TRIBAL HOUSING STABILITY REPORT

SUPPORTING TRIBAL HOUSING STABILITY 

WITH PANDEMIC RESPONSE FUNDS

DECEMBER 2023
TRIBAL HOUSING STABILITY REPORT

SUPPORTING TRIBAL HOUSING STABILITY WITH 

PANDEMIC RESPONSE FUNDS

DECEMBER 2023

Note: The Tribal Housing Stability Report presents Treasury’s federal financial assistance programs aimed at meeting 

a range of Tribal housing needs. Eligible use projects and services (e.g., home preservation, housing stability services 

and needs, and essential home repairs to maintain habitability of a home) are not distinctly categorized among the 

HAF, SLFRF, LATCF, and ERA1 programs. For information about specific eligible uses categories and other program 

requirements, Tribal governments, as well as other readers of the report, should refer to the SLFRF final rule and 

program guidance and the LATCF, HAF, and ERA1 programs’ guidance available at https://home.treasury.gov/policyissues/coronavirus. Please contact Treasury’s Office of Tribal and Native Affairs at tribal.consult@treasury.gov if you 

have questions about the data provided in this report.

Photo Credit of Secretary Yellen by Kevin Abourezk
CONTENTS

Introduction .................................................................................................. 1

Tribal Consultation Engagement to 

Promote Equitable Outcomes ................................................................. 3

State of Housing in Indian Country...................................................... 6

Investing Recovery Funding to 

Address Tribal Housing Needs ............................................................... 10

Housing Stabilization ................................................................................ 13

Home Preservation..................................................................................... 14

New Housing Construction...................................................................... 16

Continuing to Support Tribal Housing Stability.............................. 18

About the Office of Tribal and Native Affairs ................................... 19
Introduction

On President Biden’s first day in office, he signed 

Executive Order 13985 – Advancing Racial Equity and 

Support for Underserved Communities Through the 

Federal Government. This executive order calls for a 

comprehensive approach for the Federal government 

to prioritize fairness and equity for all, including for 

people of color and others who have been historically 

underserved, and to embed these principles into the 

implementation of Federal programs and services. 

Included in these efforts, the Biden-Harris 

Administration championed equity through the 

landmark American Rescue Plan Act (ARPA). The ARPA 

contained economic and recovery programs managed 

by the U.S. Department of the Treasury (Treasury), 

including a set aside of approximately $21.5 billion for 

Tribal governments. This historic pandemic relief 

1 Two separate ERA programs have been established: the ERA1 program was authorized by the Consolidated Appropriations Act of 2021. 

The ERA2 program was authorized by the American Rescue Plan Act of 2021. ERA1 awards were provided directly to Tribal governments or 

their Tribally Designated Housing Entities, states, the District of Columbia, U.S. territories, and certain local governments with 200,000 or 

more residents, and in the case of ERA2, the awards were provided directly to states, the District of Columbia, U.S. territories, and certain 

local governments.

2 The Coronavirus Relief Fund was authorized by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).

funding is administered by the Office of Recovery 

Programs (ORP) within Treasury. ARPA authorized five 

critical Tribal recovery programs: Coronavirus State 

and Local Fiscal Recovery Funds (SLFRF), Homeowner 

Assistance Fund (HAF), Local Assistance and Tribal 

Consistency Fund (LATCF), State Small Business Credit 

Initiative (SSBCI), and Capital Projects Fund (CPF). 

ORP oversees two additional recovery programs for 

Tribes – Emergency Rental Assistance (ERA1)1

 and the 

Coronavirus Relief Fund (CRF)2

 that were authorized 

by legislation enacted before ARPA and implemented 

by the Biden-Harris Administration. These programs 

are intended to assist Tribal governments, their 

communities, Tribal citizen-owned businesses, and 

households with accessing relief.

TABLE 1

Summary of Tribal Grantee Recovery Funding Data

1
2

To support the implementation of these programs 

for Tribal governments and other Tribal entities, the 

Secretary of the Treasury, Janet L. Yellen, created 

the Office of Tribal and Native Affairs, which is 

overseen by the Treasurer of the United States, Chief 

Marilynn Malerba, the first Native American to hold 

this position. The Office’s purpose is to serve as a 

permanent hub for Tribal policy within Treasury. This 

Tribal Housing Stability Report (Report), authored 

by the Office of Tribal and Native Affairs, focuses 

on the SLFRF, HAF, and ERA1 programs, which are 

a critical part of the Biden-Harris Administration’s 

broad strategy to help homeowners and renters 

avoid foreclosure and eviction, stabilize the country’s 

housing market, and improve the nation’s economy 

as it recovers from the effects of the COVID-19 

pandemic. The Report features housing construction, 

preservation, and stability projects and services 

planned or underway by Tribal governments and 

Tribally Designated Housing Entities (TDHEs) to reduce 

barriers to affordable housing and keep people in 

their homes. The highlighted housing projects and 

housing stability services are among many that Tribal 

recipients have invested in with their SLFRF, HAF, and 

ERA1 awards. 

Secretary Yellen and Treasurer Chief Lynn Malerba meeting with a Tribe in the Great Plains. Photo Credit Kevin Abourezk
3

Treasury is committed to strengthening its relationships 

with Tribal governments and Indian Country.3

 Executive 

Order 13175 and President Biden’s Memorandum 

for Tribal Consultation and Strengthening Nation-toNation Relationships charge Treasury with engaging in 

regular, meaningful, and robust consultation with Tribal 

officials. Consultation recognizes Tribal sovereignty and 

the political Nation-to-Nation relationship between the 

United States and Tribal Nations. It acknowledges that 

the United States maintains certain treaty and trust 

responsibilities to Tribal Nations.

Honoring these commitments, Treasury prioritized 

Tribal engagement and feedback to better understand 

and respond to Tribes regarding requirements set 

forth in applicable regulations, legislative comments, 

proposed legislation, and policy statements that have 

Tribal implications, as well as those having a direct 

and identifiable economic impact on Tribes or that 

preempt Tribal law. The Office of Tribal and Native 

Affairs, in partnership with ORP, conducted nine Tribal 

consultations on ORP programs, held over 300 oneon-one sessions, and partnered with the White House 

Council on Native American Affairs and numerous 

Tribal-led national and regional organizations to 

provide direct engagement.

