The Evaluation of the Tribal Welfare-to-Work Grants Program:
Initial Implementation Findings

I. Introduction

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Contents

  1. Purpose of the Study
  2. Policy Context
  3. Study Methods and Sites
    1. Study Sites
    2. Site Visits

Endnotes

American Indian tribes use a number of programs, including the Temporary Assistance for Needy Families (TANF) program and the Native Employment Works (NEW) program, to place members in jobs and to improve their economic well-being.(1) The Welfare-to-Work (WtW) grants program offers tribes additional resources to supplement those of TANF, NEW, and other programs by targeting the most disadvantaged welfare recipients and helping those with significant barriers to employment make the transition from welfare to work. This report, based on site visits to a diverse sample of 10 tribal WtW grantees, describes how the tribal WtW program has been implemented in Indian country, the problems encountered, and the promising approaches developed.(2) The report has a broad focus, which includes a description of the special circumstances of tribes and the effects of welfare reform in Indian country.

The evaluation of the tribal WtW program is mandated by the Balanced Budget Act (BBA) of 1997 and is being conducted under contract from the U.S. Department of Health and Human Services (DHHS) by Mathematica Policy Research, Inc. and its two subcontractors, the Urban Institute and Support Services International, Inc. Because of the special circumstances in Indian country, the findings pertaining to the tribal WtW program are presented separately in this report. Findings from the national WtW evaluation are reported elsewhere.(3)

A. Purpose of the Study

The tribal evaluation assesses the implementation and operation of tribal WtW grantees' programs and how they are evolving in a diverse set of sites. The evaluation also assesses how social, cultural, economic, programmatic, and other factors unique to Indian country and to each site affect this evolution. The study describes the implementation of the WtW program in the broader context of welfare reform and the special circumstances of tribes. The goal of the study is to provide information to Congress, tribes, federal agencies, states, and others concerning four issues:

  1. How the special circumstances of tribes affect their WtW programs in particular and welfare reform in general (Chapter II)
  2. The framework for implementation of tribal grantees' WtW programs (Chapter III)
  3. How tribes are using WtW funding, the types of services provided, and the attributes of the clients served (Chapter IV)
  4. Promising approaches developed by tribes and tribal consortia in implementing WtW and other programs associated with welfare reform, as well as lessons learned and policy implications of grantees' experiences (Chapter V)

This report presents the initial findings of the tribal WtW evaluation based on the first round of site visits to 10 tribal WtW grantees conducted in fall 1999 and spring 2000. It supplements a report, prepared for and submitted to all the federally recognized tribes in November 2000, on the initial lessons based on the experience of tribal WtW grantees (Hillabrant and Rhoades 2000). Both reports are based on the first round of site visits. The earlier report was prepared for tribal leaders and managers. The present report was prepared for people interested in welfare reform in Indian country, including members of Congress, federal, state, and tribal policymakers, and program administrators.

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B. Policy Context

Indian tribes and consortia of tribes have been explicitly included in federal welfare reform initiatives such as TANF, Child Care Development Fund (CCDF), WtW, and NEW. Both Congress and federal agencies administering these programs have supported Indian self-determination and tribal consultation in formulating the legislation and in developing policies and regulations. The legislation and regulations permit tribes to operate the programs and allow some flexibility for the special circumstances and interests of each tribe.

The WtW grants program is a $3 billion program established by Congress as part of the BBA. Its purpose is to provide additional resources to supplement the welfare reform funds included in the TANF block grant, which was authorized under the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996. Congress intended that these additional funds would support programs, especially in high-poverty communities, that help the least employable, most disadvantaged welfare recipients make the transition from welfare to work and that help noncustodial parents increase their earnings and support their children.

The BBA permits Indian tribes and tribal consortia to participate in the WtW grants program.(4) One percent (more than $30 million) of the $3 billion was set aside for the tribal WtW program; $15 million was awarded to tribal grantees in fiscal year (FY) 1998 and a similar amount in FY 1999 (Table 1.1 presents the key components of the tribal WtW program). While the WtW grants represent a distinct funding stream, most tribal grantees use the funds, combined with funding from other programs (e.g., NEW, TANF, Job Training Partnership Act [JTPA], Workforce Development Act [WIA]), to enhance services provided by existing employment programs. As discussed in Chapter III, under the authorization of the Public Law (PL) 102-477 program, some tribes have reprogrammed WtW and other funds into a unified "477 Program" that addresses particular circumstances and goals set by the tribe.

