Temporary Assistance for Needy Families: HHS Needs to Improve Guidance and Monitoring of Tribal Programs
Released: 2011-10-17T00:00:00

Letter

Background

According to 2009 population estimates from the U.S. Census Bureau, about 3.2 million U.S. residents identify themselves as solely of American Indian or Alaska Native origin. Furthermore, the Bureau of Indian Affairs (BIA) in DOI reported that for 2005—the most recent year for which data are available—the total number of enrolled members in federally recognized American Indian and Alaska Native tribes and villages was nearly 2 million. American Indians have high rates of poverty, unemployment, single-parent families, and substance abuse relative to the population as a whole. BIA reported that the unemployment rate for American Indians living on or near a reservation was 49 percent in 2005, the most recent year for which data are available, while the Bureau of Labor Statistics reported a national unemployment rate of 5 percent for the same year. A recent study by the Economic Policy Institute noted that from the first half of 2007 to the first half of 2010, the national American Indian unemployment rate—which includes individuals living in both urban areas and on tribal lands—increased 7.7 percentage points to 15.2 percent, while it increased 4.9 percentage points to 9.1 percent among Caucasians. Additionally, in 2009, 53 percent of American Indian children lived in single-parent families, compared with 34 percent of all children nationwide. HHS data estimates for 2004 through 2008 indicate that the percentage of American Indians or Alaska Native adults who needed treatment for alcohol or illicit drug use problems in the past year was higher than the national average (18 percent and 10 percent, respectively).

As of October 2010, there were 565 federally recognized tribes—340 in the continental United States and 225 in Alaska. Federally recognized Indian tribes are Native American groups eligible for the special programs and services provided by the United States to Indians because of their status as Indians. Under the Indian Self-Determination and Education Assistance Act, as amended, federally recognized Indian tribes can enter into self- determination contracts or self-governance compacts with the federal government to take over administration of certain federal programs for Indians previously administered by the federal government on their behalf.

Tribal lands vary dramatically in size, demographics, and location. The largest reservation, that of the Navajo Nation, is about 24,000 square miles in size and is inhabited by more than 176,000 American Indians. In comparison, some of the smallest tribal lands, held by California tribes, take up less than 1 square mile and some tribal lands have fewer than 50 Indian residents. Some Indian reservations have a mixture of Indian and non-Indian residents. In addition, most tribal lands are rural or remote, although some are near metropolitan areas.

Legislation Authorizing Tribal TANF

Although tribal members were previously served through state AFDC programs, under PRWORA, they can be served through tribal or state TANF programs. Tribal and state TANF programs may use TANF funds in any manner reasonably calculated to accomplish the purposes of TANF. These purposes are to (1) provide assistance to needy families so that children can be cared for in their own homes or in the homes of relatives; (2) end needy parents’ dependence on government benefits by promoting job preparation, work, and marriage; (3) prevent and reduce the incidence of out-of-wedlock pregnancies; and (4) encourage the formation and maintenance of two-parent families. Like states, tribes generally have the flexibility to set their own TANF eligibility requirements, to determine what policies will govern mandatory sanctions for noncompliance with program rules, and to determine what types of work supports they will provide to recipients, such as child care, transportation, and job training. However, some of the federal requirements for state TANF programs differ from those for tribal TANF programs (see table 1).

Before the 1996 welfare reforms, some tribes were operating their own Tribal Job Opportunities and Basic Skills (JOBS) programs that provided work and training activities. These tribes remained eligible to provide these services through the Native Employment Works (NEW) program when PRWORA repealed the JOBS program. As of January 2011, 31 tribes and tribal organizations operate both a tribal TANF program and a NEW Program.

More recently, in 2006, DRA made several modifications to state TANF programs, none of which applied to tribes. DRA also reauthorized TANF through fiscal year 2010, and the Claims Resolution Act of 2010 extended it through fiscal year 2011.

State Matching MOE Funds

TANF has a maintenance-of-effort (MOE) provision that requires states to maintain a significant portion of their historic financial commitment to their welfare programs. States are not required to provide funding to tribal TANF programs, but many do so. As of July 2010, HHS data indicate that 54 of 64 tribal TANF programs received state funding. Contributions made by states to tribal TANF programs generally count toward a state’s MOE requirement.

Agencies Overseeing Tribal TANF Programs

The Office of Family Assistance within the Administration for Children and Families (ACF) in HHS is the main federal agency responsible for overseeing tribal TANF programs. Both HHS’s headquarters office and 6 out of 10 regional offices have staff that work directly with tribes to help them implement and maintain their tribal TANF programs. Tribal TANF is a block grant, and we have previously found that building accountability into block grants is an important, but difficult, task requiring trade-offs between federal and state—or in this case, tribal—control over program finances, activities, and administration. HHS holds tribes accountable, in part, through the tribes’ reporting requirements, which are similar to those for state TANF programs. For example, tribes have to submit quarterly reports that include caseload data, data used to calculate work participation rates, and financial information. In addition, per the Single Audit Act, as amended, all states—including tribal governments—local governments, and nonprofit organizations expending $500,000 or more in federal awards during one fiscal year are required to obtain an audit in accordance with the requirements set forth in the Single Audit Act.

In addition to the TANF block grant that tribes receive from HHS, the Recovery Act’s TANF Emergency Contingency Fund provided up to $5 billion to help states and tribes in fiscal years 2009 and 2010 that had an increase in caseloads or in certain types of expenditures. HHS provides these funds to tribes as a reimbursement for expenses incurred no later than September 30, 2010. According to HHS, the funds a jurisdiction receives as reimbursement are available without fiscal year limitation and can be spent in any way permissible under TANF. According to HHS, 24 tribes have received Emergency Contingency Fund grants totaling approximately $14 million as of June 2011.

The Indian Employment, Training and Related Services Demonstration Act of 1992 provides tribes with additional program and funding flexibilities. Specifically, it allows DOI to authorize federally recognized Indian tribes to combine funds they receive from various federal agencies and programs for employment, training, and related services, such as TANF, into one program, called a “477 plan.” These plans help tribes streamline funding from as many as 11 different federal sources by utilizing a single budget and a single reporting system. According to a DOI official, eligible grant funds include formula-funded programs in HHS, DOI, and the Department of Labor. DOI oversees these plans at the federal level. As of July 2011, 15 tribes incorporate their tribal TANF programs into these plans.

Since 2002, More Tribes Have Used Program Flexibilities to Tailor Services and Cope with Changing Economic Conditions

More Tribes Administer Their Own TANF Programs and Serve Native Families Outside of Their Tribes

The number of tribal TANF programs has increased from 36 in 2002 to 64 in 2010 (see fig. 1), and several additional tribes are actively pursuing administering their own programs. Most of the tribes that have begun administering their own program since 2002 had no previous experience managing a TANF program; however, according to information provided by HHS, at least two tribes that were previously served as part of a larger tribal TANF consortium of tribes have decided to administer their own programs. For a list of all tribes administering a TANF program, including those tribes who were previously served as part of a larger tribal TANF consortium, see app. II. In addition to the 64 tribal TANF programs in operation in 2010, HHS officials stated that as of April 2011, 11 more tribes were actively pursuing starting their own program.