A key consideration throughout the development 

of ORP’s program regulations, published guidance, 

and other actions has been ensuring fairness and 

promoting equitable outcomes. Tribal leaders 

expressed in each consultation that business closures 

caused significant deterioration to the Tribal economy, 

adding to preexisting unmet needs. At the start of the 

pandemic, Native Americans faced overcrowding in 

homes and an inequity in healthcare services and 

health status as compared to other Americans. Beyond 

healthcare, other determinants such as education, 

access to nutritious foods, criminal and social justice 

issues, and unemployment contributed to inequities.

3 In this Report, the term “Indian Country” is used to mean Tribal areas, including Alaska Native Villages.

4 U.S. Commission on Civil Rights. (2018). Broken Promises: Continuing Federal Funding Shortfalls for Native Americans.

The U.S. Commission on Civil Rights (USCCR) 2018 

report,4 Broken Promises, reported:

“Indian Country faces many economic 

development challenges. Over 25 percent of 

Native Americans live in poverty, which is higher 

than the poverty rate of any other racial group 

in the U.S. Approximately 12 percent of Native 

Americans are unemployed, more than double 

the national average. For Native Americans 

living on reservations, the unemployment rate is 

around 50 percent, and for certain reservations, 

the average unemployment rate is much higher, 

hovering around 80 percent and up...”

To that end, Treasury recognized that pandemic 

responses funded by ORP programs would need to 

be adapted to varying needs across Indian Country. 

To promote more equitable outcomes and a stronger 

recovery, Treasury sought ways to support selfgovernance and self-determination by increasing 

flexibility in Tribes using their award funds under ORP 

programs and decreasing administrative burdens 

where possible.

Tribes form for-profit businesses to fund the provision 

of government services to their citizens, to support 

public safety, road and infrastructure maintenance, 

housing, education, social services, healthcare, 

and other programs and projects that benefit the 

community. Unlike state and local governments, 

Tribes have the additional responsibility of restoring 

language, preserving culture and traditions, and 

safeguarding sacred sites. Tribes generally have no 

property tax base to fund these government services 

because the United States owns trust lands. Further, 

over 40 percent of Tribal governments are located 

Tribal Consultation Engagement to Promote 

Equitable Outcomes
4

in states5 that do not have a sales tax, which makes 

instituting Tribal sales tax an unreliable revenue 

strategy. As a result, Tribes rely on for-profit business 

revenue in place of a solid tax base. Over 30 percent 

of Tribal businesses reported laying off or furloughing 

80 to 100 percent of their workforce at the beginning 

of the pandemic.6

 The financial viability of some of 

these businesses was threatened, especially for those 

businesses that were already operating on small profits 

because of their intent7

 to provide governmental 

services and create jobs for the community.

Tribal leaders shared that including Tribal 

government-owned businesses in the definition 

of “general revenue” in the SLFRF 2022 Final Rule 

was of utmost importance to creating economic 

recovery and growth. The SLFRF 2022 Final Rule 

also provided recipients the option to either elect a 

standard allowance of up to $10 million or complete 

a full revenue loss calculation. The standard 

allowance option dramatically simplified the program 

administration and ease of use, with 54 percent of 

Tribal governments having a total SLFRF award of 

under $10 million.

Early on, Treasury heard from Tribal leaders that lowincome families living in overcrowded households 

were declined for ERA1 assistance. These families 

would have qualified for assistance if their overall 

5 There are 248 Tribes in states with no general statewide sales tax: Alaska, Montana, and Oregon.

6 Lozar, C., Colombe, J., Feir, D. (2020). Federal Reserve of Minneapolis, Center for Indian Country Development. COVID-19: A deep economic 

crisis in Indian Country.

7 GASB Codification 2600.116.

8 See HUD Office of Native American Programs, Program Guidance No. 2021-01, June 22, 2021.

household income was at or below 80 percent of 

Area Medium Income (AMI). In response, Treasury 

permitted Tribal entities under the ERA1 program 

to rely on the methodology authorized by the U.S. 

Department of Housing and Urban Development 

(HUD) for its Indian Housing Block Grant8

 (IHBG) 

program to determine the AMI for Tribal members 

applying for ERA1 assistance. By aligning with IHBG, 

Tribes could serve more families facing homelessness. 

Following this practice, the HAF program also used 

IHBG as one of the methodologies to determine 

eligibility. Alongside work to strengthen its guidance, 

Treasury moved to improve program capacity. In 

consultations, Tribal leaders in areas with limited 

broadband access explained that despite significant 

progress in them making contractual obligations 

to pay rental assistance to eligible households 

and employing every effort possible to fast-track 

applications submitted for assistance, it was 

challenging to kick off the ERA1 program during 

the height of the pandemic, which impacted the 

pace at which the ERA assistance was disbursed to 

eligible households. Subsequently, Treasury did not 

involuntarily recapture unused ERA1 award funds 

from Tribes as part of the statutory reallocation 

process while Tribes’ programs were still in progress 

but instead provided a reasonable approach to a 

voluntary return of unused ERA1 award funds. 

Unlike state and local governments, Tribes have the additional responsibility of restoring language, preserving culture and traditions,

and safeguarding sacred sites.
5

Some Tribes quickly exhausted their ERA1 award 

funds but still had a high need for the ERA1 assistance 

in their communities. Treasury listened to concerns 

and recommendations from Tribal leaders and 

incorporated comments into the ERA1 reallocation 

process. Treasury established an internal process to 

reallocate the unused ERA1 award funds to Tribal areas 

with a large population of citizens at risk of eviction 

and demonstrated success in implementing their ERA1 

awards. Over $85 million in ERA1 award funds from 

states and Tribes that were voluntarily returned to 

Treasury were reallocated to other Tribes that may have 

otherwise gone unused, ensuring rapid deployment of 

resources across Indian Country. For example:

Treasury officials and CFPB Director Rohit Chopra toured the 

ancient Pueblo of Acoma, where the traditional Puebloan 

housing and cultural structures served as a model for modern 

Tribal apartments.