PRWORA authorizes tribes or tribal consortia to operate a TANF program and allows them flexibility in the specification of the service area and population and operation of the program. In fall 2000, the Office of Child Support Enforcement in the Administration of Children and Families (ACF), DHHS, issued interim regulations (45CFR Part 302) that permit tribes to enter into cooperative agreements with state agencies to assist in administering the State Child Support Enforcement (CSE) plan.

Primary federal responsibility for tribal programs related to welfare reform is spread across units of two departments--Health and Human Services and Labor (DOL). Within DHHS, ACF administers tribal TANF and NEW programs (through the Office of Community Services/Division of Tribal Services), the Administration on Children, Youth, and Families administers tribal CCDF (through the Child Care Bureau), and the Office of Child Support Enforcement administers CSE. Tribal WtW programs are administered by the Division of Indian and Native American Programs (DINAP) in DOL. Both DHHS and DOL have consulted with tribes in developing and modifying regulations for tribes operating TANF, NEW, CSE, and WtW programs.

In Indian country, as in all communities throughout the United States, the overall goal of welfare reform is to help people dependent on welfare to become gainfully employed and financially independent. The TANF program, in conjunction with other federal and state programs such as food stamps, Medicaid, Medicare, and the Children's Health Insurance Program (CHIP), provides income support while helping participants secure unsubsidized employment. The WtW program was designed to help the most disadvantaged and least employable TANF recipients move from welfare to work. The NEW program, authorized by PRWORA, replaced the tribal Job Opportunities and Basic Skills Program (JOBS) and provides a variety of work-related activities (e.g., education and training, work readiness, employment activities, supportive and job retention services) to tribal members. NEW grantees may also provide labor/job market assessments, job creation, and economic development activities designed to lead to job creation. Only those tribes and Alaska Native villages that operated a tribal JOBS program in FY 1995 are eligible for NEW grants.

Table 1.1
Key Tribal WtW Provisions
Provision Original Program Amended Program
Authorization The Indian and Native American (INA) WtW Program is authorized by Title V, section 5001(c) of the Balanced Budget Act of 1997 (PL 105-33), which amended title IV-A of the Social Security Act by adding section 412(a)(3) [42 U.S.C. 612(a)(3)]. Title VII of HR 3424, the Departments of Labor, Health and Human Services, and Related Agencies Appropriations Act of 2000.

Effective Date 8/5/1997 11/29/1999
Grantee Eligibility Three categories of federally recognized Indian tribes, consortia of such tribes, or Alaska Native regional nonprofit corporations are eligible to receive INA WtW funds--those that (1) operate a tribal TANF program, (2) operate a NEW program, or (3) operate an employment program funded through other sources under which substantial services are provided to recipients of assistance under a program funded under Part A of title IV of the Social Security Act. No change
Funding Formula Two funding formulas used: (1) for TANF and NEW tribes, based on welfare caseload data (AFDC/TANF data); and (2) for the "substantial services" tribes, based on FY 1990 Census data. Each eligible tribe received a formula allocation that represents its share of the national total. No change
Eligibility for Hard-to-E mploy Long-Term Welfare Recipients (70% Category) No less than 70 percent of the WtW grant funds must be expended to serve clients who meet 2 conditions:
1.Received assistance for at least 30 months AND
2.Meets 2 of 3 characteristics:
  • Lacks HS diploma or GED AND has low math or reading skills
  • Has poor work history
  • Requires substance abuse treatment for employment
Received TANF assistance for at least 30 months, OR is within 12 months of becoming ineligible for TANF due to time limits
Eligibility for Recipients with Characteristics of Long-T erm Dependency (30% Category) Up to 30% of the WtW grant funds may be expended to serve clients, including noncustodial parents, who are school dropouts, experience teenage pregnancy, or have a poor work history. Up to 30% of the WtW grant funds may be expended to serve clients who fall in at least 1 of 3 categories:
  1. Youth who have "aged out" of foster care
  2. Custodial parents with incomes below the poverty level
  3. TANF recipients who face barriers to self-sufficiency under criteria established by the local workforce investment board
Eligibility for Noncustodial Parents Eligible under both the hardest to serve (70%) and long-term welfare dependency (30%) categories

Under hardest to serve category (70%), must meet 2 of 3 characteristics:

