillabrant and Rhoades 2000; Hillabrant, Rhoades, Pindus, and Trutko 2001)
2. Evaluation of tribal TANF programs (Hillabrant, Rhoades, and Pindus 2003)
3. Analysis of Economic Development in Indian Country (Hillabrant, Earp, Rhoades, and Pindus, 2004)

Endnotes

In enacting PRWORA and the BBA,^(1),(2) Congress made special provisions to help American Indian tribes move their members from welfare to work. This legislation authorized five new programs: Tribal TANF, Indian and Native American Welfare-to-Work, Native Employment Works, Tribal Child Care, and Tribal Child Support Enforcement. These programs gave tribal governments new latitude to combine funds from different sources to promote employment and to design certain aspects of the programs to meet their unique needs and circumstances. In addition to the core evaluation of the WtW Grants Program, the BBA called for a study of WtW initiatives undertaken by tribes and tribal organizations. This tribal study comprised the following features:

• A Focus on the Implementation Experience. Given the diversity of circumstances and cultures across the 561 federally recognized tribes, rigorous statistical evaluations of program impacts were infeasible. Instead, the study emphasized developing a clear understanding of program designs, implementation experiences, promising approaches, and lessons learned. The tribal study employed intensive site visits and telephone interviews in three waves of data collection conducted from 1999 to 2003. Each wave included at least 10 sites; the first focused on tribal WtW grantees, the second on tribal TANF grantees, and the third on Indian tribes and Alaska Native Regional corporations. While efforts were made to obtain diversity in such factors as geographic location, population size, and level of unemployment in each of the three study samples, the study results should not be considered representative of every tribe and Alaska Native village.
• Input from a Tribal Working Group. An advisory group with expertise in employment and training programs and welfare reform in Indian country helped to identify potential methodological problems and develop solutions, select sites for the implementation study, and guide the dissemination of results.
• Two-Way Involvement of Tribal Leaders at Study Sites. The study team sought and obtained the approval of relevant tribal authorities for all site visits. Site-specific findings were circulated in draft to the participating tribes, tribal consortia, and Alaska Native Regional corporations for comment before they were included in the study reports.
• Focused Topical Papers. The tribal study had three components, with separate reports produced for each. The first was an evaluation of tribal WtW grants programs for which two reports were prepared. The first report, written for tribal leaders and managers, described preliminary findings of tribal experiences in designing and implementing WtW programs (Hillabrant and Rhoades 2000). The second report on the first component was written for a wide audience and assessed the implementation and operation of tribal WtW programs, describing social, cultural, economic, programmatic, and other factors affecting their operation (Hillabrant, Pindus, Rhoades, and Trutko 2001). The second component of the tribal study examined tribal TANF programs (Hillabrant, Rhoades, and Pindus 2003). The third component focused on innovative economic development efforts in Indian country and their role in moving tribal members from welfare to work (Hillabrant, Earp, Pindus, and Rhoades 2004). The salient aspects and findings of these components are summarized below.

A. Evaluation of Tribal WtW Grants Programs
(Hillabrant and Rhoades 2000; Hillabrant, Rhoades, Pindus, and Trutko 2001)

This component of the tribal study addressed the socio-economic context of welfare reform in Indian country, the scope and services provided, the lessons learned, and promising approaches developed by tribal WtW programs. The evaluation revealed that welfare reform has had both positive and negative consequences in Indian country. On the positive side, welfare reform is consistent with the traditional values tribes place on self-reliance and contribution to the well-being of family and community. Yet, participants in the evaluation expressed concern that welfare reform might push tribal members into more dire straits because too few jobs are available or are being generated to provide employment in much of Indian country. Because many tribes have high unemployment — but typically just below the 50 percent unemployment threshold that relieves the 60-month TANF lifetime limit — large numbers of Indians and Alaska Natives may be left without support, no matter how hard they try to find work. Some participants said that denial of TANF under such circumstances would conflict with treaty-based federal trust responsibilities to Indian tribes.

