When DHHS approves a tribal TANF plan, it confirms the tribe's specification of when it will take responsibility for the TANF program, but the transition is often gradual rather than abrupt. The grantees in the study worked closely with the states to ensure a smooth transition, often involving an interim period of continued state involvement. For example, the Torres Martinez consortium's agreement with the state provided for a 90-day period for the transfer of clients to the tribal program. The Navajo Nation began the implementation phase in March 2002, with an anticipated completion in September 2002, including specific transition timetables for portions of the reservation in Arizona, New Mexico, and Utah.
Tribal grantees can also smooth the transition by making it incremental. Eight of the 10 study grantees developed an approach that allowed the tribe/consortium to take over the operation of program components gradually while the state continued to provide some services and to operate other program components. For example, a tribal grantee might begin by enrolling and serving new TANF participants while the state continues to serve the existing caseload, turning over a specified number of participants to the tribe each month or quarter. Grantees reported that phased transfer of cases from the state was especially valuable when the tribe had few resources for TANF planning and implementation. A delay of 3 to 8 months in transferring cases helped tribal grantees to recruit and train program staff and to identify and correct problems while serving a manageable caseload..
After implementing the tribal program, grantees may choose to contract with states or other service providers for selected TANF services or operations on a long-term basis. For example, the Mille Lacs tribe contracts with the state of Minnesota for cash payments to tribal TANF participants and uses the state TANF information system to produce data which the tribe uses in preparing quarterly reports as mandated by the Act. The Torres Martinez consortium, through an arrangement with Wells Fargo Bank, issues payments to TANF participants through debit card accounts.
For tribes that plan to operate all aspects of the TANF program, good working relationships with state and local TANF offices can be important for a smooth transition. The Port Gamble S'Klallam tribe met with the county TANF staff to develop a Memorandum of Understanding (MOU). The county TANF office assigned specific workers to help in transferring cases and, after the tribe negotiated an agreement with the state of Washington, helped to speed up Medicaid and Food Stamp Program (FSP) applications for tribal members.
After timetables and tribal/state responsibilities are clarified, tribes must develop policies and procedures for their TANF plan. The tribal director of TANF or human services (or assigned staff) usually prepares a policy and procedures manual, and then presents the TANF policies to the tribal government for approval. Sometimes, differences between tribal and state TANF policies require special accommodations. For example, the Winnebago tribe uses the state's system for issuing TANF payments, but the tribe's sanction policy differs from that of the state. The state's payment system was set up according to the state's policy, so it could not be used to issue payments to tribal TANF participants who had been sanctioned. This problem was resolved by using an alternate payment mechanism for those who have been sanctioned, while the state issues all other tribal TANF checks.