The number of tribes served by tribal TANF programs has also increased from 174 in 2002 to at least 272 in 2010, and more of the tribes administering their own programs are serving Native families outside of their own tribe. Tribes have the flexibility to determine whom their program will serve as well as their service area—the geographic area that their TANF program will cover. In 2002, we reported that 16 out of 36 tribes (44 percent) served only their own enrolled tribal members. According to our review of tribes’ TANF plans, 16 out of 64 tribes (25 percent) administering a program serve only members of their tribe whereas 48 tribal TANF programs (75 percent) extend their services and benefits to families who are not enrolled members of their tribe. For example, according to their most recently approved TANF plan, the Oneida Tribe of Indians of Wisconsin serves both enrolled tribal members as well as other Indians who are members of federally recognized tribes residing on its reservation who are eligible for TANF, whereas the Hopi tribe serves only its own enrolled tribal members. We also found that according to HHS data, 11 of the 64 tribal TANF programs have expanded in order to serve more Native families in nearby or surrounding areas. For example, the California Tribal TANF Partnership began administering TANF in 2003 and has expanded its program at least three times since then to include more tribes. As of May 2011, this partnership was associated with 35 tribes and other organizations, and its TANF program service area spanned 14 different counties in California.

Nationwide, the total number of families receiving tribal TANF cash assistance has increased since 2002, primarily because the number of programs has grown, but also because of varied caseload increases among existing programs. Figure 2 below shows the changes in the nationwide average monthly number of families receiving tribal TANF cash assistance since 2002. As shown, the total nationwide average monthly caseload increased almost every year between 2002 and 2009; in some years, increases were driven primarily by the addition of new programs. However, aggregate changes from year to year hide significant variation in caseload trends among programs. For example, between 2008 and 2009, the majority of tribal TANF programs experienced increases in their average monthly caseloads, but some saw their caseloads decline. And even where increases occurred, they varied widely. A couple of smaller programs—which serve a dozen or fewer families on average per month— saw their average monthly caseloads increase by as few as four families, which represents caseload increases of about 33 and 67 percent, respectively. In comparison, a couple of the larger programs saw their average monthly caseloads increase by more than a hundred families, representing caseload increases of about 16 percent and 21 percent, respectively. While tribal TANF programs range in size, the majority of these programs are relatively small, and according to preliminary fiscal year 2009 caseload data provided by HHS, 41 out of 63 tribes reporting caseload data had an average monthly caseload of less than 200 families.

Tribes report that the flexibility they are given to tailor their tribal TANF programs allows them to address the specific needs of their TANF families. All 50 of the tribes responding to our survey reported that the flexibility to provide employment-focused and education-related services to families was a very major or major benefit to administering their own TANF program (see fig. 3). In addition, 49 out of 50 tribes reported that the ability to administer and deliver TANF services in a culturally sensitive manner and the ability to tailor the program to the needs of their community were very major or major benefits to administering TANF. One tribe responding to our survey reported that administering TANF encourages nation-building by strengthening the tribe’s social fabric and by helping to develop their tribal workforce. Similarly, a study conducted by Mathematica Policy Research, Inc. notes that tribal control of TANF affords tribes the opportunity to improve services for program participants and expand program coordination.

In addition, we found that tribes continue to use the flexibility to set their own work participation requirements. According to tribes’ fiscal year 2009 work participation data provided by HHS, participation rate requirements for both newer and more-established programs combined ranged from 20 to 50 percent. In 2002, we reported that most of the tribes’ work participation rates generally ranged from 15 to 30 percent over the first few years of the tribal TANF program. We also found that some tribes have increased their rates over time. For example, more than half of the 36 tribes that have been administering a TANF program since 2002 have raised their work participation rate goals over time. One tribe gradually raised its work participation rate goal for all families more than 10 percentage points over the course of 8 years, from 35 percent to 48 percent. According to tribes’ TANF plans, minimum work requirements vary among tribes, and while one newly established program required 22 percent of all tribal TANF families to participate in 16 hours of work each week in fiscal year 2010, another more-established program required 35 percent of all families to participate in a minimum of 40 hours of work each week. According to HHS data, of those tribal TANF adults required to participate in work activities, a higher percentage were participating and meeting minimum requirements in 2009 than in 2002 (see fig. 4).

Our review of tribes’ TANF plans shows that the majority of tribes administering TANF programs count work activities beyond the 12 identified in PRWORA toward meeting work participation requirements, and over time tribes have increased the number and types of activities they count as work activities. PRWORA provides tribes the flexibility to count a wide spectrum of activities as work activities, which helps them accommodate the training needs and cultural traditions of their recipients. Some tribes count cultural activities (including beading and participating in tribal ceremonies), NEW participation (including educational activities and training and job readiness activities), and commuting time toward meeting work participation rate requirements. For example, the California Tribal TANF Partnership allows tribal TANF recipients to participate in cultural activities, such as basket weaving, to help meet work participation requirements (for a related photo of the basket weaving activity, see app. III). Furthermore, in 2002, we reported that 1 out of 36 tribal TANF programs (3 percent) counted commuting time toward meeting work participation requirements. In 2010, according to our analysis of tribes’ TANF plans, we found that 35 out of 64 tribes (55 percent) counted commuting time toward meeting work participation requirements.

Some of the activities tribes count as work activities, including receiving counseling, substance abuse treatment, and participating in life skills and parenting classes, are used by tribes to support the more family-oriented goals of the TANF program, such as preventing and reducing out-of- wedlock pregnancies, promoting marriage, and encouraging the formation and maintenance of two-parent families. For example, the Forest County Potawatomi tribe offers classes such as Positive Indian Parenting, Healthy Relationships, and Nurturing Fathers, and counts time spent in these classes toward work participation requirements (see fig. 5). These types of activities may benefit TANF families, even when they do not lead directly to paid employment. For more examples of work activities that tribes use to meet their work participation rate requirements, see photos from our site visits in appendix III.

Both in our survey and during our site visits, tribes reported that the recent economic downturn has contributed to an increase in the size of their TANF caseloads, in part because it has exacerbated the scarcity of job opportunities within and near their service areas. In all, 30 of the 50 tribes that responded to our survey question reported that as of September 2010, their average monthly caseload was larger than when their tribal TANF program first began providing services; and of those, 12 reported that the increase was due to economic conditions or high unemployment. One tribe in particular said that its caseload was higher in September 2010 because there had been job layoffs and because companies in their area had been consolidating positions or not hiring. According to preliminary data provided by HHS, seven out of 55 tribes were serving at or above their program capacity in fiscal year 2009.

An Oneida tribal TANF staff member told us that because there are fewer jobs available in their area, there could be over 100 people to apply for an entry-level position at a fast food restaurant. Another tribe we met with, the Hopi tribe, said that, despite the lack of employment opportunities on the reservation, many tribal members have moved back to the reservation after the economic recession caused them to lose their jobs, which has further strained the tribes’ resources and contributed to an increase in their average monthly caseload.