Tribal WtW grantees offered many of the same services as the WtW formula and competitive grantees. All of the tribal grantees in the study provided some pre-employment job readiness preparation — usually workshops or individualized counseling — to help participants overcome and address serious barriers to employment. The tribal grantees commonly made available, either directly or through referral, a variety of supportive services such as transportation assistance, child care, substance abuse treatment and counseling, uniforms or other clothing, work tools, and equipment.

In several respects, however, tribal WtW grantees operated differently from the formula and competitive grantees. If the tribe did not operate the TANF program, then its WtW program had to develop agreements with state agencies to promote referrals from TANF offices. Typically, a memorandum of understanding was developed between the tribal WtW program and local TANF agency. In some cases, agreements with multiple counties (and even multiple states) were needed. Despite successful negotiation of such agreements, some state TANF agencies were unable to refer tribal members to appropriate tribal programs because they were unable to identify tribal members. While states and counties may record the race/ethnicity of TANF recipients, they seldom record the particular tribe to which recipients who are American Indians belong. As a result, some tribal WtW programs had difficulty recruiting participants.

Lessons learned from the evaluation of tribal WtW grants programs include the need to:

• Enhance coordination with other tribal programs. The modest scale of WtW funding and its limited duration make linkages with other programs and agencies, especially TANF, critical for recruiting WtW participants, referring them to needed services, and addressing their longer-term education and employment needs.
• Collaborate with state agencies and programs, especially TANF and Child Support Enforcement. Tribes can benefit from agreements with state TANF and child support agencies to promote referrals from TANF offices to tribal WtW programs, and find noncustodial parents residing off-reservation so that support can be collected according to tribal court decisions.
• Expand child care and transportation resources. Tribal programs have used approaches such as training TANF recipients to become licensed child care providers, providing van services, leasing or otherwise providing refurbished automobiles, and reimbursing transportation costs.
• Utilize the Indian Employment, Training, and Related Services Demonstration Act (the “477 program”) to streamline and coordinate employment and training activities.⁽³⁾ Service integration can be enhanced if the tribe participates in the 477 program, which allows unified management of funds from various federal sources for training, education, support services, job development and placement, and other services. Tribal agencies then no longer have to refer clients between programs if one has exhausted its funds; this is especially valuable to small tribes whose limited WtW funds often support no more than a part-time staff position.
• Use WtW funds to promote economic development. Tribal WtW programs can do little to directly stimulate economic development. But, in addition to providing high-quality services to enrollees, the programs can support economic development by (1) documenting the number and skills of WtW enrollees for employers who may be considering moving into the area and (2) having a plan for upgrading skills in response to the needs of prospective employers.

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B. Evaluation of tribal TANF programs
(Hillabrant, Rhoades, and Pindus 2003)

This component of the tribal study addressed the benefits of tribes operating their own TANF programs, the challenges and problems encountered, and the lessons learned. The ultimate impact of tribal TANF programs remains a question, however, because this study was not designed to measure impacts on employment outcomes. Furthermore, the persistent lack of employment opportunity in Indian country is an ongoing challenge to tribal TANF programs no matter how well they are run.

Assuming responsibility for TANF presents tribes with important opportunities that affect many members. In addition to increasing participants’ employability and opportunities, it can bring an infusion of federal and state dollars under tribal control, enhance program coordination, and improve the tribe’s reputation and image. However, operating TANF also poses risks and costs for tribes and tribal consortia. A tribal TANF program contends for resources with other tribal programs. Funding levels are based on 1994 Aid to Families with Dependent Children (AFDC) caseloads, and tribes (as with state TANF agencies) report that they cannot guarantee their ability to serve all eligible participants if unexpected events or circumstances arise, such as a natural disaster. Failure to operate the program successfully might harm the most vulnerable tribal members, set back other tribal self-determination initiatives, raise difficult personnel issues, and create or exacerbate problems with the state.

Despite these possible drawbacks, the overall experiences of tribes/Native corporations with operating their own TANF programs have been positive. In fact, cooperation on welfare reform may represent one of the best examples of tribal-state collaboration, and can serve as a model for other areas. For example, state governments have worked with tribes in the study sites to plan and carry out the transfer of responsibility for operating TANF from the state to the tribe or tribal consortium. The states have provided training and technical assistance to tribal staff and shared their approaches to TANF data collection, management, and reporting. Most of the states examined in the evaluation provided the tribal TANF programs with some or all of the matching funds they would be required to provide in a state-run program.

