Temporary Assistance for Needy Families:
HHS Needs to Improve Guidance and Monitoring of Tribal Programs
GAO-11-758, Sep 15, 2011
The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) gives American Indian tribes the option to administer their own Temporary Assistance for Needy Families (TANF) block grant programs. GAO first reported on the use of this flexibility by tribes in 2002 (GAO-02-768), and given the upcoming expected reauthorization of TANF, GAO was asked to examine (1) how tribal TANF programs have changed since 2002, especially in light of changing economic conditions; (2) the challenges tribes face in administering their own TANF programs and what tribes have done to address them; and (3) the extent to which the U.S. Department of Health and Human Services (HHS) has provided guidance and oversight to promote the integrity and effectiveness of tribal TANF programs. GAO analyzed federal TANF data; interviewed federal officials; surveyed all tribal TANF administrators; and conducted site visits at 11 tribal TANF programs in four states.
Since GAO first reported on tribal TANF programs in 2002, the number of programs has increased--from 36 in 2002 to 64 in 2010. In addition, more tribes use program flexibilities to both tailor services to meet the needs of their TANF families and cope with changing economic conditions. GAO also found that some tribes have increased their work participation rate goals over time. For example, more than half of the 36 tribes that have been administering a TANF program since 2002 have raised these goals over time. Many tribes also allow a wide range of activities families can use to meet work participation rates, such as cultural activities or commuting time. Tribes also reported in GAO's survey that changing economic conditions have adversely affected their caseloads, funding, and services provided. For example, some tribes reported that since the beginning of the economic recession in 2007, they have larger average monthly caseloads, use other federal funding to fill budget gaps, and cut back supportive services to provide more cash grants. According to GAO's survey results, tribal TANF programs face challenges with initial program implementation, staff development and retention, and the development of adequate data systems. Moreover, all 11 tribes GAO visited talked about the various barriers to self-sufficiency facing their TANF participants, such as a lack of transportation and limited employment opportunities. To address these challenges, many tribes reach out to HHS regional office staff, other tribal and federal programs, and private consultants. For example, to address challenges related to developing adequate data systems, GAO learned that the majority of tribes use consultants to develop their systems and provide training. In addition, to enhance employment opportunities, some tribes have placed participants at their Head Start offices, while another tribe has partnered with its modular housing plant. HHS provides oversight and guidance for tribal TANF programs, but does not always do so in a timely or consistent manner. HHS officials told GAO that they use tribal TANF single audit report findings to target training and technical assistance to tribes. However, the systems that HHS uses to track these reports are fragmented, and as a result, 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. Other oversight tools, such as quarterly data reports used to calculate work participation rates, are not consistently updated by HHS in a timely manner, which, according to GAO's survey, is a challenge to tribes' administration of their TANF programs. HHS headquarters and regional offices provide guidance such as basic policy manuals, training at yearly conferences, and one-on-one assistance over the phone. However, some tribes expressed difficulty in finding and receiving clear, consistent, and timely guidance from HHS, which hinders their ability to successfully manage tribal TANF programs and finances. GAO recommends that HHS review its process for tracking related single audit reports, improve processes for maintaining tribal TANF data that can be shared in a timely manner, and provide timely, accessible and consistent guidance that is clearly communicated to its tribal TANF programs. HHS commented it will be mindful of these recommendations as it examines ways to improve its efforts.
- Closed - implemented
- Closed - not implemented
Recommendations for Executive Action
Recommendation: To improve guidance and oversight of tribal TANF programs, the Secretary of Health and Human Services should 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.
Agency Affected: Department of Health and Human Services
Comments: HHS' Administration for Children and Families' (ACF) Program Integrity Internal Control Senior Assessment Team met with program offices in September 2011 to discuss an audit review initiative with the goal of ensuring "clean" audit opinions by September 2013 for all TANF and other ACF programs. HHS reported that they would also take follow-up steps to ensure that all audits with tribal TANF findings will be promptly addressed, and committed additional staff to working on audit issues. In FY12, HHS reported that ACF's Office of Family Assistance (OFA) central and regional office staff review audits and identify trends in findings to determine training and technical assistance plans for Tribes administering Tribal TANF. Audits were a topic at the Region V, VI, VII and VIII multi-regional meeting agenda in August 2012. The OFA central office staff also holds policy discussions with regional involvement to better respond to audit findings and the audit process in general. However, it was not clear what was discussed at the conferences related to the audits, whether the agency improved its audit tracking, and how audits are being used to target training and technical assistance. In FY13, HHS reported that OFA central office staff were continuing to hold policy discussions on a quarterly basis with regional office staff to discuss program trends, best practices and training and technical assistance needs. They also reported that, in response to audit findings and resolution, central and regional office staff have worked to resolve matters that do not involve the penalty process in a manner that is timelier and more responsive to the tribe. However, it is still not clear if the HHS/ACF OFA has taken any actions to review and revise HHS's actual process for monitoring and tracking tribal TANF single audit findings; for example, if ACF's "Program Integrity Internal Control Senior Assessment Team" ensured "clean" audit opinions by September 2013 for all TANF and other ACF programs.