•	 The Pueblo of Acoma Housing Authority’s 

mission is to create housing opportunities 

while embracing the traditions and culture of 

the people. As such, it focused on community 

engagement and outreach to target populations 

needing ERA1 assistance and to structure 

the program to maximize the delivery of rent 

and utility support in a culturally appropriate 

way. With the addition of two rounds of ERA1 

reallocation funding, the Housing Authority was 

also able to partner with local governments 

to target Tribal members who were unhoused 

or living in hotels to get them into apartments 

and provide stable rental homes for citizens in 

recovery rehabilitation programs.

 9 The University of Arizona-Native American Advancement, Initiatives and Research. (2018). White Mountain Apache Tribe Community 

 Profile: https://naair.arizona.edu/white-mountain-apache-tribe

• The Chippewa Cree Housing Authority w

awarded ERA1 reallocation funding to continue 

supporting families after it had expended its 

original award. Each of the 725 households 

assisted had the opportunity to receive 

financial education. Intending to improve 

housing stability, applicants received financial 

education materials and had check-ins with 

housing staff members.

• The White Mountain Apache Housi

Authority is located in rural Arizona, where 

the area median income for a household is 

$16,3139

. After successfully administering its 

ERA1 award, the Housing Authority received 

ERA1 reallocation funding. The Housing 

Authority took a multi-pronged outreach 

approach to ensure all citizens needing 

emergency rental and utility services knew 

about its ERA program. Staff hand-delivered 

applications to elders, people with disabilities, 

and those who do not have transportation to 

help explain the program and assist citizens 

with applying for the ERA assistance. As a 

result, the Housing Authority provided nearly 

$9 million in services to those in danger of 

facing evictions and disconnection of utility 

services. 
6

Tribal leaders and their representatives also 

emphasized the need to reduce the administrative 

burden of implementing their ERA1 and HAF awards 

received from Treasury. Treasury’s goal has been 

to accelerate support and maximize available 

resources for homeowners and renters. Consistent 

with that goal, Treasury permitted Tribal recipients 

to serve qualifying Tribal citizens wherever they 

lived and allowed self-attestation of COVID-19-

related financial hardships and household income. 

Additionally, Treasury created Tribal-specific 

reporting requirements10 for ERA1 and HAF awards 

and hosted weekly open office hours to support the 

implementation of the Tribal recipients’ housing 

programs. These and other modifications provided 

flexibility so that each government has discretion on 

the best use of funds and has greater autonomy and 

responsibility in implementing their recovery plans.

State of Housing in Indian Country

Stable housing is one of the primary factors driving10

economic well-being in Tribal communities. It is often 

cited as an important social determinant of health,11

recognizing a range of ways that overcrowding, 

poor housing conditions, and a lack of housing can 

negatively affect health and well-being. Complex legal 

and other constraints, such as fractionated land, are 

critical to understanding the housing problems and 

needs on Tribal lands. 

Federal policies, including the General Allotment Act of 

1887 (also called the Dawes Act), resulted in 90 million 

acres of Indian land taken out of Indian ownership 

and control, with 60 million being sold or transferred 

to non-Indians. Later, the Burke Act of 1906, gave 

the Secretary of the Interior the power to issue feesimple titles to any Indian deemed “competent and 

capable” regardless of Tribal citizenship, thus making 

even more Indian land available for sale or lease. As 

a result, some of the reservation land remaining was 

divided up and allotted to individual Tribal members, 

causing a “checkerboard” pattern of land status. 

Checkerboarding impairs the ability of Tribes and 

individual Tribal citizens to use the land for housing, 

ranching, and other economic development that 

requires contiguous sections of Indian trust land. 

 10 Tribes allocated less than $5 million in HAF award funds must only submit the third quarter report (Quarterly) and the Annual Report 

once a year. Tribes that are allocated more than $5 million in HAF award funds must submit the Quarterly report four times a year and the 

Annual Report once a year. For ERA1, demographic data collection was reduced for Tribal recipients.

11 World Health Organization. (2008). Closing the gap in a generation: Health equity through action on the social determinants of health.

12 National Archives. Bureau of Indian Affairs Records: Termination. (July 2023). https://www.archives.gov/research/native-americans/bia/termination.

13 Treasury Tribal Consultation on the Tax Status of Tribally Chartered Corporations. (June 2023). https://home.treasury.gov/system/

files/136/Tax-Status-of-Tribally-Chartered-Corporations-Consultation-Summary.pdf

The “Termination Era” radically changed the lives of 

many Native Americans. From 1953-1968, Congress 

“terminated” or withdrew federal recognition of over 

100 Tribal governments, which ended the federal aid 

and services that came with recognition. Over 3 million 

acres of land12 were relinquished during this period. 

After the termination policy ended under President 

Richard Nixon, many Tribes fought a long, complex, and 

costly legal battle to regain federal recognition. Few 

have had their lands restored, while most have not.

Recently, there has been a “land back” movement 

across Indian Country where Tribes are acquiring their 

ancestral lands through private capital and federal 

programs. Because Tribes have been deprived of the 

vast majority of their traditional land base, purchasing 

back lands near or adjacent to their reservations 

is a shared priority. Tribes have commented that 

landowners will often take advantage of this fact 

and charge a premium to the prospective Tribal 

purchaser.13 Today, the 56 million acres of reservation 

land currently under Indian ownership is held in 

trust for Indian people by the federal government. 

Consequently, the Secretary of the Interior must 

approve nearly all land-use transactions, including 

leasing to potential homeowners, consolidating and 

selling trust land, and business development.
7

According to HUD, Indian Country had a deficit 

of 68,000 housing units as of 2015, which is likely 

undercounted.14 In the USCCR’s Broken Promises 

report,15 it was noted that flat funding of HUD 

programs combined with inflation in construction 

costs over time has resulted in a sharp decrease in 

the number of affordable housing units developed 

in Indian Country in recent years. According to HUD, 

unless additional funding is allocated for its programs, 

affordable housing development and assistance 

services in Indian Country “will continue to erode.”16

Compounding the housing problems due to land 

constraints and insufficient federal funding is the 

fact that the Native American population is rapidly 

growing. To assess overcrowding and the housing 

shortage, it is important to note that the Native 

American population is growing at twice the rate of 

the national average. In 2020, the number of people 

who identified as Native American and Alaska Native 

alone and in combination with another race was 9.7 

million.17 Approximately 60 percent of Native people 

live on or near reservations, with 30 percent nationally 

being younger than 18 compared to 24 percent for the 

non-Native population. 