Several lessons were learned from the evaluation of tribal TANF programs. Reports of the number of tribal members on AFDC in 1994 are critical to the financial soundness of tribal TANF programs, but some of these reports were based on estimates that were subject to error. Refinement of some TANF program policies and procedures might help tribal programs.⁽⁴⁾ In addition, cooperation with the state can smooth the transition to a successful tribal TANF program. State policies and services are critical to the success of tribal TANF programs: states can deliver training, provide TANF services for a transition period, share state information systems and equipment, and ensure that tribal TANF participants have access to other state services.

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C. Analysis of Economic Development in Indian Country
(Hillabrant, Earp, Rhoades, and Pindus, 2004)

American Indian tribes and Alaska Native villages have embraced the goals, objectives, and programs associated with welfare reform, but the lack of jobs threatens the success of tribal programs such as TANF and WtW. Recognizing the scope and importance of this problem, the federal government has promoted business and economic development (BD/ED) in Indian country. This last component of the tribal study examined: (1) examples of BD/ED activities and the federal initiatives utilized by a convenience sample of eight tribes and two Alaska Native Regional corporations, (2) the legal, historical, and cultural context of tribal BD/ED, and (3) the challenges tribes/Native corporations face in pursuing BD/ED, as well as the promising approaches they are developing to minimize or overcome them.

Every tribe/Native corporation in the study benefited from one or more federal programs promoting BD/ED; however, no single program/initiative was especially beneficial to all tribes in the study. The most helpful were gaming, USDA rural development programs in combination with the Empowerment Zones and Enterprise Communities (EZ/EC) program, and the Small Business Administration 8(a) and HUBZone programs. Some tribes identified the Indian Gaming Regulatory Act⁽⁵⁾ as the federal initiative with the greatest impact on their BD/ED. In 2001, 201 of the 561 federally recognized tribes had gaming operations, with total revenues of $12.7 billion. While gaming has transformed some tribal economies and provided a stimulus to others, most tribes do not participate in gaming operations and some that do participate have been unsuccessful or have produced only modest profits.

The tribes/Native corporations in the study have developed a wide range of BD/ED activities that build on their natural resources and other favorable conditions — for example, location near such tourism and recreation attractions as national parks and monuments. These tribes have developed businesses in the service sector (gaming, tourism, banking), manufacturing, farming, natural resource management and development (mining, forest products), and more. Two tribes in the study have experienced significant success, transforming their economies, creating jobs, and dramatically reducing unemployment and poverty on their reservations. Another gradually developed a diverse and strong economy and has achieved one of the lowest unemployment rates (10 percent) in Indian country. Other tribes, often using innovative and aggressive BD/ED planning and operations, have developed new businesses and industries and created jobs.

Yet despite some notable successes in the area of economic development, the number of jobs created and the wealth produced in Indian country continue to be outpaced by the large numbers of tribal members who lack employment and live in poverty. Many Indian tribes and Alaska Native villages experience levels of unemployment exceeding 45 percent, and levels of poverty exceeding 36 percent. Study participants in seven of the eight tribes and one of the Alaska Native corporations in the sample reported unemployment rates exceeding 45 percent — with the highest at 80 percent.

The study participants identified four critical challenges to their BD/ED efforts: (1) legal and administrative barriers such as zoning regulations, tax policies, and/or incomplete commercial codes, (2) pressure from elected officials or tribal stockholders on business activities that is inconsistent with long-term planning and investment, (3) lack of investment capital (debt and equity financing), and (4) poor coordination of business-related activities within the tribe and with neighboring cities and counties.

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Endnotes

(1) Public Law 104-193, section 103, August 22, 1996.

(2) Public Law 105-33, section 5001, August 5, 1997.

(3) Public Law 102-477, 1992.

(4) For example, facilitating the use of state TANF reporting systems by tribal grantees could make the required quarterly reports easier to compile. In addition, waivers or other procedural changes could facilitate participation by tribal TANF recipients in state-run Food Stamp, Medicaid, and SCHIP programs.

(5) Public Law 100-497, 1988.

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