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Feasibility Study for the Evaluation of DHHS Programs Operated under Tribal Self-Governance

Publication Date
Nov 29, 2003

Draft Final Report

Delivery Order 27
Under Contract No. HHS-100-97-0017

Kathy Langwell
Cynthia Helba
Jo Ann Kauffman

Prepared for:
Andrew Rock, Task Order Mgr.
Office of Planning & Evaluation
Dept. of Health & Human Svs.
200 Independence Ave., SW
Washington, DC   20201

Prepared by:
Rockville, Maryland
1650 Research Blvd.
Rockville, MD   20850



Cynthia Helba and Kathy Langwell, Westat, and Jo Ann Kauffman, Kauffman and Associates, Inc., prepared this Draft Final Report.  W. Sherman Edwards and Brian Colhoff, Westat, Victor Paternoster, Kauffman and Associates, Inc., Janet Sutton, Project HOPE Center for Health Affairs, and Frank Ryan, project consultant, made substantial contributions to the study.  We would like to thank the members of the Technical Working Group for their assistance and thorough reviews of draft reports throughout the study.  In addition, we are grateful to the Tribes/Tribal organizations that volunteered to participate in site visits that were conducted for the study, including:  Bois Forte Band of Chippewa, Choctaw Nation, Hopi, Little Traverse Bay Band of Odawa Indians, Port Gamble S’Klallam Tribe, and the Yukon-Kuskokwim Health Corporation.  Several individuals at the Indian Health Service also contributed generously of their time and provided assistance with data review activities.  Finally, we would like to thank Andy Rock and Tom Hertz, OASPE/DHHS Task Order Managers for the project, who provided valuable guidance and insights throughout the project.

Chapter 1 - Summary of Findings, Background, and Objectives

1.1 - Summary of Findings

Purpose of Study:


Summary of Findings:

  • All evaluation models are technically feasible.
  • Costs would be very high for comprehensive model for evaluation of new DHHS programs under a (possible) demonstration, but results would be rigorous and useful.
  • Comprehensive evaluation of DHHS health programs operated under compacts is technically feasible and with moderate costs, but likely would not be feasible due to political considerations.
  • Limited evaluation model is technically feasible, with moderate costs, it is likely Tribes would agree to participate, and would produce solid and useful results for a limited range of evaluation issues.
  • Evaluation using aggregate reporting and monitoring data is technically feasible, would have modest costs, and likely Tribes would agree to participate, but would produce findings of limited value.

1.2 - Background of the Study

In the Tribal Self-Governance Amendments of 2000 (P.L. 106-260), Congress re-affirmed its commitment to Tribal self-governance.  In the Preamble to the Act, the Congress defined the goal of self-governance as “to permit an orderly transition from Federal domination of programs and services to provide Indian Tribes with meaningful authority, control, funding, and discretion to plan, conduct, redesign, and administer programs, services, functions, and activities (or portions thereof) that meet the needs of individual Tribal communities.”

The Act established Tribal Self-Governance of Indian Health Service programs on a permanent basis.  In addition, the Congress directed the Secretary of DHHS to “conduct a study to determine the feasibility of a Tribal self-governance demonstration project for appropriate programs, services, functions, and activity (or portions thereof) of the agency [HHS].”  The Office of the Assistant Secretary for Planning and Evaluation conducted the Tribal Self-Governance Demonstration Feasibility Study in 2001-2002.  The Final Report on the Study, submitted to Congress in March 2003, identified 11 DHHS programs as “feasible for inclusion in a Tribal self-governance demonstration project” (p.15).  These 11 programs[1] are: 

  • Administration on Aging
  1. Grants for Native Americans
  • Administration for Children and Families
    1. Tribal Temporary Assistance for Needy Families
    2. Low Income Home Energy Assistance
    3. Community Services Block Grant
    4. Child Care and Development Fund
    5. Native Employment Works
    6. Head Start
    7. Child Welfare Services
    8. Promoting Safe and Stable Families
    9. Family Violence Prevention:  Grants for Battered Women’s Shelters
  • Substance Abuse and Mental Health Services Administration
    1. Targeted Capacity Expansion
  • There are Tribes currently managing each of these DHHS programs that were determined feasible for inclusion in a Tribal Self-Governance Demonstration project, under contractual arrangements or grant awards.  A Self-Governance Demonstration program, as detailed in the Final Report, could permit a simpler, multiple-program application process and simpler and consolidated reporting requirements.  Importantly, the Demonstration program could provide “Tribes with the flexibility to change programs and reallocate funds among programs” (p.19) to better address specific Tribal community priorities.

