Report to Congressional Requesters

United States General Accounting Office

GAO

July 2002 WELFARE REFORM

Tribal TANF Allows

Flexibility to Tailor

Programs, but

Conditions on

Reservations Make it

Difficult to Move

Recipients into Jobs

GAO-02-768
Page i GAO-02-768 TANF Welfare Reform

Letter 1

Results in Brief 2

Background 4

Despite Tribes’ Economic Development Efforts, Economic

Conditions on Reservations Remain Poor, and Tribes Lack Some

Key Factors for Economic Growth 7

Fewer American Indians Are Receiving TANF Nationally, but This

Trend Has Not Occurred on All Reservations 18

Flexibility Helps Tribal TANF Programs Meet TANF Requirements 24

Tribes Face Challenges Implementing Their Programs 32

Conclusions 38

Recommendations 39

Agency Comments 39

Appendix I Scope and Methodology 41

Site Visits 42

Appendix II Tribal TANF Programs 43

Appendix III Tribal TANF Work Activities 46

Appendix IV Comments from the Department of Health and

Human Services 50

Appendix V GAO Contacts and Staff Acknowledgments 53

GAO Contacts 53

Staff Acknowledgments 53

Tables

Table 1: Gaming and Other Sectors in Which Tribes Own

Enterprises and Provide Per Capita Payments 13

Table 2: Support Services not Available on Reservations 23

Table 3: State and Tribal TANF Program Adults Engaged in Work

Activities by Type of Activity 26

Contents
Page ii GAO-02-768 TANF Welfare Reform

Table 4: All Families Work Participation Rate Requirements for

Selected States and Tribes (FY 2000) 28

Table 5: Survey Numbers and Response Rates 41

Table 6:Activities That Count Toward Meeting Work Participation

Rate Requirements As Defined by Tribal TANF Programs 46

Figures

Figure 1: Number of Tribes That Reported Owning an Enterprise 8

Figure 2: Tribally Owned Enterprises 10

Figure 3: Counties with Predominantly American Indians Have

High Poverty Rates 14

Figure 4: Many Indian Reservations Are Isolated Geographically 16

Figure 5: Proportion of Cash Assistance Caseload Made Up of

American Indians 19

Figure 6: Self-Employed Navajo Artisan 22

Figure 7: Number of All Tribal TANF Programs Counting Various

Work Activities 25

Figure 8: Tribal TANF Program Service Areas 30

Figure 9: Tribal TANF Service Populations 31

Figure 10: Confederated Salish and Kootenai Tribe’s Mobile

Computer Training Center 35

Figure 11: Facilities Used for Tribal TANF Programs 36

Figure 12: Map of Federally Recognized American Indian Tribes,

Alaska Nonprofit Corporations, and Tribal TANF

Programs 44

Abbreviations

AFDC Aid to Families with Dependent Children

BIA Bureau of Indian Affairs

HHS Department of Health and Human Services

PRWORA Personal Responsibility and Work

 Opportunity Reconciliation Act

TANF Temporary Assistance for Needy Families
Page 1 GAO-02-768 TANF Welfare Reform

July 5, 2002

The Honorable Max Baucus

The Honorable Jeff Bingaman

The Honorable Kent Conrad

The Honorable Tom Daschle

The Honorable Daniel K. Inouye

United States Senate

Recognizing the sovereignty of American Indian and Native Alaskan

tribes,1

 the Congress included provisions in the 1996 Personal

Responsibility and Work Opportunity Reconciliation Act (PRWORA) that

give tribes the option to administer Temporary Assistance for Needy

Families (TANF) programs either alone or as part of a consortium with

other tribes rather than receiving benefits and services from state TANF

programs. Because of the difficult economic circumstances on many

reservations, the law also gives tribal TANF programs more flexibility than

it gives to states to design their programs to meet TANF requirements. To

date, the Secretary of Health and Human Services (HHS) has approved 36

tribal TANF programs, which serve over 170 tribes. These programs are

still in the early stages of implementation; half of the programs have been

operating for fewer than 3 years.

Although the welfare population, in general, and state TANF programs

have been widely studied, less is known about TANF recipients who are

American Indian, or about tribal TANF programs. To assist the Congress in

its deliberations concerning the reauthorization of PRWORA and in its

assessments of various proposals for changing the tribal TANF provisions

in the act, this report provides information on (1) the economic conditions

and the prospects for economic growth on reservations;2

 (2) how the

number of American Indians receiving TANF assistance has changed in

both state and tribal programs since the welfare reform law was enacted;

(3) how tribes have used the flexibility in PRWORA in administering tribal

TANF programs; and (4) challenges tribes face in implementing their tribal

TANF programs.

 1

 In this report, the term m American Indians refers to both American Indians and Alaska

Natives.

2

 In this report, the term “reservation” refers to all types of tribally owned land.

United States General Accounting Office

Washington, DC 20548
Page 2 GAO-02-768 TANF Welfare Reform

To obtain this information, we mailed a questionnaire to the TANF

program directors in each of the 34 states where at least one federally

recognized Indian tribe is based, the 36 tribal TANF programs, and the

remaining 334 federally recognized tribes.3

 We received responses from all

34 states (100 percent), from 28 of the 36 tribes with TANF programs (78

percent), and 124 of the 334 tribes (37 percent). Because of the relatively

low number of tribes responding, the results of our survey cannot be

generalized beyond the experiences of those tribes that responded.4

 We

also met with tribal leaders and program officials of 12 tribes in 5 states—

Arizona, Idaho, Montana, North Dakota, and South Dakota—as well as

state TANF officials in those states. Finally, we interviewed

representatives of American Indian organizations, as well as federal

officials from HHS’ Administration for Children and Families and the

Department of the Interior’s Bureau of Indian Affairs (BIA). We conducted

this review in accordance with generally accepted government auditing

standards. (See app. I for a more detailed description of our scope and

methodology.)

Tribes have used various strategies to stimulate economic development,

but despite these efforts, unemployment and poverty rates on reservations

remain high and prospects for economic growth may be limited. To

improve economic conditions on reservations, tribes operate enterprises

in a range of commercial sectors. While some tribes encourage private

companies owned by nonmembers to locate on their reservations, 87

tribes reported on our survey that they place more emphasis on promoting

tribally owned enterprises. However, not all tribally owned enterprises

generate substantial revenues. For example, contrary to the common

perception that all tribally owned casinos are highly profitable, few are

lucrative. Despite the tribes’ efforts to stimulate the economy on

reservations, most Indians living on reservations are poor and

unemployment rates are high. Fifty-seven tribes with reservations reported

 3

 We also sent surveys sent to the presidents of Alaska Native regional nonprofit

corporations. PRWORA limits the entities in the state of Alaska that may operate a TANF

program. The Metlakatla Indian Community of the Annette Islands Reserve and the 12

Alaska Native regional nonprofits are the only eligible entities.

4

 It should be noted that not all respondents to the survey answered every survey question

because not all questions applied to every respondent, and some respondents chose not to

answer one or more of the questions that did apply to them. As a result, there were often

fewer answers to individual survey questions than the total number of respondents to the

survey.

Results in Brief
Page 3 GAO-02-768 TANF Welfare Reform

that at least half of all families living on their reservations had incomes

below the federal poverty level. Prospects for improving the economic

conditions of families living on reservations may be limited because many

reservations lack some of the key factors shown to be associated with

economic growth, for example, a skilled workforce and easy access to

markets.

Nationally, the number of American Indian families receiving TANF

assistance has declined in recent years; however, in some states, American

Indians represent a large and increasing share of the state TANF caseload.

Furthermore, on some reservations, caseloads have remained constant or

even increased: 49 tribes with reservations reported that their caseloads

had stayed the same or increased over the past few years. Reasons for this

trend include the scarcity of jobs on reservations; the difficulty residents

have accessing work supports they need, for example, job training and

child care; and cultural or religious ties to tribal lands and strong ties to

families and communities that make it difficult for many American Indians

to relocate. In addition, like many other TANF recipients, many American

Indian TANF recipients have characteristics such as low education levels

and few job skills, which can make it difficult for them to get and keep

those jobs that are on reservations.

To date, 174 tribes, either alone or as part of a consortium, are

administering their own TANF programs and have used the flexibility in

PRWORA to tailor their tribal TANF programs to meet TANF

requirements. Some tribes have taken advantage of provisions that allow

them to define a wide spectrum of work activities to accommodate the

training needs and cultural traditions of their recipients. For example, to

encourage family formation, the Confederated Salish and Kootenai tribes

allow parenting and family strengthening activities to count as a work

activity. Tribal TANF programs have also used the flexibility in the law to

set their own work participation rate requirements, time limits, and

eligibility rules. Like states, the tribal TANF programs have also used their

flexibility to determine what work supports to provide to tribal recipients.

For example, the majority of tribes responding to our survey devoted

TANF funds to job training, work experience, and job search activities.

Tribes have faced a number of challenges in implementing tribal TANF

programs. Many tribes have found that TANF caseload and unemployment

data on American Indians is inaccurate, complicating the determination of

TANF grant amounts for tribal programs and making it difficult to design

and plan such programs. Tribes also lack infrastructure, such as

automated information systems, to administer their programs efficiently—
Page 4 GAO-02-768 TANF Welfare Reform

infrastructure states already had from administering previous welfare

programs. Tribes have had to rely on contributions from a variety of

different sources in addition to their basic TANF grants to cover tribal

TANF start-up costs and ongoing operating expenses. Finally, because

tribes lack experience administering welfare programs, they have turned

to both states and the federal government for assistance. However, tribes

have not received assistance in conducting feasibility studies that will

allow them to make informed decisions about administering tribal TANF

programs, nor do they have easy access to information about strategies

other tribes have used to engage recipients in productive work activities

given the economic conditions on reservations.