Nationally non-native households have just 2.2 

percent overcrowding, whereas 16 percent of 

households on a reservation are overcrowded. 

Living with extended family is common in Tribal 

communities to prevent homelessness. The role of 

multigenerational households and overcrowded 

homes was a risk factor for developing more severe 

forms of COVID-19,18 since reduced personal space 

14 U.S. Department of Housing and Urban Development. (2017). Housing Needs of American Indians and Alaska Natives in Tribal Areas: A 

Report from the Assessment of American Indian, Alaska Native, and Native Hawaiian Housing Needs.

15 U.S. Commission on Civil Rights. (2004). Broken Promises: Evaluating the Native American Health Care System.

16 HUD, F.Y. 2017 Congressional Justifications, supra note 795, at 11-5.

17 U.S. Census Bureau. (2020). 2020 Census Results.

18 U.N. Emeruwa, S. Ona, J.L. Shaman, et.al. (2020). Associations between built environment, neighborhood socioeconomic status, and 

SARS-CoV-2 infection. 

19 U.S. Census Bureau reported that it undercounted approximately 4.9% of the Native American population in prior counts at U.S. Census 

Bureau. (2012). Census Bureau Releases Estimates of Undercount and Overcount in the 2010 Census. [CB12-95]. https://www.census.gov/

newsroom/releases/archives/2010_census/cb12-95.html

20 IPUMS-USA; University of Minnesota.

made it challenging to socially distance. Many Tribal 

citizens living on reservations could not work from 

home due to a lack of broadband access and having 

a larger proportion of service-oriented roles. These 

factors created additional exposure to the virus, with 

people crowded together in the evening and on the 

frontlines during the day.

TABLE 2

Native American Population Growth19

TABLE 3

65.2% of those who live in overcrowded housing also 

live with an essential worker20
8

Additionally, families in Tribal communities are five 

times more likely to live in poor housing conditions 

than the general population.21 For instance, 

Tribal area households lack basic plumbing, face 

mold issues, and are 1,200 times more likely to 

have heating problems. Many homes have other 

condition problems, defined as having at least five 

of the following maintenance problems: leaks from 

outdoors, holes in the floor, holes or open cracks in 

the walls or ceiling, more than one square foot of 

peeling paint or plaster, rats in the past 90 days, or 

leaks from the inside (such as broken pipes or water 

heaters, backed up plumbing, or water from another 

unit22). More than 56 percent of Tribal area households 

also have one or more identified housing problems 

of any kind, compared with 40 percent of the United 

States overall.23 Other specific inadequacies include 

broken heating equipment and having no electricity 

or other electrical problems. The hardest hit Tribal 

communities are those with harsh weather conditions 

– Alaska, the Great Plains, and the Southwest. 

These staggering statistics represent longstanding 

challenges facing Tribes and a lack of sufficient 

investment to address these challenges.

TABLE 4

Housing Problems in Tribal Areas24

21 U.S. Department of Housing and Urban Development. (2017). Housing Needs of American Indians and Alaska Natives in Tribal Areas: A 

Report from the Assessment of American Indian, Alaska Native, and Native Hawaiian Housing Needs.

22 Id. at 66.

23 Id. at 68.

24 Urban Institute Household Survey 2013-2015. American Housing Survey, 2013.

25 Alaska Rural Health Plan. (2001). Alaska’s Plan for Participating in the Medicare Rural Hospital Flexibility Program.

26 The University of Arizona, Native Nations Institute. (2016). Access to Capital and Credit in Native Communities. 

Alaska Native Villages in particular face uncommon 

circumstances in obtaining home building supplies 

and challenges with maintaining their homes. Over 

70 percent of Alaska communities are not connected 

by roads,25 with most dependent on costly barge 

shipments and air service for materials and services. 

The unique conditions of Alaska’s hard-to-reach 

villages, some accessible only by plane throughout the 

year or boat in summer months, contribute to lengthy 

delays in fire services. In some cases, homeowner 

insurance companies will not offer policies or 

will do so at a premium because fire protection 

and emergency services are limited. The lack of 

homeowner insurance options can be a barrier to 

obtaining home loans.

Citizens living in Tribal communities also face 

development barriers with remodeling and 

constructing new housing because of insufficient 

infrastructure for water, sewer, electricity, gas, and 

roads. Home ownership or construction on existing 

homes can be obstacles because both depend 

on access to private capital. In 2016, a report26

commissioned by Treasury’s Community Development 

Native American Housing in Tribal Areas Total US

Facilities Problems

Heating 12.00% 0.10%

Kitchen 6.60% 1.70%

Plumbing 5.60% 1.30%

Electrical 1.10% 1.40%

Conditions Problems 8.10% 0.08%
Financial Institutions Fund (CDFI Fund) identified 

that financial institutions were hesitant to provide 

lending services in Indian Country due to a poor 

understanding of Tribal sovereignty, the absence 

of a politically independent judicial and dispute 

resolution system, and the lack of certainty in Tribal 

commercial law. Trust land and jurisdictional issues 

also contribute to the higher cost of home financing 

and the reliance on manufactured homes. As a result, 

Tribal citizens attempting to obtain a home loan on a 

reservation are 55 percent more likely to have a higher 

priced loan than borrowers outside of a reservation, 

and these higher priced loans have average interest 

rates nearly two percentage points higher than other 

nearby loans.27

Federal programs such as the Section 184 Indian 

Home Loan Guarantee Program and USDA Rural 

Development provide homeownership opportunities; 

27 Feir, D. (2019). Federal Reserve of Minneapolis, Center for Indian Country Development. The Higher Price of Mortgage Financing for Native 

Americans.