    Congressional action would be necessary to authorize a DHHS Tribal Self-Governance Demonstration.  In order to anticipate evaluation issues that would arise if a demonstration were to be authorized, DHHS identified a need to examine how an evaluation of outcomes and successes of Tribal management of health and social services programs might be conducted. While a number of assessments of tribally-managed programs have been conducted, these have been primarily qualitative in nature. The Office of the Assistant Secretary for Planning and Evaluation (OASPE) was interested in determining the feasibility of conducting an evaluation that includes both qualitative and quantitative analysis of processes and outcomes associated with DHHS programs managed by Tribes under self-governance.

    In September 2002, DHHS contracted with Westat, and its subcontractor, Kauffman and Associates, Inc., to conduct a study of the feasibility of evaluating DHHS programs operated under Tribal self-governance that would provide background information and assess the feasibility of conducting a rigorous and defensible evaluation of DHHS programs managed by Tribes under self-governance.

    1.3 - Objectives of the Study

    The Evaluation Feasibility Study was designed to provide information to DHHS and to Tribes on several questions:

    • Is an evaluation of DHHS programs operated under Tribal self-governance feasible?
    • What evaluation issues and research questions are important to address in an evaluation?
    • What measures – both qualitative and quantitative – are appropriate to use to address each of the selected evaluation issues and research questions?
    • Are there data available, within DHHS and from Tribes managing DHHS programs, which would permit an evaluation to be conducted, using a rigorous methodology that would be likely to produce reliable results?
    • What are the cost implications of alternative feasible evaluation strategies (including sample size cost implications)?

    It is important to note that, while this project was intended to provide information helpful to the design of an evaluation, the project was not designed to produce a definitive evaluation design and methodology.  Any evaluation that might be considered, at some future time, would be developed with a consultation process between DHHS and the Tribes. Results of this Study were intended only to provide information on feasible options for an evaluation and considerations that can be used by DHHS in consultation with the Tribes about an evaluation that could be conducted and the range of issues that could be addressed.

    1.4 - Organization of this Draft Final Report

    This Draft Final Report on the Evaluation Feasibility Study provides background information and assesses the feasibility of conducting an evaluation of DHHS programs managed by Tribes under self-governance.  Throughout the 15-month project, guidance and input were provided to the study team and to OASPE by the project’s Technical Working Group (TWG).[2] In addition, preliminary findings of the site visits and data reviews were presented at discussion sessions held at three national conferences: National Indian Health Board, Self-Governance Tribes, and National Congress of American Indians.  The issues raised and perspectives of the TWG and participants in the discussion groups are reflected in the findings presented throughout this Draft Final Report. 

    Section 2 of this Draft Report provides an overview of considerations for the feasibility of conducting an evaluation of DHHS programs managed by Tribes under self-governance and describes key feasibility issues that guide the study. The study methodology and background information activities conducted are described in Section 3.  Findings from the site visits and data reviews are presented in Section 4 and results of the discussion groups held at national conferences are presented in Section 5.  In Section 6, four illustrative evaluation models are described and issues and considerations for the feasibility of conducting these alternative evaluation models are discussed.  A summary and discussion of the findings of the study is provided in Section 7.

    Unit of Measurement

    Data Available

    At the Service Unit level

    Number of patients provided services in SU, by age and gender


    Number and type of Contract Health Services provided by quarter of the fiscal year


    Percent with Medicare


    Percent with Medicaid


    Percent with SCHIP


    Percent with Private Health Insurance


    Number of hospital admissions


    Number of hospital days


    Number of primary care visits


    Number of specialist physician visits


    Number of dental visits


    Number of prescriptions filled




    Percent children under age 5 immunized


    Percent aged 50+ receiving influenza immunizations


    Percent of women over 18 with annual Pap smears


    Percent pregnant women obtaining prenatal care in first trimester


    Percent of adults screened for diabetes


    Percent diagnosed with breast cancer surviving 5 years


    Percent diagnosed with cervical cancer surviving 5 years


    Percent of births that are low-weight or premature


    Percent of births that are high-weight


    Percent of deaths attributable to diabetes


    For each Service Unit, for all patients with diabetes, three years:

    Percent seeing physician at least once in 3 months


    Percent receiving HbA1c testing once in 3 months


    Percent receiving dilated eye exam annually


    Percent of people with diabetes who have diabetic retinopathy


    Percent of people with diabetes who have had amputation

    The availability of administrative and personnel-related data elements was also investigated.  These elements would include staffing information, information on staff credentials, staff turnover, pharmacy information, and payment information.  Some of this information are likely available through other components of the RPMS (e.g., accounts payable, contract health, staff credentials), if these components are in use by the Tribal entities of interest.  