Changing economic conditions have in some instances led to reductions in state contributions to tribal TANF programs. Most states with tribal TANF programs have in the past provided tribes with state funding, but some are revisiting this commitment in light of tight fiscal conditions. In an effort to address a growing shortfall in its budget for TANF, the state of Washington, for example, reduced funding for tribal TANF programs effective January 2011, reducing funding that tribes in the state have relied on to help administer their TANF programs. Similarly, in the state of Arizona, a tribe we spoke with said that the state has had to cut back on funding for TANF-related programs. For example, the tribe said that its parenting program used to be funded by five different grants from the state, but because the state faces budget deficits, it has cut both the number of grants and the amount of funding for the program.

In response to the economic recession that began in 2007, the Recovery Act created the $5 billion TANF Emergency Contingency Fund for states and tribal TANF programs. Tribes can qualify for these funds based on increases in the number of families receiving cash assistance or in TANF expenditures for nonrecurrent, short-term benefits or subsidized employment. As of June 2011, 24 tribes had received Emergency Contingency Fund grants totaling approximately $14 million. According to our review of tribes’ HHS-approved Emergency Contingency Fund applications, 21 out of the 24 tribes demonstrated an increase in the number of families receiving basic assistance. Fifteen tribes showed increased expenditures for funding for nonrecurrent, short-term benefits, and 9 tribes requested funds due to increased expenditures for subsidized employment needs. Once a tribe received the Emergency Contingency Fund grant, the funds could be spent on any TANF-related purpose for TANF-eligible families. For example, 22 of the tribes responding to our survey applied for and received Emergency Contingency Fund grants, and of these 22 tribes, 17 reported using these grants to expand existing tribal TANF services and programs. Furthermore, more than half of these 22 respondents reported using Emergency Contingency Fund grant funding to issue more cash grants or to fill TANF budget gaps caused by the recession. While two of the tribes we visited said that they used Emergency Contingency Fund grants to fund cash grants for families, another tribe said they used the funds for supportive services, such as providing approximately 700 children with school clothes.

According to our survey and site visits, the recent economic downturn has also affected the types of TANF services some tribes are providing to participants. Of the 49 tribes that responded to our survey question, 39 (80 percent) reported that since the beginning of the economic recession in 2007, they have increased their provision of nonrecurrent, short-term benefits—emergency payments to families to cover housing, utilities, transportation, or other expenses. For example, the Forest County Potawatomi stated in their application to HHS for Recovery Act funds that as a result of current economic conditions, they have been providing more assistance to help families with car repairs and utilities. Other tribes have had to cut back on supportive services so that they could provide more TANF families with basic cash assistance. The Lac du Flambeau tribal TANF staff reported having to reduce spending on alcohol and other drug abuse programs as a result of economic conditions.

Tribal TANF Programs Face Various Administrative and Other Challenges, and Many Partner with Other Entities to Address Them

Tribes Reported Challenges with Initial Program Implementation, Staffing, Data Systems, and Overcoming Barriers to Participants’ Self- Sufficiency

The majority of tribal TANF programs that responded to our survey reported that they have faced administrative challenges related to initial program implementation, staff development and retention, and development of adequate data systems (see fig. 6). In addition, all 11 tribes we visited talked about other challenges related to overcoming the various barriers to self-sufficiency that their TANF participants face, such as a lack of transportation and limited employment opportunities.

According to survey respondents, some of the top challenges were:  Staff development and retention. Many tribes face challenges in finding, developing, and retaining their TANF staff. One tribe we visited said that it has been difficult for them to hire knowledgeable staff, such as a TANF program manager that is familiar with the program’s goals. According to HHS officials, another tribe lost their tribal TANF director 3 years ago and has struggled to find someone to permanently fill that position. Our survey results also indicate that 38 out of 49 tribes (78 percent) responding to the question have had difficulty in developing expertise in the staff they do employ. For example, one tribe said that while it was important for them to hire locally based staff for its TANF program, it was difficult to do so because not only were there very few qualified applicants, but also because there was a lack of training opportunities for new staff not familiar with the administration of TANF. Another tribe noted that they had to train and develop their own staff, as state TANF caseworkers often had Master’s degrees in Social Services, while most of their own caseworkers did not. Furthermore, once tribes have hired and developed their staff, it is increasingly difficult for them to retain that staff. One tribal TANF administrator we spoke with said she had about three to four different supervisors during the last 4 years. An HHS official also told us that, in his opinion, staff turnover can affect tribal TANF programs more dramatically than state TANF programs since tribes may lack the institutional knowledge and experience necessary to administer the program and provide training to staff. systems that can support their TANF programs. While tribes can use a percentage of their TANF grant for developing a new information system, this would decrease the amount of funding available for direct services to TANF families.

With a reservation spanning about 24,000 miles and three states—Arizona, New Mexico, and Utah—the Navajo Nation refers to its TANF program as the Program for Self-Reliance, in order to reflect its mission to empower families to become self-sufficient. A tribal TANF administrator said that having the flexibility to design a program that incorporates the Navajo teaching of Taa’ hwo ajit eego laid the groundwork to “break the cycle” of dependence and instill self-confidence.

In addition to the challenges outlined above, tribes we visited identified several barriers to self-sufficiency faced by their TANF participants that present challenges to their programs. These barriers include limited public transportation, employment opportunities, child care options, and educational attainment, among others. All 11 tribes we visited mentioned the availability of transportation as a challenge, with tribal TANF officials noting that many of their program participants lack a valid driver’s license or have limited or no public transit options. Many tribes also said that their TANF participants have limited job opportunities. The Forest County Potawatomi tribe, for instance, told us that few jobs exist for TANF participants because of recent closures of logging mills and because seasonal jobs are only available during the summer months. This same tribe said that due to its rural setting and recent child care facility closures, TANF participants have limited options for child care, hampering their ability to work. A lack of education among participants also affects their ability to secure employment. One tribe told us that its TANF participants, some of whom have only earned their General Equivalency Diploma, have had a harder time competing for jobs during the economic recession. Furthermore, of the 11 tribes we visited, 6 mentioned substance abuse, domestic violence, or both as barriers to their TANF participants’ self-sufficiency.

When tribes experience challenges administering their TANF programs, they often turn to other entities for assistance, such as HHS, other tribal and federal programs, and consultants, among others. In particular, those responding to our survey reported that they most commonly contact HHS regional office staff, other tribes, and private consultants (see fig. 7). In addition, 9 out of the 11 tribes we visited indicated that they also work with other federal programs to help address challenges.

According to our survey, tribes most commonly contacted HHS regional office staff for assistance. All 48 tribes responding to this question (100 percent) selected “yes” for this question in our survey. According to HHS officials, tribes often reach out to their regional offices for guidance and technical assistance to address challenges that can occur during the initial implementation of their TANF programs. Regional offices provide most of HHS’s training and technical assistance to tribes, and the majority of their assistance focuses on the development and oversight of tribal TANF plans. Regional offices also inform tribes about policy and procedural updates and provide clarification if needed. For example, when the Recovery Act’s TANF Emergency Contingency Fund became available, HHS provided technical assistance and outreach through its regional offices. HHS regional offices also provide regional tribal TANF conferences, typically held once per year. In addition, one senior HHS official said that their regional staff can also conduct in-person site visits to provide direct one-on-one assistance to tribes, but generally they lack the resources to do any extensive travel.

