Operating TANF: Opportunities and Challenges for Tribes and Tribal Consortia. Coordinating TANF with Other Programs


Moving TANF from state to tribal administration changes the way that TANF interacts with other programs run by both tribes and states. The change is likely to facilitate coordination between TANF and tribal programs such as Welfare-to-Work (WtW), workforce development, and social services. Some study informants said that incorporation of TANF into the 477 program further enhanced program coordination. However, moving TANF administration to the tribe/tribal consortium may complicate coordination between TANF and programs still administered by states.

Tribal operation of TANF increases opportunities for coordination between tribal TANF and other tribal programs. When a tribe takes over TANF, it opens one or more offices on the reservation. Often, the tribal TANF offices are in the same facilities as other tribal programs  this improves access for tribal members and makes it more feasible to have TANF and other program staff in close communication. In some tribes, several programs may even share staff, with one or more staff partially funded by TANF, WtW, and NEW. Tribal operation of TANF may increase awareness of needs that can be met from multiple program resources. For example, Mille Lacs staff, recognizing tribal TANF clients' needs for child care and transportation, have planned cross-program initiatives to address them. They are writing an application for a grant to support reservation-based licensed child care  coordinating with Head Start and with the tribal housing program to make sure homes that provide child care comply with building and safety codes. They are also working with a local car dealership on a car ownership program; the dealership will buy used cars at auction, repair them, and sell them to tribal members at little or no profit. Port Gamble TANF clients are encouraged to participate in a two-month budgeting and credit management course offered by the tribal housing authority to help families clean up their credit so they can purchase a manufactured house. Those who finish the training receive a housing bonus that they do not have to pay back.

Opportunities for coordination between tribal TANF and other tribal programs can be amplified if TANF is included in a 477 program. For example, 477 grantees can use a portion of their 477 plan resources to promote economic development which, in turn, can address what is probably the most serious threat to the success of tribal TANF programs  the lack of unsubsidized jobs in much of Indian country. Section 1103(e) of Public Law 106-568 (which amends Public Law 102-477) allows 477 tribes to use 10 to 25 percent of their total 477 plan resources, including TANF (if it is part of the 477 plan) on economic development, depending on their unemployment rate. One tribal grantee noted that program coordination and continuity of service was facilitated by the pooling of funds in a 477 program because agencies no longer have to refer clients from one program to another if one has exhausted its funds. Two tribes reported that the integration of funds and services in their 477 programs is a key ingredient in their training, education, support services, job development and placement, and other services for TANF participants. At Mille Lacs, for example, the 477 program, including TANF, is in the tribe's education division, which includes the workforce center and adult education and community technology grants. Program staff said that the co-location of TANF with tribal education programs and the integration of TANF and other programs under 477 helped to coordinate training of TANF participants and other tribal members. Despite the program's flexibility, there are clear limits to the discretion allowed 477 grantees  Section 14(a)(1) of Public Law 102-477 provides, "program funds shall be administered in such a manner as to allow for a determination that funds from specific programs (or an amount equal to the amount attracted from each program) are spent on allowable activities authorized under such program."

Despite potential advantages in service delivery, some tribes that incorporated TANF into a 477 program reported disappointment with the degree to which management integration was achieved. Four of the study grantees operate a 477 program that includes TANF, and they are enthusiastic about how the program works, but officials of some of these tribes reported problems related to funding and how it is distributed. All federal funding that is part of a 477 program is usually made available to tribes through the BIA; however, from late FY 2001 to late FY 2002, pending the signing of an updated interagency memorandum of understanding (MOU) between DHHS, the Department of Labor, and the Interior Department, TANF funds were disbursed directly by DHHS to tribal grantees. The "477 tribes" in the study said that the disbursement of TANF funds separate from other 477 funds created administrative problems. One tribe found that the TANF program was in effect a drain on resources from other programs once their resources were pooled, because the integrated program ended up serving many more people after the tribe began operating TANF.

Enthusiasm for the service integration possible under 477 is also dampened by concerns the 477 tribes voiced about TANF reporting requirements. Under the 477 program, tribes and tribal consortia annually submit a single set of reports (statistical, narrative, financial status, and audit) for the integrated program to the BIA, which forwards the reports to other federal departments and agencies that fund programs incorporated into the 477 program. However, the Act requires that tribal (and state) grantees submit quarterly TANF reports. Thus, incorporating TANF into 477 does not streamline reporting. Whether for these or other reasons, the majority of tribal TANF programs do not incorporate TANF into the 477 program  26 out of 38 current grantees do not administer TANF in 477. DHHS staff reported that of 6 plans currently under review, 8 plans pending submission, and 18 tribes and consortia deliberating whether to develop plans, none envision including TANF in 477 programs.

Which tribal programs are coordinated varies across the grantees in this study. For two of the four study grantees that participated in the 477 program (Mille Lacs and Port Gamble), TANF was integrated into the 477 program along with other programs such as WtW, NEW, WIA, and vocational education. For the other study grantees, TANF tended to be closely coordinated with the WtW program. Since tribes' WtW funding is substantially smaller than their TANF funding, WtW funds are often used to supplement services provided under TANF. For example, in one case WtW funds are used to pay for a portion of the salary for one or more staff employed by the tribal employment and training or workforce development program. WtW funds are also used to support child care, special training, and job-readiness activities for TANF recipients.

Tribal operation of TANF opens possibilities for improved coordination between TANF and other tribal programs, but it can also complicate links with programs still administered by the state. Coordination between a tribal TANF program and the state-run Food Stamp Program, Medicaid, and State Children's Health Insurance Program (SCHIP) can actually become more difficult than when TANF was also operated by the state. Most of the tribal grantees had to negotiate and work with the state(s) to develop procedures to facilitate the enrollment of tribal TANF participants in the three state-run programs. Although developing effective procedures was not easy, tribal officials acknowledged that access to TANF, FSP, SCHIP and, to a lesser degree, Medicaid, was also a problem before the tribe took over TANF. Two of the grantees in the study (Lac du Flambeau and Red Cliff) avoid the divide between TANF and the three other programs by administering all of them for their tribal members, under an agreement with Wisconsin and a federal waiver.

However, coordination and agreements between tribal TANF and state programs can help deal with a variety of problems experienced by tribal members. Members of the Port Gamble S'Klallam tribe had to travel 30 miles to the county service office (CSO) to enroll in FSP, SCHIP, and Medicaid. The tribe argued that federal law does not require state staff to interview applicants in person for these programs. With support from the governor's office, an agreement was reached that allows tribal members to complete applications at the tribal TANF office, which faxes them to the CSO for processing. State staff come to the reservation weekly to conduct face-to-face interviews as needed. Electronic Benefit Transfer (EBT) cards are mailed to recipients, unless they wish to go to the CSO to get them more quickly, in which case the tribe provides either transportation or a voucher for it. The agreement also provides for special attention at the CSO for tribal members when they do seek assistance there, so they are not "lost in the shuffle," the county assigned one worker at the CSO to be the FSP/Medicaid liaison for tribal TANF clients. Other tribes have achieved similar accommodations. For example, Torres Martinez tribal TANF staff help clients deal with the county social services offices for FSP and Medicaid, and they transport clients to county offices when necessary. Los Angeles County Department of Public Social Services staff are on-site at the tribal TANF offices at scheduled times to process clients' FSP and Medicaid applications and to provide other assistance.

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