Tribal TANF programs are still in their early stages. So, it is not yet clear

whether the flexibility in program design provided to tribal TANF

programs alone will enable them to achieve TANF requirements given the

economic conditions on reservations. Consequently, we are

recommending that the Secretary of the Department of Health and Human

Services provide more assistance to tribes to ensure that they have the

information they need to make informed decisions regarding whether it is

feasible to administer tribal TANF and can draw on the experiences of

other tribal programs in designing their own programs.

The Congress passed PRWORA in 1996, making sweeping changes to

national welfare policy and placing new emphasis on the goal of work and

personal responsibility. The Congress recognized the unique economic

hardship facing the 40 percent of American Indians living on reservations

with high unemployment by effectively extending the law’s 60-month time

limit on receipt of TANF cash assistance.5

 Furthermore, the act gave

federally recognized American Indian tribes the option to administer their

own TANF programs either individually or as part of a consortium, an

option they did not have in the past. (See app. II for a list of tribal TANF

programs and a map showing their locations.) Under the Aid to Families

With Dependent Children (AFDC) Program, the precursor to TANF, tribal

members enrolled in state welfare programs.

 5

 PRWORA exempts any month from counting toward an individual’s time limit if that

individual is living on a reservation with a population of at least 1,000 and an

unemployment rate of 50 percent or greater, whether they are enrolled in a tribal or state

TANF program. Most states use the biennial statistics maintained by BIA.

Background
Page 5 GAO-02-768 TANF Welfare Reform

Under PRWORA, tribes implementing their own TANF programs have

greater flexibility than states in some areas. For example, for state

programs, PRWORA sets numerical requirements for the percentage of

adults to be participating in work activities and specifically defines the

approved work activities that count for the purposes of meeting these

federal participation rates.6

 The law set minimum requirements for state

work participation rates at 25 percent in fiscal year 1997, increasing to 50

percent in fiscal year 2002. In contrast, tribes can set their own

participation rate requirements and may define work activities more

broadly, subject to approval from HHS. Finally, while states must adhere

to a federal time limit on cash benefits of 60 months or less, tribal

programs can set their own time limits on welfare-related services, which

includes cash benefits. Tribes have the same flexibility as states to set

their own eligibility requirements and to determine what policies will

govern mandatory sanctions for noncompliance with program rules.

Tribes and states also have the same flexibility to determine what types of

work supports, such as child care, transportation, and job training, they

will provide to recipients.

Some of the requirements to which tribal TANF programs are subject

differ from those to which states are subject. For example, eligible tribes

must submit a 3-year tribal TANF plan directly to HHS for review and

approval; HHS does not approve states’ plans, though it certifies that they

are complete. Unlike states, whose TANF grants are based on the highest

of three possible funding formulas, tribal grants must be based on the

amount the state spent in fiscal year 1994 for all American Indians residing

in the tribe’s designated service area. In addition, tribes are not eligible for

several sources of additional TANF funding that were originally provided

for the states. These include performance bonuses, a population/poverty

adjuster (for high-population/low-spending states), and a contingency fund

for states experiencing economic downturns. Finally, whereas a state can

receive a caseload reduction credit, which reduces its work participation

rate requirement when its caseload falls, tribes are not eligible to receive

caseload reduction credits.

 6

 Approved activities include: unsubsidized employment, subsidized private or public sector

employment, work experience, on-the-job training, job search and job readiness assistance,

community service programs, vocational educational training, job skills training directly

related to employment, education directly related to employment, satisfactory attendance

at a secondary school or a course of study leading to a certificate of general equivalence, or

the provision of child care services to an individual who is participating in a community

service program.
Page 6 GAO-02-768 TANF Welfare Reform

The relationships of tribal TANF programs and state governments can be

ambiguous under the law. States have the option to include families being

served by tribal TANF programs or a tribal work program in their own

calculations of state TANF participation rates. Although states have no

formal role in the Tribal TANF plan approval process, tribes can enter into

partnerships with the states for additional funding and coordination of

services. However, the law is clear that the amount of the tribal grant is

subtracted from the state’s total grant, and the state’s maintenance-ofeffort (MOE) requirement is also reduced by a corresponding amount. 7

 In

addition, tribes have the option to “retro-cede” their program by returning

it to the state, although no tribe has yet exercised this option.

According to the 2000 Census, about 2.5 million U.S. residents identify

themselves as solely of American Indian or Alaska Native origin.

Furthermore, 1.6 million members are enrolled in about 560 federally

recognized tribes. American Indians are disproportionately poor. The

Census Bureau reports that during the period 1998 to 2000, about a quarter

of American Indians lived in poverty, more than double the rate of people

of all races.

Under U.S. law, federally recognized American Indian tribes—sometimes

referred to as nations, bands, pueblos, communities, rancherias, or

villages—are sovereign governments. The federal government has

financial obligations to tribes on the basis of treaties and overall trust

responsibility. As officially recognized sovereign entities, many tribes have

increasingly taken control of programs that serve tribal members. These

efforts have been supported by laws such as the Indian Self-Determination

and Education Assistance Act (P.L. 93-638), which permits the federal

government to contract with tribes to administer many services provided

to tribal members.

 7

 To receive a TANF block grant, each state must meet a MOE requirement, under which it

must spend at least a specified amount of its own funds. Under AFDC, state funds

accounted for 45 percent of total federal and state expenditures. Under PRWORA, the law

requires states to sustain 75 to 80 percent of their fiscal year 1994 level of spending on

welfare through the MOE requirement.
Page 7 GAO-02-768 TANF Welfare Reform

Tribes have used various strategies to stimulate economic development;

however, unemployment and poverty rates remain high on reservations.

To improve the economy on reservations, tribes own many types of

enterprises.8

 Despite these efforts, most Indians living on reservations are

poor, and many tribes lack some of the key factors research has shown to

be associated with economic growth on reservations.

Although some tribes encourage private companies owned by

nonmembers to locate on their reservations, many tribes responding to

our survey question place more emphasis on developing tribally owned

enterprises. Eighty-six tribes responding to our survey question reported

that they place more emphasis on promoting tribally owned enterprises

than on encouraging private companies owned by nonmembers to locate

on reservations.

Tribes have launched their own enterprises in a number of sectors, which

could include gaming, tourism, manufacturing, natural resources, and

agriculture or ranching (see fig. 1). Of the tribes with enterprises that

responded to our survey question, 21 have enterprises that are

concentrated in a single sector and 94 have enterprises in more than one

sector.

 8

 See U.S. General Accounting Office, Economic Development: Federal Assistance

Programs for American Indians and Alaska Natives, GAO-02-193 (Washington, D.C.: Dec.

21, 2001) for information on federal economic development programs for tribes and tribal

members.

Despite Tribes’

Economic

Development Efforts,

Economic Conditions

on Reservations

Remain Poor, and

Tribes Lack Some Key

Factors for Economic

Growth

Tribes Primarily Rely on

Developing Tribally Owned

Enterprises to Stimulate

the Economy on

Reservations
Page 8 GAO-02-768 TANF Welfare Reform

Figure 1: Number of Tribes That Reported Owning an Enterprise

Note: Tribes can own enterprises in multiple sectors.

Source: GAO survey of tribes.

In establishing enterprises, some tribes have drawn on their cultural and

land-based resources, others have concentrated on providing goods and

services to those living on the reservations, while still others have

embraced new technologies. The Nez Perce tribe in Idaho, historically

known for breeding Appaloosa horses, generates revenue for the tribe by

selling horses that they have crossbred between the Appaloosa and AkhalTeke, horses that are registered in the Nez Perce registry. The White

Mountain Apache tribe of Arizona charges hunters up to $19,500 for a

permit to hunt elk on its reservation. They also charge lesser amounts for

permits for fishing and camping on their land. In Montana, the Blackfeet

tribe operates the cable television service on the reservation. The tribe

also procures and delivers bottled water to the large number of residents

who do not have any access to potable water. The Cheyenne River Sioux

tribe in South Dakota operates the only telephone company serving the

reservation. Another tribally owned enterprise converts paper documents

into electronic media for outside businesses.

Number of tribes (n=116)

0

10

20

30

40

50

60

70

80

90

Gaming

Type of enterprise

87

56

45

50

19

53

Tourism

Agriculture/

ranching

Natural

resources

Manufacturing

Other
Page 9 GAO-02-768 TANF Welfare Reform
Page 10 GAO-02-768 TANF Welfare Reform

Figure 2: Tribally Owned Enterprises

Nez Perce Tribe, horse registry
Page 11 GAO-02-768 TANF Welfare Reform

San Carlos Apache tribe, sawmill

Confederated Salish and Kootenai Tribes, Flathead Stickers, a subsidiary of S&K Holding 

Company, specialty wood products
Page 12 GAO-02-768 TANF Welfare Reform

Many tribes own and operate gaming facilities, and they vary in size and

the amount of revenue generated. Some facilities, such as the Coeur

d’Alene facility in Idaho, are part of a hotel and restaurant complex, while

others, like the Assiniboine and Sioux Tribes on the Fort Peck reservation

in Montana are part of a convenience store. Contrary to the common

perception that tribal gaming has dramatically improved the economic

circumstances for many tribes, the most lucrative facilities account for a

small percentage of all tribally owned gaming facilities. According to our

2001 report, in 1999, 27 of the 193 tribes that operated gaming facilities

generated two-thirds of total gaming revenue.9

 For example, the Coeur

d’Alene gaming facility, near Spokane, Washington, and Lake Coeur

d’Alene, a major tourist area, has generated profits for the tribe. In

contrast, officials from the San Carlos Apache Tribe indicated that its

gaming facility, located in a remote area, 90 miles from Phoenix, Arizona,

barely makes enough money to cover its costs. Furthermore, gaming

facilities do not always generate employment for tribal members.