  1. Lacks HS diploma or GED AND has low math or reading skills
  2. Has poor work history
  3. Requires substance abuse treatment for employment
Noncustodial parents eligible only under the 70% category if they meet each of 3 conditions:
  1. Are unemployed, underemployed, or have difficulty in making child support payments AND
  2. Their minor children (1) are eligible for TANF or receive TANF benefits; ( 2) received TANF benefits in the preceding year; or (3) are eligible to receive benefits from Food Stamp, Supplemental Security Income, Medicaid, or Children's Health Insurance Programs; AND
  3. Enter into a personal responsibility contract under which they commit to establish paternity, pay child support, and participate in services to increase their employment and earnings, and to support their children.
Personal Responsibility Contracts for Noncustodial Parents Not required Required (see above)
Integration with Workforce Investment Act A state's WtW plan is a supplement to its TANF plan. Addition to the 30% eligibility category: TANF recipients who face barriers to self-sufficiency under criteria established by Workforce Investment Board (WIB)
Allowable Activities
  1. The conduct and administration of community service or work experience programs
  2. Job creation through public or private sector employment wage subsidies
  3. On-the-job training
  4. Contracts with public or private providers of readiness, placement, and postemployment services
  5. Job vouchers for placement, readiness, and postemployment services; and
  6. Job retention or support services if such services are not otherwise available

Stand-alone training is not an allowable activity.

 Preemployment vocational education and job training for up to 6 months is added as allowable activity.
Other None Any participant enrolled in a tribal WtW program prior to the 1999 Amendments will remain eligible despite changes in eligibility.
Grantee Reporting Requirements Using forms developed by DOL, grantees are required to submit cumulative quarterly and annual reports covering program activity and financial expenditures. Minor change in reporting forms
Inclusion in PL 102-477 Program All grants awarded under the INA WtW program are formula-funded; any INA WtW grant funds awarded to a tribe can therefore be included in a consolidated plan authorized by PL 102-477. For those tribes already participating in the 477 demonstration, application for an INA WtW grant will take the form of a "477 plan" modification submitted to the lead agency responsible for the 477 program. No change

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C. Study Methods and Sites

The study focuses on a small but diverse set of tribal WtW grantees. Ten grantees were selected from the 92 tribal grantees that were awarded WtW grants by DOL in FY 1999 with the aim of ensuring variation in five attributes (see Table 1.2):

  1. Region of the country defined as East (east of the Mississippi River), Southwest (Arizona, New Mexico, Oklahoma, Texas, Utah), Plains (Kansas, Montana, Minnesota, North Dakota, South Dakota, Wyoming), Pacific (California, Idaho, Nevada, Oregon, Washington), and Alaska
  2. Size of the TANF population defined, for the purposes of this study, as large (more than 1,000), medium (between 100 and 999), and small (fewer than 100)
  3. Whether the tribal grantee operates a PL 102-477 program
  4. Whether the tribal grantee operates its own TANF program
  5. Whether the grantee is an individual tribe or a tribal consortium

Table 1.2
Diversity of Study Sample on Key Attributes

Grantee

 State(s) Region Size of TANF Population 102-477 Program Tribal TANF Consortium

1. California Indian Manpower Consortium, Inc. (CIMC)

 CA Pacific Medium No No Yes

2. Eastern Band of Cherokee (EBCI)

 NC East Medium No No No

3. Kickapoo Tribe of Kansas

 KS Plains Small No No No

4. The Klamath Tribes

 OR Pacific Small No Yes No

5. Navajo Nation

 AZ, NM,UT Southwest Large No Yes No

6. Nez Perce Tribe

 ID Pacific Medium Yes Yes No

7. Red Lake Band of Chippewa Indians

 MN Plains Medium No No No

8. Tanana Chiefs Conference, Inc. (TCC)

 AK AK Large No Yes Yes

9. Three Affiliated Tribes (TAT)

 ND Plains Medium Yes No No

10. White Earth Reservation Tribal Council

 MN Plains Medium Yes No No

1. Study Sites

Appendix A presents a profile of each of the 10 WtW grantees in the study. These profiles describe the economic context in which the grantee WtW program operates, as well as the program's structure, model, and services provided.

Grantees were selected to ensure diversity in the five attributes discussed, but they were also chosen based on the comprehensive plans and innovative approaches described in the WtW grant proposals. When more than one grantee met the five diversity criteria, the one with the most comprehensive or innovative proposal was selected to participate in the study. Two alternates were selected for each of the 10 grantees selected, in case some of the grantees might be unable to participate in the study. Despite the diversity of the WtW grantees in the study sample, they were not selected at random, and no attempt is made in this report to generalize the study findings to other tribal WtW grantees, tribes, or tribal consortia.

The grantees in the study were diverse in other attributes as well (see Table 1.3). While there are inconsistencies between the data reported in published sources and the data provided at site visits, Table 1.3 does give a sense of the variation across tribes and of the relative nature of differences among the grantees. For example, the size of the Tanana Chiefs Conference enrolled member population is less than five percent of the Navajo Nation; roughly similar to that of Red Lake, the Cherokee, and Three Affiliated Tribes; and slightly more than half that of the White Earth Tribe.(5) The labor forces of the Tanana Chiefs Conference and the Kickapoo Tribe are small compared with those of the Cherokee, the Navajo Nation, and the Three Affiliated Tribes. The number of enrolled members ranges from 326 in the Kickapoo Tribe to more than 234,000 in the Navajo Nation. There is corresponding variation in the size of the grantee labor force, ranging from 142 (Tanana Chiefs Conference) to 41,451 (Navajo Nation).