Other Tribal Programs

To enhance employment and training opportunities for program participants, tribal TANF programs reach out to other programs within their tribe (see fig. 8), and many also contact other tribes when they experience challenges administering their program. The Menominee Tribe has worked with its local tribal college to provide different education and training opportunities to its tribal TANF participants, such as degree and trades programs (for a related photo of the Menominee tribal college, see app. III). In our survey, 46 out of 47 tribes (98 percent) responding to the question indicated that they contact other tribes when they experience challenges administering their own TANF programs. For example, tribal TANF administrators from one program we spoke with participated in meetings with other tribal TANF programs in their state, which they found more valuable than HHS regional meetings for coordinating with other tribal TANF programs on particular issues and sharing information about such topics as data, tribal TANF plans, and HHS guidance.

To enhance employment opportunities for tribal TANF participants and address some of their barriers to self-sufficiency, tribes also collaborate with other federal programs. Tribes seek out these partnerships, in part, because their TANF programs are typically serving areas with high unemployment rates. Some tribes we visited told us they collaborated with such programs to create opportunities for individuals to help meet their work participation requirements. For example, at least three tribes we visited—the Lac du Flambeau, Zuni, and Hopi tribes—placed participants at their Head Start offices to gain work experience (for a related photo of the Lac du Flambeau Head Start program, see app. III). The Hopi tribe has also sent some participants to an orientation for the Job Corps program, an education and training program that helps young people learn a career, earn a high school diploma or General Equivalency Diploma, and find and retain employment.

To facilitate further coordination with federal programs and address challenges related to program implementation and staffing, tribal TANF programs can also participate in a “477 plan” administered by DOI. According to DOI, when TANF is integrated into a comprehensive “477 plan,” participants may receive additional support services, such as longer-term job preparedness, and “477 plan” case managers can receive additional training from DOI to better assist unemployed tribal members with finding jobs. DOI also noted that consolidating resources into a single plan helps to minimize overhead costs, maximize client participation, and integrate services. Of the 11 tribes responding to our survey that include their TANF program in such a plan, nearly all indicated that doing so improved service delivery coordination (10 out of 11), increased continuity of service provision (10 out of 11), and improved administrative and staff coordination (9 out of 11). For example, one tribe we visited said their participation in a “477 plan” allowed them to reduce paperwork and duplication among their various federal programs, including TANF, and to provide a one-stop service location as well.

Tribal TANF programs also coordinate with other federal grant programs under HHS, such as the Native Employment Works (NEW) program. Of the tribes we surveyed, 18 out of 22 (82 percent) that operate both NEW and TANF programs reported improved service delivery coordination as a benefit of operating both programs. In addition, 16 out of the 22 tribes indicated that they had benefited from increased continuity of service provision and improved administrative and staff coordination as a result of administering both programs.

Private Consultants

In our survey, 37 out of 46 tribes (80 percent) reported that they contact private consultants when they experience challenges administering their TANF programs. During our site visits, we learned that tribes reach out to consultants to address some of the top challenges reported in our survey, such as developing data systems and staff expertise. For example, to address challenges related to developing adequate data systems, we learned that the majority of tribes use data systems and receive training on these systems from consultants, according to HHS. Another tribe we visited consulted with the University of California, Davis to help facilitate the development of goals for their tribal TANF plan, which included clarifying the tribe’s definitions for performance and results. In addition, the Center for Human Services at the University of California, Davis annually presents a National Tribal TANF Institute to provide information, tools, and networking opportunities to support the development and operation of tribal TANF programs that meet the needs of Native people.

HHS Oversight of and Guidance for Tribal TANF Programs Lacks Consistency and Timeliness

HHS Uses Tribal TANF Single Audit Reports to Target Training and Technical Assistance, but Fragmented Systems Track and Monitor These Reports

According to HHS officials, the single audit is the primary oversight mechanism for tribal TANF programs, and single audit findings are used to target technical assistance to tribes. At least 19 tribes have had repeat single audit findings since 2002, most often in the areas of allowable costs/cost principles, reporting, eligibility, cash management, and equipment and property management. One official from an HHS regional office explained that a lack of infrastructure and the inability to retain qualified staff in tribal TANF programs are often the main causes of repeat audit findings such as these. HHS officials described how record keeping can be a challenge for tribal TANF programs as a result of inadequate computer systems. More specifically, one senior HHS official stated that one of the most common findings from tribes’ audits is weaknesses in procurement systems, where documents supporting procurement purchases are missing and incomplete, or inventory lists are missing. One HHS regional official added that tribes are especially susceptible to financial audit findings because of staff turnover—a tribe could be making progress with addressing their audit findings, but then a key staff member may leave, and the tribe is “back to square one.” To help tribes prevent financial audit findings resulting from new or inexperienced staff, one regional official stated that they invite new tribal TANF financial officers to come to their offices for basic training on the TANF program and fiscal issues. Another HHS official described how they have also used single audit report findings to target their training and technical assistance by holding sessions on common audit findings and resolutions at some of their annual tribal TANF conferences. HHS has also included guidance on single audits in some of its policy manuals available on its tribal TANF Web site, such as an audit supplement guide that outlines common tribal TANF audit findings and program activities that can ensure compliance with government regulations. Additionally, HHS has the authority to impose financial penalties if it decides they are warranted.

However, we found that HHS’s tracking of single audit reports was fragmented, with multiple systems tracking different sets of reports with tribal TANF findings. An HHS Office of Inspector General (OIG) official explained that audits are tracked in an agencywide single audit database that HHS’s OIG oversees, and some program offices, including ACF, have their own database for tracking audits they are responsible for resolving. However, audits with tribal TANF findings may not always be tracked in ACF’s database, because depending on the nature of the finding, another HHS program office or even another federal agency may be responsible for resolving it. For example, HHS officials explained that audit reports with crosscutting findings affecting multiple programs usually do not show up in ACF’s database, as they are assigned to and tracked by HHS’s Office of Finance, Division of Systems Policy, Program Integrity and Audit Resolution, which is responsible for handling or resolving these specific types of findings. However, a summary of all audit findings are sent to the HHS tribal TANF program office for their review.

One senior HHS tribal TANF official confirmed that due to workload priorities, they are behind in reviewing these summaries of audit findings for both state and tribal TANF programs. One HHS OIG official explained that these summary reports contain all audit findings for tribal TANF programs, including those that the tribal TANF office is not responsible for resolving. If these summary reports are not reviewed in a timely manner, tribal TANF officials may not be aware of all recurring audit findings related to tribal TANF programs. For example, one tribe was found to have not met compliance requirements for allowable costs or cost principles for each of the five consecutive years it submitted single audit reports. According to information provided by the OIG, ACF was responsible for resolving some but not all of the findings, and thus may not have known that these findings had occurred every year if they did not review the summary reports in a timely manner. Our Standards for Internal Control in the Federal Government provide that internal control monitoring should ensure that findings of audits and other reviews are promptly resolved. Due to the delays in reviewing the summaries and the fragmented systems for reporting and tracking single audit findings, HHS tribal TANF officials may not consistently be aware of all the single audit findings related to tribal TANF programs, or be in a position to promptly identify and address recurring problems and mitigate risk.