Nationally, only a quarter of all jobs in tribally operated gaming facilities

are held by American Indians.10

The practice of distributing gaming royalties to tribal members is not

widespread and, contrary to common perception, payments that are made

are not making tribal members wealthy. About a quarter of the tribes that

responded to our survey question distributed a portion of their revenues

from gaming facilities and other enterprises through per capita payments

to members. Of the tribes that reported operating a gaming facility, 28

reported providing per capita payments to members. Of those, 16 provided

payments of less than $5,000 (see table 1).

 9

 See U.S. General Accounting Office, Indian Issues: Improvements Needed in Tribal

Recognition Process, GAO-02-49 (Washington, D.C.: Nov. 2, 2001).

10 National Indian Gaming Association data.
Page 13 GAO-02-768 TANF Welfare Reform

Table 1: Gaming and Other Sectors in Which Tribes Own Enterprises and Provide Per Capita Payments

Amount of annual per capita payment

Gaming and other sectors

No. of

 tribes

No. of tribes

with payments <$500

$500-

1,499

$1,500 -

4,999 $5,000+

No enterprises 28 1 0 0 1 0

Gaming only 10 1 0 0 1 0

Gaming and one or more enterprises in

other sectors

77 27 3 8 4 12

One or more enterprises in sectors other

than gaming, but no gaming

28 2 2 0 0 0

Total 143 31 5 8 6 12

Source: GAO survey of tribes.

Despite tribes’ efforts to stimulate the economy on reservations, American

Indian families on reservations still have high poverty rates. Fifty-seven

tribes with reservations that responded to our survey question reported

that at least half of all families living on their reservations had incomes

below the federal poverty level.11 Poverty rates are also high among

Indians who are employed and living on or near reservations. According to

BIA (the only regularly collected source of poverty and unemployment

data on all U.S. reservations), one-third of employed tribal members had

incomes below the federal poverty level in 1999—the most recent year for

which data are available. Three-fourths of the tribes with reservations

responding to our survey question indicated their level of poverty had

remained the same or increased since 1996.12

Census data on reservations and county-level data show that poverty rates

are high in counties where the population is predominately American

Indian. For example, as shown in figure 3, for the 26 counties with a

majority of American Indians—all of which have a reservation or Alaska

 11 In 2001, the federal poverty guideline in the contiguous 48 states was $14,630 for a family

of three.

12 Census data show that the poverty rate for American Indians did not significantly change

from 1998 to 2000, whereas the poverty rate for other racial groups significantly decreased.

The Current Population Survey regularly collects national data on demographics, labor

force, and income from a representative national sample, including Indians. Although the

sample of American Indians is too small to allow the data to be projected to the entire

Indian population, reliable estimates of some measures can be obtained by averaging data

over 3 years. People who are jobless, looking for jobs, and available for work are

considered unemployed. See also Poverty in the United States: 2000, Current Population

Reports, Consumer Income (Washington, D.C.: U.S. Census Bureau), Sept. 2001. Data taken

from the years 1999-2000 and 1998-1999.

Despite Economic

Development Activities,

Indians Living on

Reservations Continue to

Have High Poverty and

Unemployment Rates
Page 14 GAO-02-768 TANF Welfare Reform

Native entity—the median poverty rate is over 32 percent, or twice the

median poverty rate of 14 percent for counties nationwide.

Figure 3: Counties with Predominantly American Indians Have High Poverty Rates

Source: U.S. Census Bureau.

BIA reports unemployment rates on reservations are extremely high.13 In

1999—the most recent year for which data are available—more than 40

percent of adults living on or near reservations between the ages of 16 and

64 were unemployed.14 According to our survey and site visits,

 13 Different methods can produce widely different rates, depending on how they define

“unemployed.” CPS uses the number of people actively searching for employment, not just

those who are unemployed. BIA calculates the number of unemployed Indians for each

reservation by subtracting the number of adults employed from the tribe’s service

population who were available for work.

14 BIA asks tribes to provide estimates on their enrolled members and members from other

tribes who lived on or near their reservations and who were eligible to use the tribe’s BIAfunded services (termed “service population”). Because tribes may not follow the same

methodology when collecting and reporting the data, the quality of the data among tribes

could vary.

0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

45.0

50.0 Poverty rate

County (state)

Ziebach (SD)

Todd (SD)

Shannon (SD)

Apache (AZ)

Wade Hampton (AK)

Buffalo (ND)

Sioux (ND)

Corson (SD)

Bennett (SD)

McKinley (NM)

Glacier (MT)

Mellette (SD)

Bethel (AK)

Dewey (SD)

Roosevelt (MT)

Rolette (ND)

San Juan (UT)

Big Horn (MT)

Dillingham (AK)

Lake (AK)

Menominee (WI)

Nome (AK)

Yukon-Koyukuk (AK)

Thurston (NE)

Northwest Arctic (AK)

North Slope (AK)

All U.S. counties (3140)
Page 15 GAO-02-768 TANF Welfare Reform

unemployment rates on reservations have changed little over time. Ninetyfour tribes reported that the unemployment rate was the same or higher

than in 1996. In addition, according to tribal officials of the Standing Rock

Sioux tribe in North Dakota, about 75 percent of all adults were not

employed, a figure that had not changed in the last several years. Tribal

officials at the Fort Peck reservation in Montana said 60 to 70 percent of

their adults were not employed; according to BIA, the unemployment rate

has been high since 1995.

Many tribes lack some of the key factors shown to be important for

economic growth on reservations. Some tribal officials we spoke with

identified a lack of accessibility to population centers, a limited number of

workers with appropriate skills and expertise, and inadequate physical

infrastructure as barriers to economic development on their reservations.

In addition, research has shown that certain political and organizational

factors such as a strong sense of sovereignty, effective governing

institutions, and development of a long-term economic strategy can also

affect the prospects for economic growth on reservations.

Tribal officials we talked with said that a lack of education and job skills

among workers living on the reservation hinders economic growth. For

example, a modular home manufacturing plant on the Blackfeet

Reservation in Montana has had trouble finding and keeping enough

workers with construction skills to expand its business. To overcome this

obstacle, the enterprise has worked with the local community college to

offer construction training to tribal members on the reservation. The

gaming facility owned by the White Mountain Apache tribe had to hire

nontribal members. Because tribal members lack the basic work and life

skills needed to hold such jobs, tribal officials said that nonmembers hold

most of the better-paid jobs.

Furthermore, the isolated geographic location and distance from markets

of many reservations limits their access to markets and makes it difficult

for many businesses to operate successfully. Of the tribes that responded

to our survey question, 133 indicated that their reservation was primarily

rural or isolated. Some reservations, such as the Navajo reservation, take

up millions of acres and span more than one state. The communities on

some reservations can be extremely isolated. For example, tribal members

on the Fort Peck reservation had to drive 70 miles to shop for clothing and

other household necessities. On the White Mountain Apache reservation,

tribal officials said that the road to one isolated community, the village of

Cibecue, “doesn’t go anywhere, it just ends at Cibecue.”

Many Tribes Lack Key

Factors Associated with

Economic Growth
Page 16 GAO-02-768 TANF Welfare Reform

Figure 4: Many Indian Reservations Are Isolated Geographically

Road to Hopi reservation

View of Navajo reservation from Hopi reservation

Hopi reservation

Road to Cibecue, White Mountain Apache reservation
Page 17 GAO-02-768 TANF Welfare Reform

The physical infrastructure—such as roads, electricity, water, and suitable

land for building—that is necessary to navigate remote areas or build

enterprises does not exist on many reservations and hinders many

potential economic development efforts. For example, even large

reservations, such as the Cheyenne River Sioux, lack paved roads and

water and sewer services in some communities. In addition, areas on some

reservations lack electricity and telephones. The Nez Perce Reservation in

Idaho has a shortage of land that is suitable for building facilities because

much of their land is in a flood plain.

Research has shown that other factors, including fully exercised

sovereignty, effective governing institutions, and a strategic orientation,

are also important for economic growth on reservations. 15 Tribes with a

strong sense of sovereignty fully exercise the authority that comes with

sovereignty—controlling and being accountable for use of their resources.

Governing institutions that are effective usually make decisions that are

consistent with tribal culture and have separate structures for making

business decisions and decisions regarding tribal governance.16 Tribes with

a strategic orientation have a formal approach for focusing on developing

and accomplishing long-term economic development goals. Successfully

integrating these factors has been shown to help tribes create an

environment that is attractive and conducive to stimulating and sustaining

economic development efforts. However, the extent each of these factors

is present in tribes varies. For example, 56 of the tribes that responded to

our survey question do not appear to have taken a formalized approach to

economic development since they did not have a written plan for

improving economic conditions on the reservation. In addition, 78 said

their tribe did not have an economic development committee or

organization that is separate from their tribal government, even though

research has shown that skilled business people are the best ones to make

business decisions, free from the interference of tribal leadership.