    Review of Reporting Requirements for Other DHHS Programs

    Current reporting requirements for each of the DHHS programs were also investigated by talking with several program staff and reviewing the documents provided to us by the Tribes visited.  The current reporting requirements are described below.

    Tribal Temporary Assistance for Needy Families (TTANF).     Currently, Tribes managing this program are required to provide the standard Federal financial reporting form SF269[5] and electronic submission (preferred) of family-level and individual-level data elements for families receiving TTANF. (Some Tribes may qualify to sample the caseloads on which they report these data.) For the family, these data elements include funding stream, number of family members, type of family for work participation, receiving subsidized housing, receiving medial assistance, receiving food stamps and amount, receiving subsidized child care and amount, child support, and family cash resources. At the individual level, Tribes are required to submit characteristics such as adult and minor child head-of-household characteristic such as date for birth, ethnicity, gender, receipt of disability benefits, marital status, relationship to head of household, parent with minor child in the family, needs of pregnant women, educational level, citizenship, cooperation with child support, employment status, and work participation status. The child characteristics submitted by TTANF grantees include family affiliation, race/ethnicity, gender, receiving disability benefits, relationship to head of household, educational level, amount of unearned income,

    Low Income Home Energy Assistance Program.     Currently, Tribes managing this program are required to provide the Household Service Report—Short Format or a letter containing similar information.  This information includes number of household receiving the following types of assistance: heating, cooling, winter/year round crisis, summer crisis, or weatherization.  Tribes are also required to file the SF269.

    Community Services Block Grant.     Currently, there is no specific Federal required reporting form beyond the SF269.

    Child Care and Development Fund.     Standard Child Care and Development Fund Annual reporting requires the following information: number of families and children receiving services, age breakdown for children receiving services, reasons for needing childcare (e.g., working, in school), number of hours services provided, amount of CCDF subsidy, amount of parent co-payment, poverty status of families receiving services, and financial reporting (SF269).

    Native Employment Works.     Current Federal reporting requirements include the SF269 and a Program Report that includes a narrative section that compares achievements for the year to their plan for the year.  It also summarizes significant barriers to implementation, provides explanations for variances with the plan, and describes actions taken.  Grantees must also summarize plans for unobligated funds.  The Program Report also includes a statistical report that provides the following information: number of clients served characteristics of clients served (e.g., age, sex, TANF recipients), number of clients participating in types of NEW activities and services (e.g., classroom training, on-the-job training, counseling), and number of clients with selected outcomes (e.g., GED, unsubsidized employment).

    Head Start.     The standard Head Start reports includes information in the broad categories of children enrolled by demographics, staff information by demographics, information on classes/ groups/ centers, volunteer information, and services provided. Head Start also currently has a requirement for extensive outcome measurement. 

    Child Welfare Services.     As reported to us, there are no specific reporting requirements.  Each grantee must report how they are progressing toward their 5-year plan.  Tribes are required to file the SF269 also.

    Promoting Safe and Stable Families.     Like other Child Welfare programs, we are aware of no specific reporting requirements beyond reporting concerning progress toward planned activities and the SF269.

    Family Violence Prevention: Grants for Battered Women’s Shelters.     Narrative or summary reports generally list the number of clients served and the services provided. Current Federal reporting requirements also include the SF269.

    Administration on Aging Grants for Native Americans.    The standard report for AoA includes information on full-time/part-time staff; program resources and expenditures, including sources of income other than grants; unduplicated numbers of people that receive support services, congregate meals, home-delivered meals; total numbers of congregate and home-delivered meals; units of supportive services, legal services, at-home services, ombudsmen services, and others.  In addition, grantees must submit the SF269.

    SAMHSA Targeted Capacity Expansion Grants.    Current Federal reporting requirements include the SF269 and a quarterly report and specified GPRA measures.  The quarterly and GPRA reports include the following information: grantee information; staffing information; data including number of new clients, services provided, and individual-level information on the clients as required by GPRA[6]; and narrative information about the project such as challenges and successes over the past quarter.