28 Colombe, J. (2020). Federal Reserve of Minneapolis, Center for Indian Country Development. Shortening the TSR Timeline: A proposal to 

end delays that hinder Native Homeownership.

however, trust land bureaucratic processes can 

seriously delay closing. Certified Title Status Reports 

(TSRs) from the Bureau of Indian Affairs (BIA) are 

required for underwriting trust land home mortgages 

and for selling those mortgages into the secondary 

market.28 These transactions require that holders 

of trust land receive a leasehold interest from the 

Tribe to use collateral and then go through various 

environmental reviews, appraisals, and approval from 

the BIA – processes that non-Tribal citizens are not 

subject to.

Although efficient land management and the need to 

improve housing inventory will require longer-term 

reforms, Tribal governments are pooling their award 

funding from ORP programs with a focus on housing 

stability and using it in conjunction with other funding 

sources to respond to housing needs and supply. 

Rincon Band of Luiseño Tribal leader and the fire chief discussing land management practices, including wildland fire safety and risk

mitigation, water management, and sustainable energy projects that the Tribe has done to keep citizens on the reservation safe. A

previous fire had left some Tribal citizens without homes, which created many challenges.

9
10

Investing Recovery Funding to Address 

Tribal Housing Needs

Through funding supported by the SLFRF, HAF, ERA1, and LATCF programs, Tribal governments and their TDHEs 

are addressing some of the barriers to housing – including the difficulty of mortgage lending on trust land. 

Within the categories of eligible uses established by the American Rescue Plan Act for the SLFRF, LATCF, and HAF 

programs, and the Consolidated Appropriations Act, 2021 for the ERA1 program, Tribal governments have broad 

flexibility to meet the housing needs of their people.29 These programs can provide support for a household at 

multiple points of the housing continuum and relieve pressure on services by keeping people in their homes 

through direct financial assistance.

THE TRIBAL HOUSING CONTINUUM30

Housing-Related Eligible Uses:

SLFRF: Address immediate and long-term housing challenges, helping renters, homeowners, and unhoused 

individuals weather the pandemic’s harms while tackling the long-standing challenge of insufficient supply of 

affordable homes. 

HAF: Assistance with mortgage payments, homeowner’s insurance, utility payments, support to make homes 

habitable, and other qualified expenses related to mortgages and housing. 

ERA1: Support for rent and rental arrears, utility and home energy costs, utility home energy costs arrears, other 

expenses related to housing including, payment of rental security deposits, and costs for housing stability services.

LATCF: Funding for any governmental purpose except for a lobbying activity.

Meeting the need for stable, quality, affordable homes and utility support are among the most prominent uses 

of SLFRF funds for Tribal governments. Tribes are implementing home improvement programs, weatherization 

and energy efficiency projects, assistance with rental payments and utility bills, new construction, and housing 

counseling programs. These critical investments with housing-related ORP funding support Tribal families with 

the preexisting housing needs and help them recover from the financial impacts of the COVID-19 pandemic. 

These projects are being accomplished under the mantle of Tribal self-determination and self-governance with 

each Tribe determining how best to meet the housing needs of their people.

29 Guidance, the final rule, FAQs, and resources for each program can be found at https://home.treasury.gov/policy-issues/coronavirus/

assistance-for-state-local-and-tribal-government. 

30 Many communities have built prior housing infrastructure on the model of the housing continuum, which support a variety of housing 

stability needs and presents a path towards housing stability.
TABLE 5

Summary of ORP Funds Committed to 

Tribal Housing Services

Tribal SLFRF Housing-related 

Projects and Services

$5.3 Billion

Tribal HAF Planned Household 

Assistance

$450 Million

Tribal ERA1 Households 

Receiving Assistance

$611 Million

To date,31 Tribal governments have committed funds 

for 1,151 housing and infrastructure-related projects 

with their SLFRF awards. This represents 25 percent of 

SLFRF award-funded projects implemented by Tribal 

governments thus far. The pandemic dramatically 

underscored the intersections between housing, 

infrastructure needs, and healthcare. Addressing 

overcrowding in homes and the need for reliable 

water, sewer, broadband, and safe roads proved to 

be the backbone for an equitable recovery. Tribes 

are investing their SLFRF award funds to find longterm solutions to address inadequate infrastructure 

for Tribal households. SLFRF awards also provide an 

opportunity to become more intentional in land use 

decisions and find solutions for stable, quality, and 

affordable housing. 

31 Data based on the ERA1 Final Report, SLFRF Project and Expenditure Reports, and the HAF Quarterly and Annual Reports submitted to 

Treasury for the June 30, 2023, reporting period. The examples included in this Report are based on recipient reports, and their inclusion 

in this document does not constitute an explicit approval of these projects by Treasury.

32 Data has been aggregated into one or more categories.

33 Housing stabilization projects include payments for mortgage, rent, utilities, and other housing assistance.

34 Broadband projects include expansion of affordable access to broadband internet across the Tribal community.

TABLE 6

SLFRF Investments in Housing-Related Projects32

SLFRF Tribal Housing and 

Infrastructure Projects

Housing Stabilization Programs33 583

New Construction and Home 

Preservation Projects 269

Drinking Water Projects 102

Clean Water Projects 100

Broadband Projects34 54

Water and Sewer Projects 43

 Total SLFRF Tribal Housing and 

Infrastructure Projects 1,151 

The ERA1 program concluded in 2022, and Tribes 

are now in the award closeout phase. Many Tribes 

leveraged the program flexibilities, reallocation 

funding, and adopted Treasury’s shared best practices 

to rapidly disburse assistance to renters in need. 

Participating Tribes and TDHEs leveraged ERA1 

funding to make over $611 million in assistance 

payments to help renters facing eviction with rent, 

utilities, and housing stability services.

“Tribal governments have committed funds for 

1,151 housing and infrastructure-related projects 

with their SLFRF awards.”

11
TABLE 7

ERA1 Stabilization Supports to Tribal Households35

ERA1 Households Receiving 

Assistance by Category36

Rent 188,631 

Utility and Home Energy Costs 133,761 

Other Expenses Related to 

Housing 22,124 

Housing Stability Services 16,315 

For the HAF program, Tribal governments have 

budgeted37 over $450 million in mortgage payment 

assistance, reductions, or reinstatements and 

displacement prevention. 