 15 Eddie F. Brown, D.S.W., Stephen Cornell, Ph.D., et al., Welfare, Work, and American

Indians: The Impact of Welfare Reform: A Report to the National Congress of American

Indians (Nov. 27, 2001).

16 Culturally appropriate decision-making processes reflects a cultural match between

governing institutions and the prevailing ideas in the community about how authority

should be organized and exercised. For example, although having a centralized system of

government with a strong executive branch works well for Apache tribes, which have a

tradition of electing their leaders, this form of government may not hold the same

legitimacy among members of tribes that traditionally had more decentralized

governments.
Page 18 GAO-02-768 TANF Welfare Reform

Nationally, the number of American Indian families receiving cash

assistance decreased between 1994 and 2001. However, in some states, the

proportion of the TANF caseload made up of American Indian families has

increased. Furthermore, on some reservations, the number of families on

TANF has remained the same or even increased due to the scarcity of jobs

and other reasons.

The number of American Indian families receiving cash assistance in state

TANF programs in the 34 states with federally recognized Indian tribes

decreased between 1994 and 2001, from almost 68,000 to about 26,000.17

Part of this decline occurred because many American Indian TANF

recipients were served by tribal TANF programs in 2001 and are not

included in the data. While data on tribal TANF program caseloads are not

available for 2001, tribes have estimated that they could be serving as

many as 22,000 families. Even if those participating in tribal TANF

programs were taken into account, the decline in American Indian families

receiving TANF of at least 30 percent is significant. In comparison, the

number of all families receiving TANF dropped by over half from about 3.4

million families in 1994 to about 1.5 million in 2001.

In some states, the share of the caseload made up of American Indians has

risen. According to HHS data, the share of the TANF caseload made up of

American Indians increased in 6 of the 34 states with federally recognized

tribes.18 As shown in figure 5, the increase has been greatest in South

Dakota, Montana, and North Dakota. In South Dakota, the proportion of

cash assistance families that were American Indian increased from about

60 percent in 1994 to about 80 percent in 2001. According to the 2000

 17 HHS did not report American Indian caseload data for 1994 for states without a federally

recognized tribe.

18 In Idaho, Iowa, Kansas, Nevada, South Carolina, and Texas, the share of the TANF

caseload made up of American Indians increased by less than 1 percent between 1994 and

2001. Insufficient data were provided to calculate the change in proportion for three states:

Alabama, Florida, and Indiana.

Fewer American

Indians Are Receiving

TANF Nationally, but

This Trend Has Not

Occurred on All

Reservations

The Number of American

Indian Families Receiving

Cash Assistance Has

Decreased

In Some States, American

Indians Represent an

Increasing Proportion of

TANF Families
Page 19 GAO-02-768 TANF Welfare Reform

census, about 8 percent of South Dakota’s population were American

Indians.19

Figure 5: Proportion of Cash Assistance Caseload Made Up of American Indians

Source: HHS.

Because many tribes on reservations reported to us that their TANF

caseloads had stayed the same or increased, it is likely that the decline in

the number of American Indians receiving TANF has predominantly

occurred among those not living on reservations, who represent a majority

of all American Indians. Forty-seven tribes with reservations responding to

 19 It should be recognized that the race of TANF recipients recorded on their applications

may not always be accurate. TANF applicants are not required to disclose their race, and

often the caseworker judges the race of the recipient for reporting purposes, which may

lead to misidentification. Furthermore, according to an HHS official, until recently, at least

one state’s TANF application only listed categories for whites, blacks, and Hispanics.

On Some Reservations,

TANF Caseloads Have

Stayed the Same or

Increased

Percent

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

Minnesota

Montana

Nebraska

North Dakota

South Dakota

Wyoming

5.9

9.4

28.7

45.2

6.1 7.8

41.4

54.9 57.3

78.2

10.7

16.0

1994

2001
Page 20 GAO-02-768 TANF Welfare Reform

our survey question reported that the number of tribal members receiving

TANF was about the same size or larger than it had been in 1997. The Salt

River community in Arizona attributed the slight increase in their TANF

caseload at least in part to tribal members returning to the reservation as

they approached the 24-month time limit in the state’s TANF program

(their tribal TANF program has a 60-month limit). The Sisseton-Wahpeton

Sioux tribe, headquartered in South Dakota, indicated that its caseload has

remained about the same because, even though about 80 percent of the

original tribal TANF recipients were no longer receiving TANF, new

families keep coming on the rolls. The Coeur d’Alene tribe in Idaho

indicated that the number of cases had actually increased since their tribal

TANF program began because of its tribal TANF program’s outreach

efforts.

Several factors may contribute to the lack of welfare caseload decline

among American Indians in certain places. These include the scarcity of

jobs on reservations; the difficulty reservation residents have accessing

work supports, such as job training and child care; and cultural or

religious ties to tribal lands and strong ties to families and communities

that make it difficult for many American Indians to relocate. In addition,

like many other TANF recipients, many American Indian TANF recipients

have characteristics such as low education levels and few job skills, which

can make it difficult for them to get and keep jobs.

Government officials, tribal representatives, and researchers all reported

that on reservations the primary impediment to decreasing the number of

American Indians on TANF is the scarcity of jobs. Navajo Tribal TANF

officials indicated that while thousands of Navajos have left the

reservation and found employment elsewhere, lack of jobs is still the

major hurdle to achieving TANF requirements. Recent studies concluded

that job scarcity in Indian country is an overwhelming barrier to the

success of employment and job training programs, including TANF, and

that the lack of jobs on many reservations is a serious handicap to moving

people from welfare to work.20,21

 20 Brown, Eddie F. et al., Welfare, Work, and American Indians: the Impact of Welfare

Reform, Nov. 27, 2001.

21 Hillabrant, Walter et al., The Evaluation of the Tribal Welfare-to-Work Grants Program:

Initial Implementation Findings, Mar. 2002.

Several Factors May

Contribute to Lack of

Caseload Decline

Scarcity of jobs on reservations
Page 21 GAO-02-768 TANF Welfare Reform

On many reservations, the government sector is the primary employer.

Consistent with the philosophy of promoting self-governance, during the

last 30 years tribes have taken over reservation programs that used to be

performed by the federal government. As management responsibility was

transferred, the number of government sector jobs grew rapidly as tribes

hired more people to manage health, social, and housing programs and

schools. Although nationally, less than 20 percent of workers are in public

sector jobs, the tribes we surveyed reported that, on average, about 42

percent of employed tribal members work for federal, state, county, and

tribal governments. The tribes we surveyed reported that, on average, 25

percent of employed tribal members worked for tribal governments;

however, in some cases this percentage was much higher. About onefourth of the tribes responding to our survey question reported that 50

percent or more of their employed tribal members worked for the tribal

government. Many tribal members are also employed by state or federal

government agencies. For example, in the summer BIA hires American

Indians to work as firefighters.

As noted previously, many tribes are also attempting to operate

commercial enterprises, but these initiatives have been at best only

moderately successful in generating jobs. On average, the tribes

responding to our survey reported that an average of 11 percent of

employed tribal members were employed by tribally owned commercial

enterprises.

Few private sector opportunities exist on reservations. Tribes responding

to our survey reported that, on average, 40 percent of their employed tribal

members worked for privately owned commercial enterprises. An

additional 4 percent of employed tribal members were self-employed. This

lack of private sector opportunities appears to be the result of a lack of

private sector commercial activity on reservations. What little commercial

activity there is generates few jobs. Sixty-nine tribes reported that no

private sector enterprises employing 15 or more workers existed on or

within 10 miles of their tribal lands. A consultant’s study of the Standing

Rock Sioux Reservation, which straddles the border of North and South

Dakota, reported that in 1999 only 34 private employers operated on the

reservation: they employed only 85 full-time workers. BIA reports that in

1999 over 5,000 adult tribal members were available for work on or near

the Standing Rock Sioux Reservation. Similarly, as of 1997, the Navajo

Nation reported only 52 employers with 100 employees or more, most of

which were schools or hospitals; the Navajo Nation considered only 13 to

be “genuine businesses.” These 13 establishments employed about 4,700
Page 22 GAO-02-768 TANF Welfare Reform

workers; the Navajo Nation reported its potential labor force at over

50,000.

Figure 6: Self-Employed Navajo Artisan

Many jobs that are available to tribal members are seasonal. For example,

Glacier National Park sometimes hires members of the Blackfeet

reservation for the peak tourist season. Forty-five tribes reported that

about half or more of the jobs held by tribal members were seasonal; only

22 reported that all or almost all jobs held by tribal members were yearround.

Finally, federal, state, and tribal officials that we spoke with reported that,

due to cultural or religious ties to tribal lands and strong ties to families

and communities that make it difficult for many American Indians to

relocate, substantial numbers of tribal members choose not to leave tribal

lands to obtain employment. Under federal law, American Indian tribes are

sovereign nations, and American Indians are citizens of those nations in

addition to being U.S. citizens.

In some cases, TANF recipients on reservations do not have easy access to

services they may need to enable them to obtain employment, including

transportation, child care, job training, job search services, and

educational programs. While most tribes that have opted to administer

Lack of access to work

supports
Page 23 GAO-02-768 TANF Welfare Reform

their own TANF programs have these types of services available on their

reservations, a significant number of tribes that are served by state TANF

programs do not have certain services available on their reservations (see

table 2).

Table 2: Support Services not Available on Reservations

Service

Tribes without TANF programs

reporting service not available

on reservation

Transportation 42

Child care 23

Classes/tutoring in reading 21

Classes/tutoring in English language skills 31

Other education: GED or high school diploma 28

Training for particular job 41

Work experience programs 31

Job search, screening/assessment, and other employment

services

40

Treatment for alcohol or substance abuse 26

Other mental health services 27

Source: GAO survey.