    3.3 - Methods for Obtaining Input from Technical Working Group and Others

    The Evaluation Feasibility Study is just one component of the DHHS efforts to support effective Tribal Self-Governance.  Since the inception of the Title VI Self-Governance demonstration feasibility study, mandated by Congress, to examine potential new DHHS programs for Tribal Self-Governance, DHHS has actively consulted with the Tribes.  A Title VI Advisory Group, comprised of Tribal Leaders with a commitment to self-governance and their designees, has worked closely with DHHS throughout that earlier process.  In addition, DHHS has made information regarding the Title VI Self-Governance demonstration feasibility study available to all interested persons through its website and through direct mailings to Tribes and other stakeholders.

    The current Evaluation Feasibility Study has continued this practice of active consultation and information dissemination.  Specific communication activities that were undertaken included:

    • A project description, explaining the project and its objectives, was sent to all Chairpersons or Presidents of Federally-recognized Tribes, with a background letter.  The packet sent included contact information for the DHHS Task Order Managers (TOMs) and for each of the Co-Principal Investigators, as well as the DHHS website address where ongoing information about the study and its progress is maintained.  Interested individuals were encouraged to provide comments and inquiries, through telephone or email to the OASPE Task Order Managers and/or the Co-Principal Investigators.
    • The Task Order Managers and Co-Principal Investigators conducted presentations and question-and-answer sessions on the project at national or regional AI/AN meetings, including the Self-Governance meetings in San Diego (November 2002) and Palm Springs (October 2003) and the Alaska Native Health Board meeting in August 2003.
    • The Technical Working Group was established and met in February 2003 to review and comment on Draft Reports, the Project Work Plan, and to provide guidance to the project.  Monthly conference calls were conducted with the TWG to discuss interim reports and progress on the project, from March through August 2003.  The Technical Working Group will meet with the project team on December 9-10, 2003 to review and discuss the Draft Final Report on the project.
    • Discussion sessions were arranged and held at the National Indian Health Board, Self-Governance, and NCAI conferences to obtain broader Tribal comments and suggestions on the study objectives and preliminary findings.
    • At the end of the project, the summary of the Final Report will be mailed to all Tribal Chairpersons with contact information for the OASPE Task Order Managers to encourage further comments and suggestions to DHHS.

    The goal of all of these communication and information dissemination activities was to ensure that the project and its development was conducted as an open and ‘transparent’ process and to glean the maximum useful advice and input from the Tribes in the conduct of the study, while seeking to assure a balanced inquiry and lead to valid and objective advice to DHHS. 

    3.4 - Methodology for Site Visits and Tribal Data Review

    Site visits were made to six Tribes to assess the feasibility of conducting an evaluation of DHHS programs managed under Tribal self-governance.  The site visits focused on determining the extent to which there is historical documentation and knowledgeable individuals who are able to provide background and information on the development and goals of Tribal management of federal programs, the Tribes’ management information systems capabilities, and the availability, sources, and completeness of data on each program managed by Tribes.  The two-day site visits were conducted by a two or three-person team during late June through August 2003. 

    While selection of site visit participants depended on availability of willing volunteers, the Technical Working Group and DHHS developed several criteria for selecting Tribes for the study.  These criteria were:

    • All Tribes selected should have three or more years of experience with compacting or contracting IHS health programs.
    • Preference should be given to Tribes that have experience in managing, under contracts or grants, one or more of the DHHS programs recommended for the Self-Governance Demonstration.
    • In addition, the sites selected, to the extent possible, reflect the following:
    • Geographic diversity, reflecting the distribution of the AI/AN population;
    • Variation in the size of the Tribe’s population; and
    • Variation in economic conditions (i.e., average income, employment levels) of the Tribe.

    The process developed by OASPE, the Technical Working Group, and the project team for recruitment of Tribes to participate in site visits included:  1) a presentation on the project by the OASPE Project Officer at the Tribal Self-Governance meetings held in late April 2003 in Phoenix; 2) distribution of a letter of invitation to all Tribes to participate, and relevant background materials, at the Tribal Self-Governance meetings; and 3) mailing of the letter of invitation and background materials to all Tribal leaders during the last week in April.  Tribes interested in participating in the site visit were asked to contact the project contact by May 20, 2003 to indicate their interest and/or to obtain additional information.