35 The categories of rent and utilities and home energy costs include arrears. 

36 ERA1 households may have received more than one category of ERA1 support.

37 The majority of HAF Tribal participants will report their first full year of program data in November of 2023.

38 The majority of Tribal governments received LATCF payments in 2023.

TABLE 8

HAF Planned Assistance to Tribal Households for 

Stabilization and Preservation 

HAF Planned Assistance

Mortgage Assistance and 

Reinstatement $186 Million

Displacement Prevention, 

Including Home Preservation $97 Million

Utility, Internet, Insurance and 

HOA Costs $82 Million

Principal and Interest Rate 

Reduction and Loan Assistance $15 Million

Property Tax Assistance $15 Million

Counseling or Education $2 Million

Program Support $53 Million

Total HAF Planned Assistance $450 Million 

While the LATCF program is in its early stages,38 Tribes 

have shared that they plan on using funding for land 

purchases and housing-related programs. 

Photo Credit: Quapaw Tribe

12
13

As the pandemic began, the unemployment rate in the 

United States hit an unprecedented level at 14.8 percent.39

In comparison, the Native American unemployment 

rate climbed to 28.6 percent40 - with the closure of Tribal 

businesses in gaming and hospitality being a leading 

factor. These closures pushed many Native households 

across Indian Country to fall behind on their rent and 

mortgages, many of whom already struggled with the 

cost of housing. The negative economic impact of the 

pandemic not only impacted renters but also affected the 

Tribal governments’ bottom line. With so many families 

unable to pay rent and utilities, units owned and operated 

by the Tribe or TDHE also saw revenue fall. 

Under Treasury’s ORP programs, Tribes pursued housing 

stabilization and related services to protect vulnerable 

renters and homeowners. For example, ERA1, HAF, and 

SLFRF awards have provided stabilization assistance to 

households to keep families in their homes, and Tribes 

have strengthened wrap-around services for housing 

stabilization. These innovations underscore the ability 

of Tribes to implement ORP programs in adaptable and 

creative ways.

•	 The Blackfeet Nation is utilizing SLFRF to 

renovate a youth homeless shelter for the over 

300 children who face housing instability yearly on 

the 1-million-acre reservation, located along the 

eastern slopes of the Rocky Mountains. The Tribe 

sees the shelter as crucial to protecting vulnerable 

youth seeking safe harbor from dangerous 

living situations. The Tribe is also investing in 

transitional housing for juveniles.

•	 The Chignik Bay Tribal Council is located in 

an area known for extreme cold in Alaska. The 

community depends on a once-a-year shipment 

of supplies, including fuel oil that generates power 

and heats homes. Under the SLFRF revenue loss 

eligible use category, the Tribe funded a generator

for the town of Chignik, which supplies central 

power and heating to individual households. 

39 Congressional Research Service. (2021, March 12). Unemployment Rates During the COVID-19 Pandemic: In Brief.

40 U.S. Bureau of Labor and Statistics. (2022). Labor Force Statistics from the Current Population Survey. (LNU04035243) [Data set]. https://

data.bls.gov/timeseries/LNU04035243

•	 The Housing Authority of the Sac and Fox 

Nation, located in rural Oklahoma, assisted nearly 

1,100 native and non-native households with 

rent and utility support with its ERA1 award. With 

pandemic-related moratoriums and utility shutoffs for water and electricity expiring, the TDHE 

prioritized getting qualified citizens caught up 

with overdue heat, electricity, and water bills.

Nome Senior Apartments, an 18-unit elder housing facility, 

owned and managed by BSRHA.

Photo Credit: Bering Straits Housing Authority

The Bering Straits Housing Authority (BSRHA)

is headquartered in Alaska and is the Nome 

community’s primary service provider of affordable 

homes. Through the ERA1 program, the BSRHA 

partnered with local social services departments, 

behavioral health services, and reentry 

specialists to focus on citizens most in need to get 

them in to stable rental housing. On average, over 

230 ERA1 applications were received each quarter. 

Seventeen previously homeless citizens were placed 

in rental housing in the Nome area, where average 

winter temperatures are -2°. The Housing Authority 

reported that since BSRHA started the ERA1 program 

and targeted unhoused citizens and those leaving 

the Anvil Mountain Correctional Center, the number 

of ambulance calls in the area was cut in half.

•	 The Native Village of Kluti-Kaah, with lands near 

Anchorage, Alaska, has an average temperature for 

the year of 29.2°F. To support the need for stable 

heating, the Tribe is carrying out a firewood program

Housing Stabilization
14

through its sawmill using SLFRF funds under the 

revenue loss eligible use category. Firewood is an 

inexpensive and culturally relevant source for both 

heating and cooking. The program ensures homes are 

heated and creates jobs for Tribal citizens.

•	 The Otoe-Missouria Tribe of Indians is providing 

mortgage, utility, and property tax assistance

with its HAF award to all qualified Tribal citizens who 

live nationwide. Homeowners are eligible to receive 

up to $20,000 in assistance. The Tribe has a goal of 

preventing at least 50 homes from foreclosures.

•	 The Penobscot Nation reservation is in a highcost-of-living area within Maine where many 

citizens rely on hotels and room rentals for 

housing. Due to seasonal tourism, those needing 

emergency housing and rentals often face 

homelessness in the summer months when hotels 

and rental homes significantly increase prices. The 

Tribe collaborated with local agencies to create 

a rapid response to housing to ensure eligible 

households under their ERA1 program were not at 

risk of losing their homes.

•	 The Saginaw Chippewa Indian Tribe of Michigan

is coordinating with a local non-profit for 

outreach and with mortgage servicers to assist 

Tribal homeowners facing financial instability. 

Their HAF program is helping prevent avoidable 

foreclosures and delinquencies. The Tribe’s 

program includes payment assistance for first 

mortgages, reverse mortgages, home equity 

conversion mortgages, contracts for deeds or land, 

and loans secured by manufactured housing. 

Construction is underway in Oklahoma for the Quapaw Tribe’s 

Tiny Homes Village. 

Photo Credit: Quapaw Tribe

The Quapaw Tribe is building tiny homes for victims 

of domestic violence with its SLFRF award funds. 