Table 1.3
Other Attributes of study sample

Grantee

 Land Area
(Square Miles)		 Population Labor Forcea
Enrolled Members Residents

California Indian Manpower Consortium, Inc. (CIMC)

 NA NA 34,000 23,384

Eastern Band of Cherokee (EBCI)

 56,688 10,000 6,311 2,366

Kickapoo Tribe of Kansas

 4,879 326 478 350

The Klamath Tribes

 372 3,248 3,748 735

Navajo Nation

 16,224,896 234,786 234,786 41,451

Nez Perce Tribe

 750,000 3,300 16,159 743

Red Lake Band of Chippewa Indians

 837,736 9,264 7,974 871

Tanana Chiefs Conference, Inc. (TCC)

 138,240 11,086 6,191 142

Three Affiliated Tribes (TAT)

 1,000,000 10,500 5,246 1,059

White Earth Reservation Tribal Council

 837,120 20,989 6,491 765
Source: Tiller (1996), except when more recent data were available from the grantee.
a The reported Labor Force includes unemployed people who are able to work.
NA = not available.

It is common for some (often, many) tribal members to live away from the reservation or tribal lands.(6) In Table 1.3, "residents" refers to all people living on or near the reservation, including tribal members, other Indians, and non-Indians. Some reservations (such as Red Lake) have few non-Indian residents, while others (such as Nez Perce) may have more non-Indian residents than tribal members, as a result of the General Allotment Act of 1887, which opened large amounts of tribal lands for homesteading by non-Indians.

2. Site Visits

Between August 1999 and April 2000, a two- or three-person team visited each of the 10 WtW grantees in the study sample. The site visit teams collected existing materials (for example, reports, analyses, data compilations) prepared for and by the tribal grantees and interviewed more than 280 key informants (see Table 1.4). Because of the broad scope of the tribal evaluation, interviews were conducted with state and county officials and private-sector employers located on or near the reservation, as well as with tribal officials, WtW program staff, and staff at other tribal programs (e.g., social services, education, workforce development). In addition, informal discussions were conducted with WtW program participants.

Table 1.4
Study Informants

Grantee

 Tribal Officials Tribal Staff Tribal Staff Other Partners State Staff Employers WtW Participants Total
WtW Other Tribal State/ County

CIMC

 3 4 8 n.a. 5 0 1 3 4 28

Cherokee

 3 2 2 n.a. 1 2 3 0 3 16

Kickapoo

 3 1 4 n.a. 1 1 3 0 1 14

Klamath

 7 2 2 4 0 0 1 2 3 21

Navajo Nation

 8 4 10 2 0 2 2 0 3 31

Nez Perce

 15 5 9 4 0 6 6 2 6 53

Red Lake

 13 2 10 n.a. 3 5 3 4 10 50

TCC

 2 2 12 2 0 1 2 0 6 27

TAT

 3 3 7 n.a. 1 3 3 2 4 26

White Earth

 8 1 6 n.a. 1 1 1 2 0 20

Totals

 65 26 70 12 12 21 25 15 40 286
n.a. = Not applicable: tribe does not operate a TANF program.

After each site visit, a report summarizing the findings was submitted to the grantee with a request for feedback, including identification of any errors or omissions. The grantee feedback was incorporated in the final report prepared for the tribe. To encourage full disclosure by all study informants, no individual informant is identified in study reports.

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Endnotes

1.  In this report, "Indian tribe" refers to any federally recognized Indian tribe, rancheria, pueblo, or Alaska Native village.

2.  "Indian country" refers to American Indian reservations, Alaska Native villages and adjacent counties, and the states of Alaska and Oklahoma.

3.  See, for example, Nightingale (2001) and Perez-Johnson et al. (2000).

4.  Not every federally recognized tribe was eligible for a WtW grant. Only those tribes that operated a TANF or NEW program, or that met the "substantial services" criterion, were eligible. Substantial services is defined as having operated an employment program that served a minimum of 50 public assistance recipients over the last two program or fiscal years, or where 20 percent of the people served had received public assistance during the most recent program or fiscal year.

5.  Many tribes and Native villages maintain a list of members or people enrolled in the tribe or village.

6.  In this report, "reservation" refers to any lands owned by an Indian tribe.

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