    The site visits were conducted in July and August 2003 to the six Tribes/Tribal organizations listed here:

    • Bois Forte Band of Chippewa (Minnesota)
    • The Choctaw Nation (Oklahoma)
    • Port Gamble S’Klallam Tribe (Washington)
    • Yukon-Kuskokwim Corporation (Alaska)
    • Hopi Nation (Arizona)
    • Little Traverse Bay Band of Odawa Indians (Michigan)

    3.5 - Methodology for Small Group Discussions

    The Small Group Discussions, conducted by Kauffman and Associates, Inc. (KAI), brought together tribal leaders, experienced tribal program managers and technical experts in self-governance program management to provide feedback and response to preliminary findings and conclusions related to this study.  These discussions provided another means for review and analysis of draft findings and conclusions.  A qualitative analysis of these discussions was conducted to identify “major themes and issues” that emerged across the board.  These major themes informed the study team and the Technical Work Group prior to finalizing reports.

    People recruited to participate in the Small Group Discussions included tribal leaders, tribal management and technical staff with direct experience in the administration of Self Governance compacts, including financial managers, MIS directors, legal or regulatory analysts, program administrators and related positions. Sign-up sheets were provided prior to each group to make sure we had the appropriate mix of expertise in each session and adequate space to conduct each session.

    The Small Group Discussions occurred between September and November 2003.  Locations for these discussion groups included the annual consumer conference of the National Indian Health Board, September 29-October 2, 2003, in St. Paul, MN; the DHHS and DOI Tribal Self Governance Conference, October 6-10, 2003 in Palm Springs, CA; and. the annual convention of the National Congress of American Indians, November 16-21, 200, in Albuquerque, NM;   At both the NIHB and the DHHS/DOI Self Governance meetings, a separate room or break-out session was provided to conduct these discussions.  Rich and substantial qualitative data was collected during these sessions.  Less effective was the session conducted at the NCAI gathering, where this topic was one of several on a busy agenda.  Comment sheets were distributed but few turned in from the NCAI event.  The majority of comments reflected in this report are from the NIHB and the Self Governance meetings.

    Each discussion group involved 10 to 25 individuals representing a mix of interests and experiences from Tribes and Tribal organizations, including both Self-Governance and non-Self-Governance Tribes.  Individuals were recruited through fliers, inserts in conference packets or by appearing on the conference agenda as a workshop option. 

    Topic Areas and Prompt Questions:

    KAI staff facilitated these discussions.  An overview was provided and a written summary of the Draft Findings and Conclusions distributed for review. The following discussion guide was generally followed, however the flow of conversation generally centered upon three main topics:  (1) reaction to the draft findings and conclusions; (2) omissions in the draft; and (3) best outcomes for this feasibility study.  The following are the questions in the formal Discussion Guide:

    1. Facilitator will describe what this feasibility study did and did not do:
      • Facilitator will explain why this study was done. (purpose)
      • Facilitator will describe the difference between an evaluation feasibility study and an actual program evaluation.
      • Q & A regarding this overall study
    2. Identification of feasible alternatives for measuring success
      • Reaction to the options proposed for measuring success.
      • What other means exist to evaluate success?
      • How would this differ between IHS and other HHS programs?
    3. Facilitator will review the preliminary findings and recommendations
    • Do these preliminary findings and recommendations reflect your experiences with SG?  Give examples of why or why not.
    • What’s missing?
  • What is the best outcome from your perspective for this feasibility study?
    • How do you see these preliminary findings or recommendations impacting future opportunities to expand SG compacting to other programs of HHS?
    • How can this study help local planning for SG?
    • Any other comments?

    Comprehensive Evaluation Model

    Limited Evaluation Model

    Evaluation Using Aggregate Monitoring and Reporting Data

    New DHHS


    DHHS Health

    Obtaining Agreements to Participate


    Very Difficult



    Availability of Comparison Groups

    Possible but difficulties

    Possible but difficulties


    Patterns over time

    Data Availability

    Would require substantial new data requirements and primary data collection

    Most data required are available, some primary data collection necessary

    Would require some new data reporting

    Data are all currently being reported. No new data requirements



    Moderate to high


    Moderate to modest

    Trade-off between comprehensiveness and usefulness of results and costs

    Would produce reliable findings on a range of useful issues, but at high cost

    Could produce findings on a range of issues, at moderate cost

    Useful findings for a limited set of issues at moderate cost

    Limited findings at modest cost

    Chapter 7 - Summary and Discussion



    Appendix: Matrix of Issues and Concerns Raised at Discussion Groups At NIHB and DHHS/DOS 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, ie 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 feds have this either.


    The responsibility to secure baseline data from states/feds prior to SG must rest with Feds.


    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, ie 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..


    American Indian & Alaska Native People (AI-AN)
    Location- & Geography-Based Data
    Tribal Communities