Domestic violence, a leading cause of homelessness 

among women and children, increased during the 

pandemic. These temporary housing options aim 

to reduce the incidence of domestic violence by 

supporting victims with a safe space to live and 

address housing instability. The Tribe will partner 

with social services to provide culturally relevant 

healing and recovery services.

Home Preservation

While many Native American families have a cultural preference for living in multi-generational households and 

believe that it enhances family life, overcrowding was a major challenge during the pandemic because of stayat-home restrictions. Additionally, homeowners who experienced financial hardship due to the pandemic may 

have delayed essential home repairs to pay other bills and obligations. 

With these issues in mind, Tribes have looked to use their SLFRF and HAF awards to reduce overcrowding, 

without giving up a traditional lifestyle, by extending rooms, renovating spaces to make the home habitable, 

and other structural improvements. The HAF program supports home preservation, which is an essential 

intervention to prevent displacement. Under the SLFRF program’s housing-related enumerated eligible use 

categories and the revenue loss eligible use category, Tribes have broad authority to choose how to implement 

affordable housing projects – including serving citizens who live away from their Tribal homelands. Typically, 

Native Americans who do not live in Tribal areas do not qualify for other federal home improvement programs 

that the Tribe receives. For the first time, Tribal governments have the potential to assist all eligible Tribal 

citizens, regardless of their location.
15

Treasury Deputy Secretary Wally Adeyemo talking with members 

of the Torres Martinez Desert Cahuilla Indians about flooring and 

bathroom renovations received through the HAF program.

Photo Credit: Taya Gray/The Desert Sun

The All Mission Indian Housing Authority (AMIHA)

serves 14 reservations in three counties in California. 

Through the HAF program, AMIHA is providing 

mortgage assistance and safe housing for Native 

Americans residing on reservations, incorporating 

traditional concepts and values in service delivery. 

The HAF program has funded repairs to structural 

damage and rehabilitation of homes for low-income 

households impacted by the Salton Sea flood and 

earthquake damage.

•	 The Fort Belknap Indian Community is using 

SLFRF funds for an elderly housing repair 

assistance program to incorporate accessibility 

floorplans, handicap ramps, appliances, and 

important age-in-place features that will support 

independence.

•	 The Native Village of Saint Michael will 

rehabilitate 29 homes that have severe structural 

issues and facilities conditions. Funded by a 

combination of its SLFRF and HAF awards, these 

homes will also receive electrical upgrades to 

ensure the safety of homeowners. 

•	 The Nez Perce Tribe experienced a devastating 

flood in 2019, which caused flood waters to rise 

around homes and shut down roads. As a result, 

insurance costs have risen. The Tribe is utilizing 

the HAF program to support Tribal citizens with 

home repairs, homeowner’s insurance, including 

flood insurance, and other allowable home 

stabilization costs. 

•	 The Navajo Nation is installing 582 waterlines 

and 478 cistern systems for collecting and storing 

water. The SLFRF project will ensure families can 

access clean drinking water in their homes. 

•	 The Pascua Yaqui Tribe is funding a Homeowner 

Repair Program for Elders with its SLFRF 

funds. The program provides funding to improve 

plumbing, heating, roof repairs, wheelchair ramps 

and railings, and other essential repairs for those 

age 55 and older.

•	 The Winnebago Tribe is committed to providing 

affordable, dependable housing on the Winnebago 

reservation. Within the reservation and town 

boundaries are vacant lots with houses needing 

repairs and abandoned structures that pose safety 

hazards. SLFRF funds will support renovating 

structures and demolishing abandoned 

property. The project aims to increase housing 

stability and housing stock within Winnebago.

Treasurer Chief Lynn Malerba and Deputy Secretary Wally 

Adeyemo met with recipients of the HAF program and Tribal 

leadership at the Chickahominy Indian Tribe in Virginia. 

The Chickahominy Indian Tribe spent many years 

working on federal recognition. Shortly before the 

pandemic, the Tribe gained recognition from the 

federal government as a sovereign nation. Despite 

being displaced and not having a reservation, the 

majority of Tribal citizens still live within five miles 

of the Tribal center, which is located near the site of 

a pre-contact village. Today, the Tribe is utilizing its 

HAF award to prevent homeowner displacement by 

targeting homes with “conditions” to make them 

safe and suitable to live in.
16

•	 The Delaware Tribe of Indians is devoting its 

SLFRF award funds toward capital resource 

assistance. The Tribe’s down payment assistance 

program is designed to help Tribal citizens 

become home buyers and ease the financial 

burden of a home purchase. 

•	 The Hoh Indian Tribe is located on the Pacific 

coast of the Olympic Peninsula, where rising sea 

levels have caused erosion and a shortage of 

land for stable housing. The Tribe believes that 

climate change has profound implications for how 

it affects the future way of life and health of Tribal 

citizens. Over 90 percent of the Hoh reservation 

is located within a 100-year flood plain, and 100 

percent is within a tsunami zone. The Tribe is 

using its SLFRF award to invest in infrastructure 

for new affordable homes that will be built at 

higher elevations.

•	 The Lac Courte Oreilles Band of Lake Superior 

Ojibwe estimates that there is a housing shortage 

41 Chairman Vernon Miller. (2017). Omaha Tribe of Nebraska Testimony to the House Committee on Natural Resources. https://docs.house.

gov/meetings/AP/AP06/20160318/104633/HHRG-114-AP06-Wstate-MillerV-20160318.pdf

of nearly 500 homes in the community. In addition 

to addressing overcrowding, the housing shortage 

makes attracting workers such as teachers, 

healthcare workers, and other professionals a 

challenge. The Tribe invested SLFRF funds to build 

a 40-unit apartment building with one- and 

two-bedroom units.

•	 The Manchester-Point Arena Band of Pomo 

Indians is braiding federal funds to alleviate 

severe overcrowding. Using SLFRF funds under 

the revenue loss eligible use category, the Tribe 

purchased five parcels of land to provide housing 

and is partnering with Indian Health Service 

to build the water infrastructure needed to 

accommodate the new housing. 

•	 The Omaha Tribe of Nebraska is located on 

a reservation where much of the land is no 

longer tribally owned due to allotment policies. 

Allotment policies, along with an unemployment 

rate of 69%41 has made home ownership 

Firefighters from the Carson Hotshots in the Klamath 

national forest. 