Like other TANF recipients, some American Indian TANF recipients have

characteristics that make it difficult for them to get and keep jobs. In a

previous report, we found that research has shown that a substantial share

of TANF recipients have characteristics that make employment difficult,

such as substance abuse, poor mental or physical health, disability, low

educational attainment, limited work experience, low basic skills, or

exposure to domestic violence. 22 Tribes that responded to our survey

reported that many American Indian TANF recipients share these

characteristics. For example, 29 tribes that responded to our survey

reported that more than 40 percent of their recipients needed mental

health services, and 43 tribes reported that more than 40 percent of their

recipients needed education to receive a high school diploma or

equivalency.

Tribal officials we met with during our site visits also noted that many of

their recipients had characteristics that impede employment. For example,

 22 U.S. General Accounting Office, Welfare Reform: Moving Hard to Employ Recipients

Into the Workforce, GAO-01-368 (Washington, D.C.: Mar. 15, 2001).

Characteristics that impede

employment
Page 24 GAO-02-768 TANF Welfare Reform

social service workers from the Salt River Pima-Maricopa Indian

Community of Arizona reported that almost none of their TANF recipients

had a high school diploma, and some are only reading at the third or fourth

grade level. Consequently, the primary work activity for most of their

recipients is education. Similarly, officials from the San Carlos Apache

tribe of Arizona reported that 80 percent of their TANF recipients had not

finished high school, and many were reading at the elementary school

level. Both the Salt River Pima-Maricopa Indian Community and the Nez

Perce tribe of Idaho reported that their residents have high rates of

diabetes. Not only is diabetes a health problem for adults, but also the high

incidence of the disease among their children increases the difficulty of

finding appropriate child care. The Sisseton-Wahpeton Sioux tribe,

headquartered in of South Dakota, found that about one-third of TANF

applicants assessed had alcohol dependency problems. Although the tribe

has a treatment facility, tribal officials said that it has only 12 slots for

inpatient care, which these officials deem insufficient.

PRWORA gives tribal TANF programs flexibility in many areas to tailor

their programs to their communities, for example, by defining their own

work activities and work participation rate requirements, time limits, and

eligibility requirements. Twenty-two tribal TANF program administrators

reported that the flexibility greatly influenced their tribe’s decision to take

on the responsibility of administering the program. Some tribes have taken

advantage of provisions that allow them to define a wide spectrum of

work activities to accommodate the training needs and cultural traditions

of their recipients. Others have modified the rules and procedures

governing work participation rate requirements, time limits, and eligibility.

Like states, they have also used their flexibility to determine what

supports to provide to tribal recipients.

The 36 tribal TANF programs are given the flexibility to define the

activities they count toward meeting the work participation requirement

more broadly than state TANF programs, subject to approval by HHS.

According to data provided by tribal TANF programs to HHS, about a fifth

of all adults engaged in work activities participate in activities that would

not count toward meeting work participation rate requirements under

state plans (see fig. 7), but do count toward meeting work participation

requirements under tribal programs. For example, the Port Gamble

S’Klallam tribe, whose reservation is located on Washington’s Puget

Sound, allows recipients to count time spent engaged in traditional

subsistence gathering and fishing towards meeting the TANF work

Flexibility Helps

Tribal TANF

Programs Meet TANF

Requirements

Tribes Use Flexibility to

Define a Broader Array of

Work Activities than States
Page 25 GAO-02-768 TANF Welfare Reform

requirement. (See app. III for the work activities accepted by each tribal

TANF program.)

Figure 7: Number of All Tribal TANF Programs Counting Various Work Activities

a

Participation in tribal Native Employment Works (NEW) program, a tribally administered work

activities program.

Source: HHS.

In general, rather than adopting an approach similar to most states that

emphasizes job search and work,23 tribal TANF programs tend to

encourage recipients to engage in alternative work activities. In fiscal year

2001, 43.2 percent of adults enrolled in state TANF programs were

engaged in work activities. In comparison, HHS has reported that in fiscal

year 2000, the overall work participation rate for all families in tribal TANF

programs averaged about 37 percent. As shown in table 3, a majority of

adults enrolled in state TANF programs who were engaged in work

activities, 60 percent, were in unsubsidized jobs. In contrast, only a third

of adults engaged in work activities in tribal TANF programs were in

 23 This approach is often referred to as “work first.”

Number of tribes

0

2

4

6

8

10

12

14

16

14

12

9

7 7

4

3

1

13

Cultural

Activites

Counseling/

Treatment

Self-Employment

Life Skills/

Parenting

Subsistence

Activites

Post-secondary

NEW

Commuting

Time

Same as

PRWORA

 Education

Participationa
Page 26 GAO-02-768 TANF Welfare Reform

unsubsidized jobs. Relative to state TANF programs, tribal TANF

programs have more adults engaged in job search, job training, education,

and other activities, many of which are not counted toward meeting work

participation rate requirements under state TANF programs.

Table 3: State and Tribal TANF Program Adults Engaged in Work Activities by Type

of Activity

Activity

State TANF programs

FY 2001 (percent)

Tribal TANF programs

FY 2000 (percent)

Unsubsidized employment 60.0 33.2

Work preparationa15.7 17.6

Job search/job readiness 14.4 29.1

Job training/education 17.6 28.1

Otherb10.6 21.7

a

Includes subsidized jobs, on-the-job training, work experience, and community service activities.

b

Includes activities allowed under state waivers, activities allowed under tribal TANF plans, and

provision of child care.

Source: HHS.

Officials from several of the tribes we visited reported that their tribal

TANF programs emphasize education and training activities because only

a small proportion of recipients have completed high school and many

lack basic literacy skills. Tribes emphasize education and training

activities to varying degrees. For example, the White Mountain Apache

tribal TANF program reported that a quarter of their adult TANF recipients

were enrolled in classes to enable them to get a high school diploma or its

equivalent, and a fifth were receiving employment services intended to

help them move directly into employment. In contrast, the Confederated

Salish and Kootenai tribal TANF program required all adult recipients to

engage in job search while only 5 percent of recipients were enrolled in a

high school equivalency program.

More than 20 percent of tribal TANF recipients were engaged in activities

that are counted as work by tribes but which generally are not approved

work activities for state programs. While not all of the activities tribes

count as work lead directly to private sector employment, they may have

other benefits. Tribal officials believed that individual TANF recipients as

well as reservation communities as a whole benefited when tribal TANF

recipients were allowed to participate in alternative work activities. For

example, tribal TANF recipients who participated in cultural activities

helped to strengthen community ties and preserve tribal traditions.

Likewise, community service projects can engage TANF recipients who
Page 27 GAO-02-768 TANF Welfare Reform

have never held a regular job in a meaningful activity that provides a

valuable service to the community. Some examples of tribal TANF work

activities include: the delivery of potable water to elderly tribal members

on the Navajo reservation, working at the local Head Start program on the

Nez Perce reservation, and participating in parenting and family

strengthening courses in the Confederated Salish and Kootenai tribes on

the Flathead reservation.

Tribes have used the flexibility in the law to set their own work

participation rate requirements and to determine the number of hours

recipients must work each week to meet those requirements, with HHS

approval. Whereas states had to ensure that 25 percent of all families

enrolled in TANF were engaged in federally counted work activities in

1997, increasing to 50 percent in fiscal year 2002, tribes could set

participation rate requirements that differed from those of states. Most of

the tribal TANF programs set their participation rate requirements

somewhat lower than those of states, generally ranging from 15 to 30

percent over the first few years of the program. Four tribal TANF

programs adopted the same participation rate requirements as states.

Unlike states, tribes are not eligible for caseload reduction credits—

reductions in the work participation rate they are required to meet when

their total TANF caseload drops. Tribes, however, must always meet the

participation rate requirements laid out in their TANF plans, no matter

how great the decline in tribal TANF caseloads. In fiscal year 2000, 7 of the

15 states with tribal TANF programs had effective work participation rate

requirements (after the caseload reduction credit was applied) of zero, and

7 more had rates of 15 percent or less. Table 4 compares the participation

rate requirements for fiscal year 2000 in the seven tribal TANF programs in

the four states that we visited.

Tribes Use Flexibility to

Set Work Participation

Rate Requirements
Page 28 GAO-02-768 TANF Welfare Reform

Table 4: All Families Work Participation Rate Requirements for Selected States and Tribes (FY 2000)

State work participation rate requirement Tribal TANF work participation rate requirement

State

Rate required by

PRWORA Sec.

407(a) Effective rate Tribe Actual rate

Arizona 40 0 Navajo Nation (Ariz., N. Mex., Utah) a

White Mountain Apache Tribal Council

(Ariz.)

25b

Salt River Pima-Maricopa Indian Community

Council (Ariz.)

20

Idaho 40 0 Coeur d’Alene Tribal Council 15

Nez Perce Tribal Executive Committee 20

Montana 40 0 Confederated Salish & Kootenai Tribes,

Tribal Council

15

South Dakota 40 3 Sisseton-Wahpeton Sioux Tribal council 25b

a

The Navajo Nation TANF Program had not yet started in fiscal year 2000.

b

Single parent family requirement. Tribal plan does not have an all family requirement.

Source: HHS.

Tribes also have the flexibility to set the minimum number of hours each

week participants must be engaged in work activities. A majority of tribal

programs, 30 of the 36, require participants to work 20 or more hours per

week. This is similar to the state requirement, which began at 20 hours per

week in 1997 and increased to 30 hours per week by 2000.

