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    "label": "Tribal - TANF [2]",
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    "title": "Tribal - TANF [2]",
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        "Records of the Domestic Policy Council (Clinton Administration)",
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    "seq": 4,
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    "url": "https://s3.us-east-1.amazonaws.com/NARAprodstorage/lz/presidential-libraries/clinton/wjc-dpc/7367479/7367479-20060197F-Seg3-031-018-2024-004.JPG",
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    "ocrText": "Explanation of Major Differences Between Tribal TANF NPRM and State TANF NPRM\nThis synopsis serves as a supplement to the earlier comparative chart itemizing the differences\nbetween the Tribal and State TANF NPRMs. I have highlighted the major differences between\nthe two NPRMs in regards to the central TANF issues (i.e. administrative cap, work\nparticipation, penalties, and time limits) and briefly discuss additional components of the NPRM.\nMajor Differences Between NPRMs\nGeneral\nFor every Tribal grantee, the Secretary and the Tribes will establish the minimum work\nparticipation requirements, time limits for receipt of services and penalties against individuals as\npart of a negotiated process that occurs following the Tribe's submission of their TANF Plan.\nEach Tribe must submit a Tribal TANF Plan to be considered as a grantee; this plan will include\nthe basis for each of the requirements mentioned above along with the rationale and policy\nimplications. The rule provides considerable flexibility to Tribes in the design of the programs.\nWhile the structure must be consistent with the requirements of TANF, it allows Tribes to differ\nbased on the economic conditions and the available resources of each Tribe. The proposal\nshould include information relating to poverty, unemployment, education levels and jobless rates\nof individuals within the geographic region of the Tribe.\nAdministrative Cap\nAdministrative expenditures are limited to 20% of a Tribal TANF grant. A Tribe must spend\n80% of its grant on direct program services and technology and other computer costs while the\nremaining 20% can be used for administrative purposes, defined as any expense other than direct\nprogram services or technology. This percentage expenditure is higher than the State's 15%\nlimit for two reasons. In preliminary discussions with States and Tribes concerns were raised\nthat Tribes do not have experience operating a welfare program, and thus they will require more\nfunds to operate the program than States do. In addition, it was agreed that Tribes will need to\nexpend a larger portion of their grant on administrative costs than States because they cannot\ntake advantage of economies of scale.\nThere was discussion concerning whether a cap should exist at all, but the belief was that in this\nsituation needy families could be deprived of benefits if excessive amounts of money were spent\nadministratively. In addition, setting a limit on administrative costs is consistent with the\npurposes of the Act and thus a component Tribes should implement.\nMinimum Work Participation Requirements\nIn the Tribal Family Assistance Program (TFAP), Tribes must specify the targeted work\nparticipation rates, the minimum number of hours individuals are required to participate in work\nactivities, work activities counting towards the requirements, limitations and special rules of the\nwork requirements, and rational for anything proposed that is different from State TANF\nprograms including how they are consistent with TANF provisions and local economic\nconditions. Allowing Tribes to specify how each TANF work component will be satisfied\nensures flexibility within the different Tribal geographic areas provided that the original plan"
}