Photo Credit: Bryan Denton/The New York Times

The Karuk Tribe faced a fire that raged through the 

ancestral heart of the Tribe in the Klamath Mountains 

in September 2020. The wildfire burned over 200 

homes in a community of 1,000, causing a rapid 

increase in homelessness. The Tribe is investing its 

SLFRF award in permanent housing and purchased 

temporary travel trailers, including handicapaccessible options, to meet the needs of families.

New Housing Construction

The opportunity for new construction for Tribal citizens living on reservations remains limited and expensive. 

In July 2022, Treasury expanded the flexibility for recipients to use their SLFRF awards to invest in long-term 

affordable housing projects. This flexibility was introduced, in part, after discussions with Tribal leaders and 

housing associations who reinforced that additional flexibility was needed to fully leverage their SLFRF awards 

for affordable housing construction.

Consistent with the SLFRF program’s flexibility, Tribes are using these fiscal recovery dollars for a wide variety 

of housing activities to address the unique access to capital and land challenges in ways that best serve their 

communities. 
17

challenging for Tribal citizens. With its SLFRF 

award, the Tribe is purchasing surplus homes 

within the reservation boundaries that are 

tax-defaulted properties. The opportunity 

presents itself not only for permanent affordable 

housing for Tribal citizens but also for reclaiming 

the “land back.” 

•	 The Southern Ute Indian Tribe has a territory that 

expands across three counties in Colorado. The 

Tribe’s “Broadband Band Modernization Project” 

braids its SLFRF award funds with other sources 

of broadband funding to provide 95 percent of 

the reservation’s new construction and existing 

homes with fiber optic internet. 

•	 The Spokane Tribe of Indians is taking proactive 

measures to address water deficiencies for existing 

homes and new home construction. The Tribe is 

investing SLFRF funds in several water and sewer 

projects and will make improvements to expand 

the water system for future home construction. 

•	 The Suquamish Tribe is leveraging its SLFRF award 

to address a lack of housing caused by the Tribe’s 

“checkerboard” reservation, where the Tribe 

owns some of the land and some of it is owned by 

non-natives. Historically, this has made building 

sustainable housing incredibly difficult. With 

SLFRF funds, the Tribe is constructing four multifamily townhome structures with multiple stories. 

Approximately 25 percent of the parking (10 stalls) 

will include electric vehicle charging stations.

•	 The Yakutat Tlingit Tribe is located on the 

northern coast of the Gulf of Alaska where lands 

span over 9,400 square miles. The Tribe recognized 

that attracting qualified health professionals was 

an ongoing challenge due to a lack of housing 

options for medical care providers. The Tribe 

is investing its SLFRF award funds to build 

affordable housing to recruit and retain highly 

trained medical professionals. 

Home built with SLFRF at the Louden Tribal Council (Galena Village).

Photo Credit: Louden Tribal Council (Galena Village)

The Louden Tribal Council (Galena Village) endured 

a devastating ice jam on the Yukon River in 2013, 

which caused waters to surge more than 15 feet 

overnight. An ice jam happens when chunks of ice 

clump together to block the flow of a river. The 

disaster destroyed many homes and structures, 

leaving some community members homeless. The 

Tribe is nearly 300 miles from the closest road, and 

the remoteness makes purchasing building supplies 

unfeasible. Funding from its SLFRF award will build 

new homes, and its HAF award will be used to 

rehabilitate homes in need of repairs. The 

construction is creating jobs and training 

opportunities for citizens.
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Continuing to Support Tribal Housing Stability

The resilience of Tribal communities is evident in their strong responses to the COVID-19 pandemic – as 

the importance of federal funding to support the continued economic development of Indian Country. The 

ARPA funds and other federal resources administered by the Treasury Department under the Biden-Harris 

Administration have often been referred to as an unprecedented “once in a lifetime” opportunity. Guided 

by regional priorities and objectives, the ARPA funding has served as a crucial resource for housing stability 

and establishing new affordable housing options for disadvantaged families. Constructing new homes and 

preserving older ones has created employment for Tribal citizens. These activities have ripple effects on 

the Tribal economy – including Native-owned small businesses – as well as surrounding local and regional 

economies. The ARPA and other federal funding outlined in this report has been a valuable addition to the 

yearly IHBG formula funding, the New Markets Tax Credit Program, the Low-Income Housing Tax Credit 

Program, and National Telecommunications and Information Administration broadband grants. 

Treasury will continue to engage with Tribal leaders and staff on compliance, assisting recipients on reporting, 

and discussing careful stewardship in carrying out the requirements of their awards.

Home built in the Rosebud Sioux Tribe’s high-tech manufacturing 

plant. 

Secretary Janet Yellen at the Rosebud Sioux Tribe’s high-tech home 

manufacturing plant.

The Rosebud Sioux Tribe is investing SLFRF funds in several substantial housing projects on its reservation, 

which spans 922,759 acres in South Dakota. The Tribe is tackling housing shortages and overcrowding by 

becoming its own builder. The Tribe is utiliz-ing a Tribal business to manufacture homes, which is also creating 

jobs for the community. The 33,600-square-foot facility has the capacity to build as many as 48 homes for lowincome families each year.
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About the Office of Tribal and Native Affairs

The Office of Tribal and Native Affairs within the U.S. Department of the Treasury is committed to working with 

Tribal governments and Indigenous communities to promote economic prosperity. The Office is overseen by 

the Treasurer of the United States, Chief Lynn Malerba, the first Native American to hold this position. The Office 

was established in September of 2022 by Secretary of the Treasury Janet L. Yellen to serve as a hub for Tribal 

policy and is part of the efforts to develop Treasury’s growing relationship with Tribal nations. The Office works 

across departmental offices to assist in implementing economic relief and recovery programs, the development 

and implementation of tax policies and tax credit programs, and reviewing regulations and rulings that impact 

Tribal communities. The staff has hosted numerous consultations on Tribal tax matters, the Inflation Reduction 

Act, the CDFI Fund, and recovery funds, ranging from the distribution of funds to guidance to the applicability of 

certain compliance standards to support an equitable and swift recovery from the challenges brought on by the 

COVID-19 pandemic.
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