Tribal TANF programs have flexibility to set their own time limits, subject

to HHS approval. Many tribal TANF recipients living on reservations are

not subject to time limits, however, when the unemployment rate on their

reservation is greater than 50 percent. Specifically, PRWORA exempts any

month from counting toward an individual’s time limit if that individual is

living on a reservation with a population of at least 1,000 and an

unemployment rate of 50 percent or greater, whether they are enrolled in a

tribal or a state TANF program. Of the 29 tribal TANF programs that serve

a single tribe, 16 are located on reservations that had unemployment rates

of 50 percent or greater, according to the most recent BIA data.24 To date,

HHS has not approved any tribal TANF plans with a time limit of greater

 24 Our analysis does not include tribal coalitions that serve residents of more than one

reservation. Of the remaining 13 tribal programs that serve residents of one or two

reservations, 6 have unemployment rates of 40 to 49 percent and 6 have unemployment

rates of 20 to 39 percent.

Tribes Set Time Limits and

Exemption Levels That

Differ from Those of States
Page 29 GAO-02-768 TANF Welfare Reform

than 60 months, although at least one tribe has submitted a plan proposing

a longer time limit. Thirty-four of the 36 tribal TANF programs have time

limits of 60 months; 2 programs have 24-month time limits. While a state

may exempt no more than 20 percent of its caseload from time limits due

to hardship, tribal programs have the flexibility to determine the share of

the caseload they are allowed to exempt from time limits due to hardship.

A majority of tribal TANF programs have the same exemption limit as

states, but HHS has approved 10 plans with higher exemption rates. If

tribes want to extend benefits beyond the level approved in their plans,

they must pay for the benefits with their own funds.25

Tribal TANF programs also have the flexibility to determine many of their

own eligibility requirements. This includes the flexibility to determine the

geographic area their TANF program will cover (the service area). Some

tribes define their service area as their reservation or land base, while

others serve families residing in nearby communities or within the

counties that overlap with their reservations (see fig. 8).

 25 States may use their MOE funds to extend benefits to recipients who reach their time

limits but do not fall within the 20-percent exemption. Tribes do not have a MOE

requirement and, therefore, do not have the same access to funding for this extension.

Tribes Have Flexibility to

Set Their Own Eligibility

Requirements
Page 30 GAO-02-768 TANF Welfare Reform

Figure 8: Tribal TANF Program Service Areas

Source: HHS.

Tribes also have the flexibility to determine whom they will serve (the

service population). Some tribes base eligibility on race or tribal

membership; others serve all families in their service areas. Figure 9

shows the populations tribal TANF programs have chosen to serve.

Number of tribes

0

5

10

15

20

25

Reservation

Surrounding County

or Counties

BIA Defined

Alaskan Regional

10

21

2

3

Only

Service Area

Corporation Area
Page 31 GAO-02-768 TANF Welfare Reform

Figure 9: Tribal TANF Service Populations

Source: HHS.

Like states, tribal TANF programs have the flexibility to use their TANF

grant to fund services they determine necessary to help recipients comply

with program requirements. Although they have the same range of options

available to states, tribal priorities and resources influence decisions

about what services tribes fund with their TANF grants. A majority of

tribes responding to our survey (18 of 24 programs) devoted TANF funds

to job training, work experience, and job search activities as well as one or

more educational programs. Most (21 of 24 programs) also used TANF

funds for child care or transportation.

In some instances, services were not funded with a tribal TANF program’s

TANF grant because the services were available through other programs

or funding sources. Tribal NEW grants can cover some work-related

activities such as job search. In addition, tribes responding to our survey

question reported that services ranging from transportation and child care

to education, work preparation, health care and treatment were funded

through federal programs or state programs other than TANF, grants to

tribes and tribal revenues.

Tribes Have the Same

Flexibility as States to

Determine Work Supports

Number of tribes

0

2

4

6

8

10

12

14

16

18

16 16

4

Serves only

tribal members

Serves all

Indian families

Serves all

families
Page 32 GAO-02-768 TANF Welfare Reform

Tribes have faced a number of challenges in implementing tribal TANF

programs. Many tribes have found that data on the number of American

Indians are inaccurate, complicating the determination of tribal TANF

grant amounts and making it difficult to design and plan programs.

Because tribes do not have the infrastructure they need to start their

programs, they have had to solicit contributions from a variety of different

sources to cover their significant start-up costs and ongoing operating

expenses. In addition, they lack the expertise needed to administer key

program features, including determining eligibility because tribes do not

have experience operating welfare programs. Some tribes have requested

and received technical assistance from states and the federal government

to help them develop this expertise.

The challenges tribes have to overcome in order to plan, develop, and

implement tribal TANF programs include, among others:

• Obtaining The Population Data Necessary To Conduct Reliable

Feasibility Studies And To Plan And Design Tribal TANF Programs.

HHS and tribal officials indicated that state data on American Indians is

inaccurate, complicating the determination of TANF grant amounts and

making it difficult to design and plan programs. The law specifies that

federal tribal TANF grants must be based on the funds expended on

American Indians who were residing in the program’s designated service

area and receiving AFDC from the state in fiscal year 1994. In practice,

however, few states collected reliable data on the race of AFDC recipients

in 1994, so some tribes work with the state to negotiate a mutually

agreeable number on which their grant will be based, according to tribal

officials.26,27 Having accurate data on American Indian caseloads is also

critical for tribes as they design their programs and make decisions about

how to allocate their resources.

The information they use to estimate the 1994 caseload varies by tribe and

by state. In some instances, tribes provide the state with their tribal

 26 This lack of data on American Indian caseloads makes it difficult for states and tribes to

determine tribal TANF grant amounts, but it also hinders a tribe’s ability to plan and design

its programs. The Torres-Martinez Desert Cahuilla tribe of Los Angeles, for example, based

its tribal TANF plan on American Indian TANF recipient estimates that turned out to be

inaccurate.

27 If the state and tribe cannot agree on the 1994 caseload numbers submitted by the state,

the Secretary of HHS, or designee, is required to make a decision on the tribal TANF grant

amount.

Tribes Face

Challenges

Implementing Their

Programs
Page 33 GAO-02-768 TANF Welfare Reform

enrollment list, and the state cross-matches the names with their database

of families receiving cash assistance in 1994 to come up with a number on

which their grant amount is based. In other instances, states rely on other

sources of data to estimate the number of American Indians who received

AFDC in 1994. Of the 26 tribal TANF programs that responded to our

survey, 17 reported that their tribal TANF grant was based on the state’s

estimate of the number of American Indian families in their service area on

AFDC in 1994, but 9 tribes reported that they negotiated a grant amount

not based on this estimate, but instead based on a number they negotiated

with the state.

The degree to which any tribal TANF program’s federal grant corresponds

to its current caseload varies substantially. Some officials attribute this to

underestimates of the number of American Indian families who were

receiving AFDC in 1994. Others believe that eligible families are more

likely to seek benefits from a tribal program, in part because of increased

outreach. Changes in the economy and population growth over the past

decade have also led to fluctuations in public assistance caseloads on

some reservations. The majority of tribes with TANF programs responding

to our survey question, 19 of 21, reported that the number of families they

were currently serving was the same as, or smaller than, the number of

families on which their grant was based. However, 2 of the 21 tribes

reported that their TANF caseload was larger than the caseload on which

their grant was based.

Because tribal TANF programs often provide TANF recipients with the

same monthly benefit as the states in which they are located, those

programs that serve more families than the number on which their grant is

based have fewer resources to fund the full range of TANF services. The

White Mountain Apache tribe spends some of its TANF grant on

transportation and child care, but none on educational, health, or jobrelated services for their recipients. The Fort Belknap tribal TANF

program, for example, only funds four TANF services: GED training, work

experience, job search, and support services. In contrast, the majority of

programs responding to our survey (17 of 24 programs) reported that they

spend TANF funds on a range of education, job-related counseling, and

transportation or child care services.

• Securing or leveraging the resources needed to establish the

infrastructure needed to administer tribal TANF. Because most

tribes starting tribal TANF programs do not have the infrastructure they

need in place, they have secured and leveraged funding from a variety of

sources to meet the basic “start-up” costs involved in setting up a new
Page 34 GAO-02-768 TANF Welfare Reform

program. These start-up costs include those for basic infrastructure such

as information technology systems. In addition, tribal TANF programs are

not eligible to receive any of the performance incentives currently

available to states.

One infrastructure need that tribes have found particularly difficult to

meet is the development of new information systems. Like states, tribal

TANF programs are permitted to spend as much of their federal TANF

grant on management information systems as they choose, and some

tribes have developed systems for their new TANF programs. Unlike

states, tribes did not receive additional federal funds expressly for the

purpose of developing and operating automated information systems

under AFDC, the precursor to the TANF program.28 Although most of the

tribal TANF programs reported using an automated system to report TANF

data, many—8 of 27—do not. For example, the Fort Belknap tribal TANF

program in Montana has a caseload of 175 families, yet it does not have an

automated information system for the collection, processing, and

reporting of TANF data. Eleven tribes reported having an automated

system devoted to their TANF program. Others use the state’s computer

system or contract with the state to collect, store, or process data for

federal reporting purposes.

