Feasibility Study for the Evaluation of DHHS Programs That Are or May Be Operated Under Tribal Self-Governance. Matrix of Issues and Concerns Raised at Discussion Groups  at NIHB and DHHS/DOI Self-Governance Conferences


Discussion Guide Matrix
Do the Draft Findings and Conclusions Ring True in Your Experience?

Financial Issues

Political Issues



Systematic Problems

Opposition to looking at “total Tribal revenues”, look at program expenditures.

Comparing SG with non-SG programs may trigger other issues, i.e. direct services vs. Title I contract Tribes.

What does ‘turn-over’ measure? Why the focus?

Possible measures include: Tribal codes and levels of community participation.

Many Tribes are members of consortia and data/finances are mixed.

Look at program revenues not Tribe total

Evaluation should provide forum for showing SG works

See if Tribal employment increased.

Look at ‘new services’ added to programs since SG.

Many Tribes lack infrastructure prior to take-over

Gaming Tribes will resist gov’t examination of total revenues

Fear that pressure on data will move Tribes toward regionalization.

Look at ‘institutional history’ through interviews, not turnover

Pre/Post not fair, as Tribes not receiving same level of funds as States (TANF, Child Support) upon contract

Draft Findings document assumes there will be a standard for uniform reporting across sites. This is not realistic.


Tribal priorities drive SG, and can prioritize ‘quality’ over ‘quantity’.

Draft Findings document suggests Tribes do not have salary data by position, but most Tribes do have this in budgets.

Draft Findings document suggests a standard of an “integrated system” which Tribes lack.  Note that neither States nor most Federal agencies have this either.


The responsibility to secure baseline data from States/Federal agencies prior to SG must rest with DHHS.


Discussion Matrix
What Omissions Do You See?


Purpose for Evaluation

Assumption of Trust

Cost Implications

We want to see success stories

Better description of evaluation processes applied in this study

You need to convey trust is there.  Trust of Tribes will reduce skepticism.

The cost of moving toward an “integrated MIS” must be born by the feds, if it will be used as a standard for evaluation.  It is a Tribal decision to move toward integrated MIS.


Address issues of evaluating small populations, numbers.

Tribal Self-Governance already assumes a level of competence.

No across the board measures. The cost of doing these measures must be covered.


Important to communicate that this study looks at feasibility of evaluating Federal PROGRAMS operated under SG and not the concept of SG itself.

Tribes have to determine and define their own outcomes.

Tribes should have same access to resources as States to do this work.


Discussion Matrix
What Are Best Outcomes of This Feasibility Study?

Success Stories/Lessons


Tribal Base

Better Focus

Know Limits

Document Tribal innovations, collaborations and creativity

Move away from terms like “failure” and use terms like “challenges”

Tribes starting from level of inadequate funding and lack of infrastructure

You cannot evaluate Self-Governance, but you can evaluate Federal programs operated under SG mechanism.

You cannot do an across the board evaluation design with SG, because SG allows for Tribal innovation and priorities.

Communicate the service ‘values’ from the community perspective, i.e. increased control, increased participation, cultural appropriateness

Find another word for “evaluation”, it has negative connotation

Tribes already have program specific reporting requirements with 11 DHHS programs.

If Tribes perform poorly in an evaluation will the feds take-away funding? Tribes want to know.

Self-Governance was intended to allow Tribes flexibility to do the most with limited resources.


Program evaluations under SG, not evaluation of SG.

Statistical data is already available and should be used.

Begin with minimum standards not maximum standards as base.

Understand challenges to measuring small populations, small data.


Look at services provided not money spent

More complex than counting users, also look at intangibles like ‘ownership’ building a base, hiring Tribal members.