HHS Collects Tribal TANF Data, but Does Not Consistently Update and Review It in a Timely Manner

In addition to HHS officials’ use of the single audit as the primary oversight mechanism for tribal TANF programs, quarterly data reports used to calculate work participation rates and financial reports, as well as other program reporting requirements, also help HHS oversee program performance and ensure program integrity (see table 2).

Through quarterly data reports, HHS reviews tribes’ data used to calculate work participation rates and follows up with tribes to make updates and changes to the data as necessary (see fig. 9). One tribe we visited mentioned that it is helpful to have HHS review their data to make sure that both HHS and the tribe itself are calculating the work participation rates correctly and arriving at the same numbers.

While one of the tribes we visited noted that it was helpful to have HHS review their data, HHS does not consistently update and review tribal TANF quarterly work participation data submitted by tribes in a timely manner. We found that in some cases, it has taken HHS several years to review, update, and share the results of its work participation rate data review with tribes, even though these rates help tribes measure the degree to which TANF families are engaged in work activities that can lead to self-sufficiency. According to our survey, 22 out of 49 tribes (45 percent) indicated that failing to receive data reports from HHS in a timely manner has been a very major or major challenge to administering their tribal TANF program. One tribe in particular stated that they received an official response from HHS regarding their fiscal year 2009 participation rates two years later, in fiscal year 2011. The tribal official noted in our survey that “tribes have deadlines to meet and we have to wait years for a response.” Another tribe responding to our survey stated that while they submit their data reports to HHS each quarter, they are waiting up to three years to receive their reports back from HHS. Because HHS does not review and share work participation rate data with tribes in a timely manner, tribes may not know of any errors in their data reporting until years later, which could impact not only the data reporting for that year, but also for subsequent years.

An HHS contractor primarily responsible for working with tribes on their TANF work participation data said that, in his opinion, tribal TANF data present different challenges for HHS than state TANF data. For example, updating information on tribes’ work participation rates requires keeping track of 64 different TANF plans, where the work participation rates or work hours often change every year, which, according to the HHS contractor, is not as common with state TANF programs. In addition, the number of plans will continue to grow as more tribes have expressed interest in starting their own programs. The same HHS contractor noted that while it would be useful for tribes to see their work participation calculations or to access information for a specific month or year, access to that type of information would require additional programming. Furthermore, he said it would take a more sophisticated program than what HHS is currently using—such as a program flexible enough to define the different tribal TANF variables—to help make updating the data to share with tribes a little easier.

HHS uses different methods to provide guidance to tribes on their TANF programs (see fig. 10).

Tribal TANF programs are generally satisfied with the assistance they receive from HHS, but some cited deficiencies. When asked to rate different types of assistance received from HHS headquarters and regional offices, the majority of the tribal TANF respondents in our survey indicated that they found guidance and policy documents, technical assistance, training and conferences provided to them by HHS to be somewhat to very useful (see fig. 11). However, many tribes noted that the assistance that HHS headquarters and regional offices provided to them for data reporting and data system development was only slightly or not useful, with some tribes also indicating that they had not received these types of assistance from HHS at all (see fig. 11). For example, 13 out of 40 tribes (33 percent) indicated that data system development assistance from HHS headquarters was only slightly or not useful, while 14 (35 percent) indicated that they had not received any assistance in this area.

Tribes also reported that HHS regional and headquarters offices’ timeliness varied in responding to requests for assistance. Specifically, tribal TANF survey respondents indicated greater satisfaction with the speed of HHS regional offices compared to headquarters (see fig. 12). For example, 33 out of 48 tribes (69 percent) responding to our survey said that they were very satisfied with the speed of HHS regional office staff, while only 18 of 46 tribes (38 percent) were very satisfied with the speed at which HHS headquarters office staff respond to their requests.

However, some of the survey respondents and tribes we interviewed described situations where HHS regional and headquarters assistance was not timely. For example, some tribes we interviewed described how they had repeatedly sent emails to their regional office asking for information, but the region was unresponsive. Some tribes we interviewed at regional conferences and who responded to our survey also indicated that delayed responses from HHS were particularly frustrating when they were trying to figure out new policies or when they had a limited time in which they could act—such as implementing the new financial form or submitting their Emergency Contingency Fund applications. One senior HHS official explained that even those questions that seem simple on the surface may have greater implications, so all questions must be reviewed and vetted to provide an accurate response, which takes time. However, one tribe stated that HHS made a general announcement about the new financial reporting form in 2007, and then they never heard anything else about the development or implementation of the form until 2 years later, when they were required to start using it. This tribe also noted that HHS held a training meeting with tribes to discuss its requirements after tribes were already required to begin reporting program data using the new financial form. As a result, they did not have an opportunity to include in the reports what they learned in the training. In our survey, another tribe described how they do not receive notifications about program changes from HHS in a timely manner, stating that “we are expected to implement . . . federal requirements immediately, without immediate guidance or training if needed.”

Tribes also indicated in our survey that tribal TANF guidance provided by HHS regional and headquarters offices via phone, email, and training conferences was not always clear or consistent. In our survey, 18 out of 50 tribal TANF respondents (36 percent) indicated that HHS policy on subsidized employment was not clear. HHS officials stated that the timeframes for implementing the Recovery Act did not allow for the issuance of proposed and final rules. HHS posted questions and answers on subsidized employment on their website and sought to provide guidance when they could. However, some tribes explained that in general, they receive mixed messages from HHS’s regional offices and headquarters, and sometimes even from different staff members within the same regional office. Tribes told us that there seems to be some confusion at HHS over how and what information is communicated to tribes, with HHS staff sending tribes incorrect or inconsistent information on tribal TANF policies. For example, one tribe responding to our survey noted that their regional office contact does not always provide direct answers to tribal leaders, which can lead to misinterpretation, while another tribe we visited noted that different HHS regional offices had different interpretations of what types of activities count as cultural activities. HHS officials stated that because tribes are very diverse, it is difficult to have a “one size fits all’ approach to developing some of the policies that tribes want guidance on, such as cultural activities allowed to meet work participation requirements. Federal officials would prefer to give tribes broad flexibility to determine themselves what constitutes an appropriate activity. However, some tribes expressed frustration with this approach, citing how the cultural activities they choose to include in their tribal TANF plans are still subject to review by HHS, and some are not always approved.