Some tribes have leveraged funds from other federal programs or relied on

other sources, including state TANF funds and tribal government

contributions, because most tribal TANF funds are used to provide

benefits to TANF recipients. For example, the Confederated Salish and

Kootenai tribal TANF program received a Community Technology Centers

grant from the U.S. Department of Education to fund the ongoing

operating costs of its “Cool Bus,” a mobile computer training center. The

bus locates in neighborhoods around the reservation on a rotating basis to

provide computer access and computer training programs to TANF

recipients and other tribal members.

 28 Between 1980 and 1992, the federal government reimbursed states for 50 to 90 percent of

the costs incurred in planning, designing, developing, installing, and operating automated

welfare systems. From 1994 to 1997, states could be reimbursed for 50 percent of their

automated systems costs. We reported that between 1984 and 1992, the federal government

spent more than $500 million annually on state automated AFDC systems. See U.S. General

Accounting Office, Welfare Reform: Improving State Automated Systems Requires

Coordinated Federal Effort, GAO/HEHS–00–48 (Washington, D.C.: Apr. 2000) and U.S.

General Accounting Office, Automated Welfare Systems: Historical Costs and Projections,

GAO/AIMD–94–52FS (Washington, D.C.: Feb. 25, 1994).
Page 35 GAO-02-768 TANF Welfare Reform

Figure 10: Confederated Salish and Kootenai Tribe’s Mobile Computer Training

Center

States recognize that it is in their best interest if tribal TANF programs

succeed and, therefore, most provide at least some of their state MOE

funds to tribal programs in their state. HHS reports that 29 of 36 tribal

TANF programs receive MOE funds from the states. Some states provide

tribes with a share of MOE proportionate to the population they are

serving; others provide some start-up costs, and others have not provided

any funds. While the law does not require states to contribute MOE, some

state officials we visited indicated that they believed that it was in their

best interest to provide MOE to tribes in order for the programs to

succeed so that tribes would never have to retrocede their programs back

to the state. Any contributions made by states to tribal TANF programs do

count toward a state’s MOE requirement.

Most tribal TANF programs that responded to our survey question, 24 of

27, reported that their tribal government made contributions to their TANF

program. Eighteen of these respondents reported that their tribes

contributed office space or buildings. In addition, 15 programs received

contributions from the tribal governments to cover other start-up costs.
Page 36 GAO-02-768 TANF Welfare Reform

For example, the Navajo tribal TANF program received $500,000 from its

tribal government to help cover start-up costs.

Figure 11: Facilities Used for Tribal TANF Programs

Hopi Guidance Center

Coeur d'Alene Social Service office

Navajo TANF office, Chinle, Arizona
Page 37 GAO-02-768 TANF Welfare Reform

In addition to securing resources from federal, state, and tribal

governments, some tribes have leveraged other funds to enable them to

administer tribal TANF with limited resources. One way tribes have been

able to do this is by combining TANF and other tribally administered

federal employment and training programs into a single program with a

single budget through a consolidated plan, as authorized by the Indian

Employment, Training, and Related Services Demonstration Act of 1992.29

Tribes with consolidated plans are able to save on administrative costs

and reduce duplication of services by streamlining the administration of

related programs. For example, a tribe with a consolidated plan could

provide job search and job preparation services to all tribal members

through a single program, rather than having a separate program for TANF

recipients. To date, 13 tribal TANF programs responding to our survey

question have included TANF in their consolidated plans. Two of the

tribes we visited, the Confederated Salish and Kootenai tribe and the

Sisseton-Wahpeton tribe, included their tribal TANF programs in

consolidated plans, and both tribes indicated that the ability to combine

funding sources and streamline service delivery was instrumental in

allowing them to administer tribal TANF within their budget constraints.

• Developing the expertise to better implement tribal TANF

programs. Tribal TANF program administrators have had to quickly

develop the expertise to plan and operate tribal TANF programs because

they do not have experience in administering welfare programs. Tribal

TANF administrators have had to train staff on eligibility determination,

data reporting requirements, and administration. They have also had to set

up information systems, conduct feasibility studies, and leverage

resources to help cover their costs.

Most of the tribes that responded to our survey reported that states

provided them with at least some technical assistance in these areas, but

the amount of assistance provided by states varied. PRWORA does not

require states to provide technical assistance to tribes, but 19 tribes

reported that the state helped them to a great or very great extent in

developing their initial concept paper describing their TANF program. In

addition, 26 tribal TANF programs reported that they had received

technical assistance and support from the state in developing or operating

automated systems to collect and report TANF program data. A number of

 29 The 1992 act (P.L. 102-477) allows federally recognized tribes and Alaska Native entities

to combine federal grant funds for employment training, or any related area, into a 477

plan, with a single budget and a single reporting system.
Page 38 GAO-02-768 TANF Welfare Reform

programs reported that they received assistance from the state on other

aspects of administering a TANF program. Tribes also reported that HHS

has provided them with technical assistance when asked.

Finally, tribal officials indicated that certain types of assistance were not

readily available to them from states or the federal government. For

example, tribes have recognized their need to conduct studies to

determine whether it is feasible for them to administer their own

programs. However, neither states nor the federal government have

provided tribes with technical assistance on how to conduct a feasibility

study that would provide them with all of the information about whether

or not they have the resources, infrastructure, and other supports

necessary to effectively administer their own programs. Similarly, while

tribes have established informal networks to exchange information about

strategies they are employing to help move recipients into productive

work activities, some of the tribes we visited indicated that such

information is not systematically compiled and is, therefore, difficult to

locate when they need it. As a result, tribes do not have all of the

information they could use to develop a successful program that responds

to the economic constraints that exist on reservations.

PRWORA gives tribes a new opportunity to exercise their sovereignty by

administering their own TANF programs. At this early stage of tribal TANF

implementation, we see tribes making progress in exercising their

flexibility by tailoring the design of their programs and engaging their

members in a broad array of work activities. However, tribes face

challenges in developing the data, systems, and expertise they need to

operate their programs.

While tribes have moved forward in establishing their own programs, it is

not yet known whether these programs will help recipients find

employment before reaching time limits. In addition, it is not yet clear

whether the flexibility afforded to tribal TANF programs will allow them

to continue to provide benefits and services to those who reach the time

limit without obtaining a job. States and the federal government have

provided tribes with many types of assistance to enable them to develop

programs tailored to their communities, but tribes have not received the

assistance they need to conduct feasibility studies that will allow them to

make informed decisions about administering tribal TANF programs, nor

do they have easy access to information about strategies other tribes have

employed to move recipients into productive work activities given the

economic conditions on reservations.

Conclusions
Page 39 GAO-02-768 TANF Welfare Reform

Whether tribal TANF programs will be successful in moving more

American Indians from welfare into the workforce will ultimately depend

on not only the ability of the programs to meet their recipients’ need for

income support, education, and training, but also the success of economic

development efforts in providing employment opportunities for American

Indians.

We recommend that HHS provide assistance to tribes to better enable

them to determine the feasibility of implementing their own TANF

programs and to ensure that they have access to information about

strategies other tribal TANF programs have used to help move recipients

into productive work activities so that they can develop better programs

that respond to economic conditions on reservations.

We provided a draft of this report to HHS for its review. A copy of HHS’

response is in appendix IV. HHS generally agreed with our findings and

our recommendation.

With regard to our recommendation that HHS assist tribes in determining

the feasibility of administering their own TANF programs, the agency

noted that it already assists tribes interested in administering tribal TANF

by providing them with approved tribal TANF plans to use as examples

and by providing them with comments and assistance in developing their

plans. This assistance is helpful to tribes that have made the decision to

administer tribal TANF and are in the process of designing their programs.

However, we believe more could be done to assist those tribes that have

not yet decided whether to administer tribal TANF in determining the

feasibility of administering the program. Concerning our recommendation

that HHS ensure that tribes have access to information about strategies

used by other tribes, HHS noted that it plans to share information on

innovative strategies used by tribes and to work with tribes to ensure that

its technical assistance efforts are effective. In addition, HHS stated that it

plans to provide additional assistance to tribes in the areas of strategic

planning, information systems, financial management, performance goals

and tracking, and staff development. We agree that additional assistance

in these areas will help tribes to develop programs that best meet the

needs of their recipients.

As agreed with your offices, unless you publicly announce its contents

earlier, we plan no further distribution of this report until 7 days after its

Recommendations

Agency Comments
Page 40 GAO-02-768 TANF Welfare Reform

issue date. At that time, we will send copies of this report to the Secretary

of HHS, appropriate congressional committees, and other interested

parties. We will also make copies available to others on request. In

addition, the report will be available at no charge on the GAO Web site at

http://www.gao.gov.

If you have any questions concerning this report, please contact me or

Clarita Mrena on (202) 512-3022 or at mrenac@gao.gov. Other staff who

made significant contributions to this report are listed in appendix V.

Cynthia M. Fagnoni

Managing Director, Education, Workforce,

 and Income Security Issues
Appendix I: Scope and Methodology

Page 41 GAO-02-768 TANF Welfare Reform

We conducted three mail surveys for this study. We sent the first survey to

the tribal Temporary Assistance for Needy Families (TANF) directors of

the 36 federally approved tribal TANF programs, including 3 administered

by Alaska Native regional nonprofit corporations. We sent the second to

the tribal chairmen or presidents of the remaining 334 federally recognized

tribes. 1

We asked both groups to provide information on tribal enrollment, poverty

among tribal members on the reservations, and employment information

among adults living on the reservations, economic development initiatives,

commercial enterprises owned by the tribe, unemployment rates, and the

types of TANF services received by tribal members enrolled in the

program. In addition, we asked tribal program administrators about their

experiences in administering a tribal TANF program.