Recommendation: To improve guidance and oversight of tribal TANF programs, the Secretary of Health and Human Services should 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.
Agency Affected: Department of Health and Human Services
Comments: In 2011, HHS recognized the need for more timely sharing of data with tribal TANF programs, and cited its efforts 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. HHS stated that in August 2011, final FY2007 work participation data was published on ACF's website, and GAO observed that FY2008 data had also been posted on their website. HHS noted that preliminary mid-year work participation rate reports for FY2009, 2010, and 2011 were distributed to tribal TANF grantees for review. In FY12, HHS reported that it posted all final years of data through FY2008 and preliminary caseload information as soon as all data is considered accurate and complete by Tribes. In FY13, HHS stated that work participation rate data for FY 2009 and FY 2010 were finalized, distributed and posted to the OFA website; FY 2011 data was expected to be finalized, distributed and posted to the OFA website by August 31, 2013; and FY 2012 data was expected to be finalized, distributed and posted to the OFA website by September 30, 2013. HHS also said that OFA had posted - for the first time - Tribal Characteristics data on the OFA website. This information is similar to data posted for state TANF caseloads and will serve to provide tribes and stakeholders information on the makeup of the Tribal TANF caseload. Also, in May 2013, OFA central office staff held a conference call with regional office staff to specifically discuss Tribal TANF data: information required, collected and the newest posting of characteristics data. However, it is still unclear what HHS/OFA has done to improve HHS's processes for maintaining and monitoring the data to share with tribes in a timely manner.
Recommendation: To improve guidance and oversight of tribal TANF programs, the Secretary of Health and Human Services should 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 Affected: Department of Health and Human Services
Status: Closed - Implemented
Comments: In FY11, HHS stated it would strengthen its efforts to be attentive to opportunities for improvement in training and technical assistance, and described how they had provided technical assistance in the past year through a variety of regional conferences, and were currently exploring the possibility of providing further specific technical assistance through the use of webinars. HHS also described how in 2011 it provided guidance to tribal TANF grantees on conformance and compliance issues via phone, writing (including program instructions), and in-person meetings with HHS staff. In addition, HHS said that they were reviewing and updating their website to ensure that it provides current, relevant information in a readily accessible, user-friendly format. HHS commented that it was also undertaking three research initiatives to better understand the needs of Tribal members, the operations of tribal TANF programs, and effective practices. These reports are expected to be published in FY 2013. In FY12, HHS did not comment on these initiatives, however, they did report additional activities. HHS' Office of Family Assistance (OFA) held a conference call with regions in July 2012 to ensure clarity of policy instructions and to update them on new policies being discussed. They will hold one call each quarter on a larger forum and individual calls with regions, as needed. Tribes are notified about policy instruction and information memos posted to the website via the OFA listserv. They communicate with regions to ensure understanding prior to posting policy memos. OFA also began monthly meetings with the technical assistance and training branch to ensure that tribal technical assistance and training requests are being addressed, and to identify larger scale training needs. In FY13, HHS reported that the HHS/ACF Office of Family Assistance (OFA) central office staff continue to hold policy discussions on a quarterly basis with regional office staff to discuss program trends, best practices and training and technical assistance needs. Central office staff worked with regional staff to determine specific technical assistance and training needs for the tribes, and central office staff reviewed a number of audit findings to develop training and technical assistance for tribes. During the second, third and fourth quarters of FY 2013 central office staff developed and organized with regional offices a series of webinars designed to assist tribes with better program administration. A Tribal TANF Summit was also held in August of 2013 to address areas of concerns raised in the GAO report as well as by tribes and regional staff related to needed technical assistance and guidance. On the agenda specifically are breakout sessions for tribal program staff and administrators that will target audit findings and trends, program integrity, data and program accountability.