Three of the grantees in the study (Nez Perce, Three Affiliated Tribes, White Earth) operate 477 programs that include WtW funding. When WtW funding is incorporated in a 477 program, there may be no distinct WtW program component; as with other 477 program funding, the WtW funds may be reprogrammed to meet the 477 program goals. Each of the three 477 programs in the study is operated under a tribal agency or department such as education, Tribal Employment Rights Office (TERO), or the tribal college.
The 477 program represents a dramatic departure from the way tribes traditionally have administered federally funded programs. Using the 477 approach, a tribe can combine funding from different federal programs without having to adhere to some of the limitations and requirements associated with specific programs or funding agencies. The tribe can define and deliver a set of integrated services in accordance with the tribe's goals and priorities. The 477 tribes in the study used service integration and case management approaches to administer unique programs. To do so, they drew on funding from WtW, NEW, vocational education, vocational rehabilitation, adult education, and other programs funded by ED, DHHS, the Department of the Interior, and DOL.(4)
While incorporating WtW, TANF, and other related programs into a 477 program has potential advantages, some problems have been encountered. The 477 approach can facilitate the development of a one-stop approach, as well as pooling of funds/resources to meet tribally determined goals. Support services, employment, training, child care, and other services or activities can be managed directly in conjunction with the TANF program. If each program is operated separately (outside 477), then the tribal units often have to implement some system of linkages, which can make service integration more difficult, although still possible. On the other hand, some problems have occurred in the release of FY 2002 NEW and CCDF funds to the 477 tribes through the BIA; in addition, some federal program administrators have raised concerns about the adequacy of 477 grantee annual reports to demonstrate that federal funds have been expended in accordance with statutory or regulatory mandates. Tribal and federal informants reported that annual 477 reports had been expanded over the years to meet some of these concerns.
The Indian and Native American Employment and Training Coalition (INAETC) offers technical assistance to tribes that want to determine the advantages and disadvantages of implementing a 477 program. INAETC works with DINAP in DOL and the BIA to obtain and distribute information to tribes pertaining to employment, training, and other welfare-related programs.
While about one-third of the tribes that operate TANF programs operate them under the 477 program, none of the tribes in this study had done so. PRWORA requires tribal TANF programs operated under a PL 102-477, like all other TANF programs, to submit TANF reports. Therefore, one advantage of program integration under 477 is not gained with regard to TANF, a factor that may contribute to some tribes' decision not to incorporate TANF in a 477 program.
Tribes in the study that participate in the 477 program were enthusiastic about it. Informants said that the 477 approach promotes Indian self-determination and self-governance, as well as service integration. These tribes had reassessed their goals and priorities with respect to education, training, and employment as part of designing and developing their 477 programs. They reported that they were better able to develop comprehensive approaches to interrelated education, employment, and training problems and conditions less fettered by the priorities, requirements, and approaches specified by separate programs and agencies.