In addition, tribes have received different kinds of guidance in different formats, and not all tribes were satisfied with the way in which HHS provided it. One tribe described how all of the guidance they received on subsidized employment was shared informally via phone calls and emails—there was no official policy memo from HHS that detailed this guidance. This tribe also acknowledged that it can be difficult to provide policy information to all of the tribal TANF programs at one time, and suggested that HHS leverage its Web site to provide relevant guidance and ensure that all tribes have access to the same information. For example, documents related to past regional tribal conferences, Web casts, and information on tribal TANF technical assistance services are posted on a different HHS Web site, and are not linked to the tribal TANF Web page. As a result, tribes may not know that this information is related to tribal TANF and available to them online. Further, some tribes cannot always attend HHS’s annual regional training conferences, and as a result they miss out on training opportunities and access to key information or guidance. One HHS regional office added that regional offices are not universally consulted or pulled in by HHS headquarters to strategize on technical assistance efforts, or to come up with collective objectives and goals. As a result, the types and amount of technical assistance provided to tribes by each of the different regions varies. The majority of the HHS regional offices we interviewed said that they would like to be able to visit tribes in person to provide more one-on-one training and guidance when tribes need or want it, but recognized that there are limited resources for travel. HHS headquarters officials also described how limited travel funds impacted their ability to visit tribal TANF programs in person as well. Additionally, tribes indicated in our survey that they would like to receive more assistance from HHS—33 out of 44 respondents (75 percent) wanted additional assistance from HHS regional offices, while 30 out of 38 respondents (79 percent) wanted more assistance from HHS headquarters.

Regional offices do not always receive clear and consistent guidance from HHS headquarters on new policies, either. HHS officials told us that tribal TANF policies are primarily created in their headquarters office, and then it is up to the regional offices to provide much of the training and technical assistance to tribes related to these policies. One regional official stated that they do not have written policies or guidance on what they should do if tribes are having difficulties administering their tribal TANF program, but that this is the same for state TANF programs, too. Another regional official said they had asked the HHS headquarters office for guidance for the new financial reporting form for a year before they received it. As one tribe indicated, this resulted in the regional office being unable to answer questions from tribes about the new form.

Further, because HHS and DOI did not always agree on how to coordinate oversight of tribal TANF programs incorporated in “477 plans,” tribes with “477 plans” were sometimes confused over which agency’s rules and regulations they are required to follow. For example, one tribe responding to our survey described how HHS and DOI still needed to provide them a definitive answer as to whether or not the Emergency Contingency Fund grant which was transferred to their “447 plan” program could be expended until the end of fiscal year 2011. One HHS official described how in the past, DOI did not provide HHS with written regulations or terms and conditions for “477 plans” in general, and this made it difficult for them to know how to implement tribal TANF as part of the “477 plan.” In response, a DOI official explained that DOI purposely did not develop any regulations because adding more rules would diminish the flexibility of the plans, which is contrary to their principal goals. However, both DOI and HHS officials told us that they have been coordinating more to share information with each other and develop policies together, such as recent joint consultations with tribes with “477 plans” on using one funding instrument.

Conclusions

While the tribal TANF program as a whole is relatively small in comparison to the TANF program for states, Congress designed tribal TANF in recognition that tribes, like states, would be better equipped to understand and meet the needs of their own communities. However, since the creation of tribal TANF, HHS’s administration of the program has not kept pace with the growth of tribal TANF or with tribes’ changing needs. Improved access to information on how to implement parts of their TANF program or policy changes that could affect their programs can facilitate tribes’ achieving program goals. Further, more prompt, consistent collection and review of all tribal TANF-related single audit report findings and work participation rate, caseload, and financial data, could help HHS to more effectively monitor tribal TANF programs and determine how it could better target its technical assistance and guidance to address areas where tribes may be having difficulty. In addition, more timely HHS data analysis could improve both the accuracy of tribes’ data reporting and the ability of HHS and tribal administrators to determine if tribal TANF programs are effectively maintaining program integrity and meeting their goals.

Given the fiscal pressures facing the federal government and the continued demands placed on assistance programs, it is critical that programs designed to serve those most in need are in a position to provide benefits and services as effectively and efficiently as possible while maintaining program integrity. Unless HHS makes improvements in the consistency and availability of single audit report findings, tribal TANF policy guidance, and program data, tribal TANF program administrators will not have the complete information they need to improve the effectiveness and integrity of their programs.

Recommendations for Executive Action

To improve guidance and oversight of tribal TANF programs, we recommend that the Secretary of Health and Human Services take the following three actions:  Review and revise, as appropriate, HHS’s process for monitoring, tracking, and promptly resolving tribal TANF single audit findings so that it can more systematically target training and technical assistance to better address recurring problems and mitigate risk.

Improve processes for maintaining and monitoring tribal TANF data— such as work participation rate, caseload, and financial data—that can be shared with tribes in a timely manner.  Create procedures to provide more timely, accessible, and consistent guidance on tribal TANF policies that is clearly communicated to tribal TANF programs, and ensure that all tribal TANF policy developments and procedures are readily and easily accessible on HHS’s Web site. For example, HHS could consider more effective ways to provide training to tribes on how new guidance or policy decisions will affect the administration of their programs, and consistently update its Web site to provide information on related tribal TANF technical assistance and training.

Agency Comments and Our Evaluation

We provided a draft of this report to the Secretary of the Interior and the Secretary of Health and Human Services for review and comment. HHS provided us with written comments on a draft of our report which are reprinted in appendix IV. Both DOI and HHS also provided us with technical comments that we incorporated, as appropriate.

HHS agreed that effective monitoring and continuous improvement of its guidance and technical assistance to tribes as well as to states and other grantees is important, and stated their appreciation for our findings on areas where monitoring, guidance and technical assistance could be improved to tribal TANF programs. HHS also stated that it would be mindful of our overall recommendations and specific examples of ways to improve its efforts, and it is already outlining actions they plan to take to address our recommendations.

Specifically, with regard to our first recommendation, HHS commented it would review and seek to identify opportunities for improvement at each step of its process for monitoring, tracking and resolving tribal TANF audit findings, including the identification of recurring problems and risks, and the identification of technical assistance needs identified through the audit resolution process. During the course of our audit work, HHS officials could not find some single audit reports, but they were recently able to provide them, so we removed our finding related to this from the report. HHS also stated that it will take follow-up steps to ensure that all audits with tribal TANF findings will be promptly addressed, and has committed additional staff to working on audit issues.

In response to our second recommendation, HHS recognized the need for more timely sharing of data with tribal TANF programs, and cited efforts it is undertaking to address this, including the hiring of an additional tribal TANF data specialist and its continuing work on improving reporting and publishing of preliminary and final caseload and work participation data for recent years.

With regard to our third recommendation, HHS stated it would strengthen its efforts to be attentive to opportunities for improvement in training and technical assistance, but it also commented on how we presented findings on its guidance to tribal TANF programs. First, HHS noted that while our report title and text highlight the need to improve guidance, the data provided in the report generally indicate a high level of satisfaction with the guidance and technical assistance currently being provided. We state in our report that tribal TANF programs responding to our survey were generally satisfied with the assistance they received from HHS, but some respondents did cite specific weaknesses in areas such as data system development and reporting. Additionally, in multiple survey open- ended responses and interviews with us, tribal TANF staff cited instances where the timeliness, clarity, and consistency of guidance could be improved, and our title reflects the need for HHS to examine these areas further. In regard to the specific survey findings on data system development and reporting, HHS clarified that the need for additional data system development assistance reflects a need to increase capacity across a broad range of HHS programs, but it is training new employees to assist with data reporting.

