Feasibility Study for the Evaluation of DHHS Programs That Are or May Be Operated Under Tribal Self-Governance. Notes

03/03/2004

[1] In this Report, the term “Self-Governance” is used to indicate the exercise of opportunities provided under P.L. 93-638, Title IV and Title V, as amended, that may be provided, if Congress authorizes a new demonstration program.  All Tribes inherently exercise self-governance as legitimate governments. 

[2] A site visit was conducted to Yukon-Kuskokwim Health  Corporation (YKHC)  in Alaska. YKHC is a Tribal organization authorized to carry out programs on behalf of Federally-recognized Tribes.  Throughout this Report, “Tribes” is used for convenience to reference both Federally-recognized Tribes and Tribal organizations that operate programs on behalf of multiple Tribes. 

[3] Some Tribes would like to be more inclusive than just the 11 programs identified by DHHS. The bill currently before Congress (S.1696) also includes Mental Health and Substance Abuse Block Grants under Title XIX of the Public Health Service Act and Community Health Center grants under Section 330 of the Public Health Service Act.  It is possible that these and/or additional DHHS programs might be included in a demonstration program, if authorized by Congress.

[4] In the case of the SAMHSA Targeted Capacity Expansion program, a broader program is proposed than what is currently available in the SAMHSA grant portfolio.  The new program would entail a combination of mental health and substance abuse services.

[5] Appendix A to this Report provides the list of members of the Technical Working Group.

[6] DHHS also included in the contractor’s Scope of Work a task to examine the feasibility of evaluating the current DHHS Indian Health Service programs managed by Tribes under self-governance.  Because the issues are substantially different for the feasibility of evaluating an on-going program, rather than a new demonstration program, results of that examination are presented in Appendix F of this Report.

[7] Referenced Reports are available on the DHHS/ASPE website, http://aspe.hhs.gov/SelfGovernance/Evaluation/actions.htm.

[8] The information in this section has been drawn from a number of DHHS sources available on the self-governance website (accessed at http://www.aspe.hhs.gov/selfgovernance/).

[9]  P.L. 102-477 allows Federally-recognized Tribes and Alaska Native entities to combine formula-funded Federal grants funds that are employment and training-related into a single plan with a single budget and a single reporting system.

[10] Federal Register, Department of the Interior, Bureau of Indian Affairs, Indian Entities Recognized and Eligible to Receive Services from the United States Bureau of Indian Affairs, Vol. 67, No. 134, July 12, 2002.

[11] All of the DHHS programs discussed in this section require the submission of Standard Form 269 to report financial data.  The financial data reported are aggregated and would not be sufficient for most evaluation purposes.

[12] SAMHSA’s established GPRA requirements include individual-level measures on drug and alcohol use; family and living conditions; education, employment, and income; crime and criminal justice status; mental and physical health problems and treatment; demographics; follow-up status; and discharge status.

[13] Data collection protocols are presented in Appendix B.

[14] Yukon-Kuskokwim Health Corporation is not a CCDF grantee.  However, two CCDF grantees provide services in Bethel, where YKHC is located:  1) Association of Village Council Presidents; and 2) Orutsararmiut Native Council.  The project team was not able to obtain information on these CCDF programs during the site visit or through follow-up telephone contacts.

[15] Note:  There are reporting requirements for Tribes that manage DHHS programs under contracts that could be viewed as uniform reporting systems.  In addition, most Tribes that compact Indian Health Service programs voluntarily submit data to the IHS RPMS system. 

[16] In addition, a similar set of illustrative models were developed and assessed for evaluation of Indian Health Service programs currently operated by Tribes under self-governance compacts.  These are presented in Appendix F to this Report.

[17] If the Tribes participating in the potential demonstration agreed on a common set of goals/objectives, then the evaluation would focus on assessing these common goals/objectives rather than, or in combination with, each Tribe’s uniquely identified goals/objectives.

[18] This additional data reporting would be limited to the evaluation period and would be discontinued at the end of the evaluation.

[19] This demonstration program officer oversight and monitoring is assumed to be similar to the type of monitoring conducted for the “477” consolidated programs.

[20] A detailed analysis of costs was not prepared for the three illustrative evaluation models for IHS programs managed under Self-Governance compacts.  Since the Indian Health Service has most data for the evaluation in-house, it would be possible for IHS to conduct these evaluation approaches as an internal activity.  The cost estimates presented represent approximated costs of an external evaluation, based on costs of comparable evaluations in terms of data collection and analytic complexity.