We sent a third mail survey to the state TANF directors of the 34 states

that have at least one federally recognized Indian tribe. We asked them to

provide information about American Indians who received TANF through

their state programs and the tribal TANF programs in their states.

The questionnaires used for each of the surveys were each pretested at

least twice. Table 5 provides survey numbers and response rates for all the

surveys.

Table 5: Survey Numbers and Response Rates

Survey of

Number of

surveys mailed

Number of survey

responses received

Response rate

(percent)

Tribal TANF

programsa

36 28 78

Tribesb334 124 37

States 34 34 100

a

This includes 7 consortiums that administer the tribal TANF program for 145 tribes, as of January 1,

2002. Five of the seven consortiums responded to our survey.

b

This excludes the consortiums that administer tribal TANF programs.

 1

 We mailed this survey to the Alaska Native regional nonprofit corporations and the

Metlakatla Indian Community of the Annette Islands Reserve that are eligible to administer

their own TANF program but do not. We excluded other federally recognized Alaska Native

entities from this survey that are not eligible to administer a tribal TANF program.

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 42 GAO-02-768 TANF Welfare Reform

Many of the questions included in the questionnaires sent to tribal TANF

programs and to other tribes were identical, so we were able to combine

the responses from the two surveys into a single database. This database

includes responses from tribes that have tribal TANF programs as well as

tribes that do not have tribal TANF programs. The database, which is used

primarily to report findings on the economic conditions on reservations,

does not include responses from tribal TANF programs operated by

consortia because tribal TANF consortia were not asked to provide

information about economic conditions on the reservations of each of

their members. Of the 370 individual tribes that were sent surveys, 147

responded to the survey, for a response rate of 40 percent.

Not all respondents to the survey answered every question because not all

questions applied to every respondent, and some respondents chose not to

answer one or more of the questions that did apply to them. As a result,

individual survey questions often had fewer answers than the total number

of respondents to the survey.

We also visited state TANF programs in Arizona, Idaho, Montana, North

Dakota, and South Dakota; seven tribes that had implemented or were

beginning to implement tribal TANF programs; and five that have decided

not to implement tribal TANF programs across these five states. We

selected states or tribes to visit based on a variety of factors, such as the

number of American Indians receiving TANF, whether TANF was provided

through a state program or a tribal TANF program, whether tribes were

administering their own programs or not, the length of time tribes had

been operating their own TANF programs, and geographic location. We

discussed TANF issues with tribal leaders and tribal social service officials

as well as state TANF officials in each of the five states.

Last, we reviewed the literature concerning the impact of welfare reform

on American Indians and discussed this subject with federal officials at

HHS’ Administration for Children and Families and the Department of the

Interior’s Bureau of Indian Affairs, representatives of the National

Congress of American Indians (NCAI) and the Indian and Native American

Employment and Training Coalition, academic experts from the Kathryn

M. Buder Center for American Indian Studies at Washington University in

St. Louis and the Udall Center for Studies in Public Policy at the University

of Arizona. In addition, we attended two tribal TANF conferences

organized by NCAI and a meeting of the Southwest Tribal TANF

Consortia, which is composed of Arizona tribes, and met with

representatives of the Montana Tribal Welfare Reform Consortia.

Site Visits
Appendix II: Tribal TANF Programs

Page 43 GAO-02-768 TANF Welfare Reform

State Programs

Association of Village Council Presidents

Central Council Tlingit and Haida Indian Tribes of Alaska

Alaska

Tanana Chiefs Conference, Inc.

Pascua Yaqui Tribal Council

Navajo Nation (also in New Mexico and Utah)

White Mountain Apache Tribal Council

Hopi Tribal Council

Arizona

Salt River Pima-Maricopa Indian Community Council

Owens Valley Career Development Center

Southern California Tribal Chairmen’s Association

California

Torres-Martinez Desert Cahuilla Indians

Coeur d’Alene Tribal Council

Nez Perce Tribal Executive Committee

Idaho

Shoshone-Bannock Tribes of the Fort Hall Reservation

Minnesota Mille Lacs Reservation Business Committee

Montana Confederated Salish & Kootenai Tribes, Tribal Council

Fort Belknap Community Council

Nebraska Winnebago Tribal Council

New Mexico Pueblo of Zuni

Oklahoma Osage Tribal Council

Oregon Klamath General Council

Confederated Tribes of Siletz Indians

South Dakota Sisseton-Wahpeton Sioux Tribal Council

Lower Elwha Tribal Council

Quinault Indian Nation - Business Committee

Colville Business Council

Port Gamble S’Klallam Tribe

Washington

Quileute Tribal Council

Bad River Band of Lake Superior Tribe of Chippewa Indians

Red Cliff Band of Lake Superior Chippewa Indians of Wisconsin

Stockbridge Munsee Community of Wisconsin

Sokaogon Chippewa (Mole Lake) Community of Wisconsin

Lac du Flambeau Band of Lake Superior Chippewa Indians of Wisconsin

Wisconsin

Forest County Potawatomi Community of Wisconsin

Wyoming Northern Araphaho Tribe (Wind River)

Shoshone Business Committee

Appendix II: Tribal TANF Programs
Appendix II: Tribal TANF Programs

Page 44 GAO-02-768 TANF Welfare Reform

Figure 12: Map of Federally Recognized American Indian Tribes, Alaska Nonprofit Corporations, and Tribal TANF Programs
Appendix II: Tribal TANF Programs

Page 45 GAO-02-768 TANF Welfare Reform
Appendix III: Tribal TANF Work Activities

Page 46 GAO-02-768 TANF Welfare Reform

Table 6:Activities That Count Toward Meeting Work Participation Rate

Requirements As Defined by Tribal TANF Programs

Tribe

Cultural

activities

Counseling/

treatment

Alaska

Association of Village Council Presidents

Central Council Tlingit and Haida Indian Tribes of Alaska

Tanana Chiefs Conference, Inc.

Arizona

Pascua Yaqui Tribal Council

Navajo Nation X

White Mountain Apache Tribal Council

Hopi Tribal Council

Salt River Pima-Maricopa Indian Community Council

California

Owens Valley Career Development Center X X

Southern California Tribal Chairmen's Association

Torres-Martinez Desert Cahuilla Indians X X

Idaho

Coeur d'Alene Tribal Council X

Nez Perce Tribal Executive Committee X X

Shoshone-Bannock Tribes of the Fort Hall Reservation X

Minnesota

Mille Lacs Reservation Business Committee

Montana

Confederated Salish & Kootenai Tribes, Tribal Council X

Fort Belknap Community Council X X

Nebraska

Winnebago Tribal Council X

New Mexico

Pueblo of Zuni

Oklahoma

Osage Tribal Council

Oregon

Klamath General Council

Confederated Tribes of Siletz Indians

S. Dakota

Sisseton-Wahpeton Sioux Tribal Council

Appendix III: Tribal TANF Work Activities
Appendix III: Tribal TANF Work Activities

Page 47 GAO-02-768 TANF Welfare Reform

Selfemployment

Life Skills/

parenting

Subsistence

activities

PostsecondaryNEWa

participation

Commuting

time

Same as

PRWORA

X

X

X

X

X

X

X

X

XX XX

X

XX XX

X

XX X

X X

X

X X

X

X

X

X

X

X
Appendix III: Tribal TANF Work Activities

Page 48 GAO-02-768 TANF Welfare Reform

Tribe

Cultural

activities

Counseling/

treatment

Washington

Lower Elwha Tribal Council X X

Quinault Indian Nation - Business Committee X X

Colville Business Council X X

Port Gamble S'Klallam Tribe X X

Quileute Tribal Council X X

Wisconsin

Bad River Band of Lake Superior Tribe of Chippewa

Indians

X X

Red Cliff Band of Lake Superior Chippewa Indians of

Wisconsin

Stockbridge Munsee Community of Wisconsin

Sokaogon Chippewa (Mole Lake) Community of

Wisconsin

Lac du Flambeau Band of Lake Superior Chippewa

Indians of Wisconsin

X

Forest County Potawatomi Community of Wisconsin

Wyoming

Northern Araphaho Tribe (Wind River)

Shoshone Business Committee

a Participation in a tribal Native Employment Works (NEW) program, a tribally administered work

activities program.
Appendix III: Tribal TANF Work Activities

Page 49 GAO-02-768 TANF Welfare Reform

Selfemployment

Life Skills/

parenting

Subsistence

activities

PostsecondaryNEWa

participation

Commuting

time

Same as

PRWORAb

X X

X XX

X X

X

X

X

X

X

X
Appendix IV: Comments from the Department

of Health and Human Services

Page 50 GAO-02-768 TANF Welfare Reform

Appendix IV: Comments from the

Department of Health and Human Services
Appendix IV: Comments from the Department

of Health and Human Services

Page 51 GAO-02-768 TANF Welfare Reform
Appendix IV: Comments from the Department

of Health and Human Services

Page 52 GAO-02-768 TANF Welfare Reform
Appendix V: GAO Contacts and Staff

Acknowledgments

Page 53 GAO-02-768 TANF Welfare Reform

Clarita A. Mrena, (202) 512-3022

Kathryn A. Larin, (202) 512-5045

In addition to those named above, Carolyn S. Blocker, Mark E. McArdle,

Robert D. Sampson, Joel I. Grossman, Catherine M. Hurley, and Corinna

Nicolaou made key contributions to this report.

Appendix V: GAO Contacts and Staff

Acknowledgments

GAO Contacts

Staff

Acknowledgments

(130159)

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