In addition, HHS noted that the regional and headquarters offices work together, and that a tribe may be unaware that the headquarters office contributed to assistance received through a regional office. HHS also stated that a question raising complex issues would typically be reviewed by both the regional and headquarters offices, and would likely take longer to resolve. We point out in our report that tribes often cited frustration with not receiving consistent and timely information from both regional and headquarters offices, especially on policy changes that had a limited time in which they could act. Thus, it is important that if both offices are indeed collaborating to provide assistance to tribal TANF programs, that their information be consistent and timely for all tribes in all regions. It can be challenging to work with multiple tribes who each have their own unique tribal TANF programs, but if it is taking the regional and headquarters HHS offices longer to resolve a particular question, if would be helpful if they communicated this to the tribes, especially if it is related to a policy change with a specific timeframe or deadline.

Finally, HHS described how ACF has committed to undertake additional research initiatives to better understand the needs of tribal members, operations of tribal TANF programs and effective practices. These studies could be helpful in providing HHS with more information on better ways to support the tribes.

As agreed with your office, unless you publicly announce its contents earlier, we plan no further distribution of this report until 30 days from its issue date. At that time, we will send copies of this report to appropriate congressional committees, the Secretary of Health and Human Services, the Secretary of the Interior, and other interested parties. The report will also be available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-7215 or brownke@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key contributors to this report are listed in appendix V.

Appendix I: Objectives, Scope, and Methodology

To obtain information on how tribal Temporary Assistance for Needy Families (TANF) programs have changed since 2002 (when we last reviewed the program), the challenges tribes face in administering their own programs and what tribes have done to address them, and federal agencies’ guidance and oversight of tribal TANF programs, we analyzed federal TANF data, documents and tribal TANF single audit data collection reports for selected years; surveyed all tribal TANF administrators; conducted site visits at 11 tribal TANF programs in four states, and interviewed federal officials.

We conducted our work from June 2010 to September 2011 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Review and Analysis of Tribal TANF Data and Documents from HHS and DOI

Because the U.S. Department of Health and Human Services (HHS) is responsible for collecting tribal TANF data and reporting on tribal TANF programs nationally, we reviewed relevant TANF data compiled by that agency. Specifically, we reviewed both published and unpublished data for fiscal years 2002 to 2009 on (1) the work participation status of all tribal TANF adults, (2) work activity data for those TANF adult recipients with activities, (3) tribes that met and did not meet work participation rates, (4) tribes’ caseloads, and (5) tribes’ expenditure data. The expenditure data analysis also includes tribal TANF expenditure data provided by the U.S. Department of the Interior (DOI) for those 15 tribes that include TANF in a “477 plan” for fiscal years 2002 to 2009. We also reviewed fiscal year 2009 and 2010 expenditure data from HHS for the American Recovery and Reinvestment Act of 2009 (Recovery Act) Emergency Contingency Fund and tribes’ applications for these funds.

We interviewed HHS officials to gather information on the processes they use to ensure the completeness and accuracy of the tribal TANF work participation, work activity, caseload, and expenditure data, but we did not independently verify these data with tribes. However, we did follow up with HHS during the course of our analysis whenever we found any inconsistencies or errors with the data in order to ensure that the data were complete, reasonable, and sufficiently reliable for the purposes of this report. In some cases, we received revised information from the agency. We also reviewed DOI documentation related to expenditure data reporting. We found these data to be sufficiently reliable for our purposes.

In addition, we reviewed selected documents submitted by tribes to HHS, which the agency does not publish. For example, we reviewed all 24 tribes’ HHS-approved applications for the Emergency Contingency Fund as of June 2011, mentioned above, and all 64 tribal TANF plans approved by HHS as of October 2010. In addition, we reviewed published and unpublished documents from HHS and DOI, such as all seven of the Welfare Peer Technical Assistance Network needs assessments for tribal TANF and Native Employment Works (NEW) programs and a sample of four “477 plan” assessments selected and provided by DOI officials.

Review of Single Audit Data Collection Reports

HHS does not regularly perform on-site reviews of tribes’ TANF data, but auditors periodically review tribal TANF programs to comply with the Single Audit Act of 1984, as amended. To determine if there were any significant tribal TANF or “477 plan” single audit compliance findings, we reviewed all 398 Office of Management and Budget Circular No. A-133 single audit data collection reports for fiscal years publicly available as of May 2011 that included tribal TANF or “477 plan” programs for fiscal years 2002 through 2010. Then we reviewed the specific types of compliance findings in all 114 available single audit data collection reports for tribal TANF programs in existence for 2 years or longer with significant compliance findings for the majority of years that their program was in existence for fiscal years 2002 through 2010.

Survey of Tribes Administering a Tribal TANF Program

To better understand tribal TANF programs, we conducted a Web-based survey of all tribal TANF administrators for all 64 tribal organizations that administer their own TANF program. The survey included questions about the benefits and challenges of administering a tribal TANF program, changes to TANF service delivery related to the economic recession, and HHS assistance to tribes after the Recovery Act. The survey was conducted from October to December 2010 with 50 out of the 64 tribal TANF administrators (78 percent) responding. We obtained contact information for surveyed tribal TANF administrators from HHS. Beginning on October 25, 2010, we sent e-mail notifications to these officials, and we sent two follow-up e-mails over a period of about 2 weeks to encourage tribes to respond to our survey. We also made follow-up phone calls to encourage nonrespondents to complete our questionnaire.

Because this was not a sample survey, there are no sampling errors. However, the practical difficulties of conducting any survey may introduce nonsampling errors, such as variation in how respondents interpret questions and their willingness to offer accurate responses. We took steps to minimize nonsampling errors, including pretesting draft instruments and using a Web-based administration system. Specifically, during survey development, we pretested draft instruments with three tribal TANF administrators from three states (Alaska, California, and Washington) in September and October 2010. We selected the pretest tribes to provide variation in selected program characteristics and geographic location. In the pretest, we were generally interested in the clarity, precision, and objectivity of the questions, as well as the flow and layout of the survey. For example, we wanted to ensure that definitions used in the survey were clear and known to the respondents, categories provided in closed-ended questions were complete and exclusive, and the ordering of survey sections and the questions within each section was appropriate. We revised the final survey based on pretest results. Another step we took to minimize nonsampling errors was using a Web-based survey. Allowing respondents to enter their responses directly into an electronic instrument created a record for each respondent in a data file and eliminated the need for and the errors associated with a manual data entry process. To further minimize errors, programs used to analyze the survey data and make estimations were independently verified to ensure the accuracy of this work.

While we did not validate specific information that tribal TANF administrators reported through our survey, we reviewed their responses, and we conducted follow-up, as necessary, to determine that their responses were complete, reasonable, and sufficiently reliable for the purposes of this report. For example, we reviewed responses and identified those that required further clarification and, subsequently, followed-up with those tribes to ensure the information they provided was reasonable and reliable. In our review of the data, we also identified and logically fixed skip pattern errors for questions that respondents should have skipped but did not. On the basis of these checks, we believe our survey data are sufficiently reliable for the purposes of our work.

Site Visits to Tribes in Selected States

To gather additional information on how tribal TANF programs have changed since 2002, the challenges tribes face in administering their own program and what tribes have done to address them, and federal agencies’ guidance and oversight of tribal TANF programs, we conducted site visits to 11 selected tribes administering TANF programs in Wisconsin, New Mexico, Arizona, and California to interview tribal TANF administrators and their staff about their programs (see table 3). We visited these tribes from November 2010 to January 2011. We selected these tribes because they varied in geographic location and selected tribal TANF program characteristics, including the size of the tribal service population, the number of years operating their tribal TANF program, program structure (e.g., tribes with “477 plans”), and type and amount of TANF and TANF-related program funding received (e.g., NEW grants, the Recovery Act’s Emergency Contingency Fund, and state funding). We also selected tribes that were located in both urban and rural areas to ensure that we captured any related differences in TANF program implementation as well as the types of challenges tribes may face.

During the site visits, we interviewed tribal TANF officials and staff as well as TANF participants. Through these interviews, we collected information on tribes’ TANF services and work activities, the benefits and challenges of administering a TANF program, the impacts of the economic recession, and tribes’ working relationship with federal agencies as well as with other tribes administering a TANF program. We cannot generalize our findings beyond the tribes we visited.

Interviews with Federal Officials

To learn more about federal agencies’ oversight and guidance of tribal TANF, we conducted interviews with DOI officials and HHS officials in headquarters and all regional offices serving areas where tribal TANF programs were located. These six regional offices are located in Chicago, IL; Dallas, TX; Kansas City, MO; Denver, CO; San Francisco, CA; and Seattle, WA. We also attended HHS regional tribal TANF conferences in California and Washington. In addition, we interviewed tribal TANF consultants and reviewed relevant information from past GAO, HHS, DOI, nonprofit, academic, and research institutions’ reports on tribal TANF, and reviewed relevant federal laws, regulations, and guidance related to tribal TANF.

Appendix II: Approved Tribal TANF Programs (Fiscal Years 2002-2010)

Appendix II: Approved Tribal TANF Programs (Fiscal Years 2002-2010)

Number of tribal TANF programs in existence in FY 2002 (36) Alaska

Association of Village Council Presidents, Inc. (serves 56 Alaska Native villages)

Cook Inlet Tribal Council, Inc. (serves all members of federally recognized tribes in the Municipality of Anchorage)

Central Council Tlingit and Haida Indian Tribes of Alaska (serves 20 Indian and Alaska Native villages)

Bristol Bay Native Association (serves 29 Alaska Native villages)

Navajo Nation (also in New Mexico and Utah)

San Carlos Apache Tribe California Robinson Rancheria/California Tribal TANF Partnership (serves 16 tribes)

North Fork Rancheria of Mono Indians Owens Valley Career Development Center (serves 8 tribes) Morongo Band of Mission Indians Southern California Tribal Chairmen’s Association, Inc. (serves 18 tribes)

Scotts Valley Band of Pomo Indians Federated Indians of Graton Rancheria (serves 4 tribes) Karuk Tribe Round Valley Indian Tribes Shingle Springs Band of Miwok Indians Montana Chippewa Cree Tribe of the Rocky Boy’s Reservation Washoe Tribe of Nevada and California (serves 2 tribes) Oklahoma Muscogee (Creek) Nation Washington Spokane Tribe of Indians South Puget Intertribal Planning Agency (serves 4 tribes)

Number of tribal TANF programs in existence in FY 2002 (36) South Dakota Sisseton-Wahpeton Oyate of the Lake Traverse Reservation Wisconsin Washington

Additional tribal TANF programs that started from FY 2003 through 2010 (28)

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

Appendix V: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, Kathy Larin (Assistant Director), Rachel Frisk, Kristy Kennedy, Meredith Moore, Brenda Muñoz, and Heddi Nieuwsma made significant contributions to this report. Joanna Chan, Lorraine Ettaro, and Stuart Kaufman also made important contributions to this report. David Chrisinger and Mimi Nguyen provided writing and graphics assistance, and Alex Galuten provided legal assistance.

Related GAO Products

Indian Issues: Observations on Some Unique Factors that May Affect Economic Activity on Tribal Lands. GAO-11-543T. Washington, D.C.: April 7, 2011 Human Services Programs: Opportunities to Reduce Inefficiencies. GAO-11-531T. Washington, D.C.: April 5, 2011.

Temporary Assistance for Needy Families: Implications of Caseload and Program Changes for Families and Program Monitoring. GAO-10-815T. Washington, D.C.: September 21, 2010.

Temporary Assistance for Needy Families: Implications of Recent Legislative and Economic Changes for State Programs and Work Participation Rates. GAO-10-525. Washington, D.C.: May 28, 2010.

Temporary Assistance for Needy Families: Implications of Changes in Participation Rates. GAO-10-495T. Washington, D.C.: March 11, 2010.

Temporary Assistance for Needy Families: Fewer Eligible Families Have Received Cash Assistance Since the 1990s, and the Recession’s Impact on Caseloads Varies by State. GAO-10-164. Washington, D.C.: February 23, 2010.

Welfare Reform: Better Information Needed to Understand Trends in States’ Uses of the TANF Block Grant. GAO-06-414. Washington, D.C.: March 3, 2006.

Welfare Reform: More Information Needed to Assess Promising Strategies to Increase Parents’ Incomes. GAO-06-108. Washington, D.C.: December 2, 2005.

Welfare Reform: HHS Should Exercise Oversight to Help Ensure TANF Work Participation Is Measured Consistently across States. GAO-05-821. Washington, D.C.: August 19, 2005.

Indian Child Welfare Act: Existing Information on Implementation Issues Could Be Used to Target Guidance and Assistance to States. GAO-05-290. Washington, D.C.: April 4, 2005.

Welfare Reform: Rural TANF Programs Have Developed Many Strategies to Address Rural Challenges. GAO-04-921. Washington, D.C.: September 10, 2004.

Indian Economic Development: Relationship to EDA Grants and Self- determination Contracting Is Mixed. GAO-04-847. Washington, D.C.: September 8, 2004.

TANF And Child Care Programs: HHS Lacks Adequate Information to Assess Risk and Assist States in Managing Improper Payments. GAO-04-723. June 18, 2004.

Welfare Reform: Tribal TANF Allows Flexibility to Tailor Programs, but Conditions on Reservations Make it Difficult to Move Recipients into Jobs. GAO-02-768. Washington, D.C.: July 5, 2002.

Welfare Reform: Tribes Are Using TANF Flexibility To Establish Their Own Programs. GAO-02-695T. Washington, D.C.: May 10, 2002.