Public Law 102-477, known as the Indian Employment, Training and Related Services Demonstration Act (25 U.S.C. 3401 et seq), was established to enhance the ability of federally recognized tribes and Alaska Native entities to address their employment and training needs. The primary intent of the 477 Program is to streamline and consolidate various federal grant programs related to employment, training, and related services into a single, cohesive plan, budget, and reporting system. This integration is designed to align with tribal priorities, reduce administrative burdens, and enhance the efficiency and effectiveness of service delivery within tribal communities.
The integration of services under the 477 Program is highly beneficial for tribes because it allows for greater flexibility in managing and utilizing federal funds. By consolidating multiple funding sources into a single plan, tribes can tailor programs to better meet the specific needs of their communities, avoid duplication of efforts, and maximize the impact of available resources. This holistic approach fosters more effective workforce development, job training, and related services, ultimately supporting tribal economic development and self-sufficiency.
The Bureau of Indian Affairs (BIA) within the Department of the Interior (DOI) serves as the lead federal agency responsible for implementing the 477 Program. The Department of Health and Human Services (HHS) is one of twelve federal departments with grant programs eligible for integration under this legislation. These federal partners collaborate to ensure that tribal plans are reviewed and approved efficiently, providing tribes with the necessary support to implement their integrated services successfully.
ACF 477 Funding — Leading the Way
The Administration for Children and Families (ACF) within HHS administers seven federal grant programs eligible for integration under 477. These programs significantly enhance the scope and scale of social services available to tribes, supporting a broad range of community needs and fostering self-sufficiency.
At the close of fiscal year 2024, 73 tribes have integrated 162 ACF grant awards under 477, totaling over $293 million. ACF's commitment to 477 is particularly noteworthy, as ACF funding accounts for 85% of the total integrated funding under 477. This demonstrates the crucial support ACF provides in enhancing tribal self-sufficiency and improving the quality of life within tribal communities.
Program integration not only simplifies administrative processes, but also amplifies the impact of federal funds, leading to more cohesive and comprehensive service delivery for tribal populations.
ACF FY24 grant programs and funds transferred to Tribes under 477
| DEPARTMENT/PROGRAM | FY24 GRANT FUNDING INCLUDED IN 477* |
|---|---|
| HHS | $293,685,000 |
| Child Care and Development Fund (CCDF) | $227,674,000 |
| Community Services Block Grant (CSBG) | $1,570,000 |
| Family Violence Prevention Services Act (FVPSA) | $68,000 |
| Low Income Home Energy Assistance Program (LIHEAP) | $7,128,000 |
| Native Employment Works (NEW) | $3,076,000 |
| Temporary Assistance for Needy Families (TANF) | $53,978,000 |
| Title IV-B, Subpart 1 Child Welfare Services Program | $136,000 |
| Title IV-B, Subpart 2 Promoting Safe and Stable Families | $190,000 |
| Other federal departments | $51,905,000 |
| Total | $345,590,000 |
*The grant funding amounts are rounded to the nearest thousand dollars.
ACF 477 Programs– Serving Socio-Economic Needs
Historically, there have been four ACF programs integrated under 477:
- Child Care and Development Fund (CCDF): The CCDF program aims to increase the availability, affordability, and quality of child care services. It helps low-income families access childcare so parents can work or participate in education and training activities.
- Community Services Block Grant (CSBG): CSBG provides funds to alleviate the causes and conditions of poverty in communities. It supports various services and activities to assist low-income individuals and families, such as employment, education, housing, and nutrition.
- Native Employment Works (NEW): The NEW program focuses on providing employment and training opportunities to Native Americans. It aims to support job readiness, skills development, and job placement services to promote economic self-sufficiency.
- Tribal Temporary Assistance for Needy Families (TANF): Tribal TANF provides temporary financial assistance and supportive services to needy families with children. The program promotes job preparation, work, and marriage, and aims to reduce the dependency of needy parents on government benefits.
In 2023 and 2024, ACF expanded its impact with the integration of five new programs:
- Family Violence Prevention and Services Act (FVPSA) Program:FVPSA provides funding for programs that prevent family violence and support victims. It focuses on enhancing safety for individuals and families, offering emergency shelter, crisis intervention, and supportive services.
- Low-Income Home Energy Assistance Program (LIHEAP): LIHEAP helps low-income households meet their home energy needs. It provides financial assistance to cover heating and cooling costs, ensuring that vulnerable populations remain safe and healthy.
- Title IV-B, Subpart 1 (Child Welfare Service): Title IV-B supports the welfare of children and families. Subpart 1 focuses on protecting and promoting the welfare of all children, preventing child abuse and neglect, and supporting at-risk families. Subpart 2 aims to improve services for at-risk children and families, promoting family stability and child well-being.
- Title IV-B, Subpart 2 (Promoting Safe and Stable Families): Subpart 2 aims to improve services for at-risk children and families, promoting family stability and child well-being.
- Tribal Personal Responsibility Education Program (Tribal PREP): Tribal PREP promotes proven and culturally appropriate methods for reducing adolescent pregnancy, delaying sexual activity among youths, and increasing abstinence and contraceptive education among sexually active youth in native communities.
The ACF programs integrated under 477 encompass a diverse array of services tailored to meet the unique needs of tribal communities. Each program contributes significantly to enhancing the quality of life and promoting self-sufficiency among tribal members.
Benefits of 477 — Elevating the Voices of Tribes
The integration of ACF grants under 477 has had a profound impact on tribal communities by streamlining service delivery and addressing a wide range of socio-economic needs. Here are some testimonials from tribes highlighting the benefits of the 477 integration:
- Holistic Approach: "The participants tell their story once, and we’re looking at the whole household, so we review the household needs, not just the individual.”
- Uninterrupted Services: “It’s one bank account and the ability for continual services without breaking funding. We don’t wait on a set of dollars to get here and have to suspend services because those dollars have not yet arrived. Continuing resolutions with federal budget is a very good example. While our neighboring tribes to us are in a hold, can’t provide services, or have to decide which services they’re going to cover with tribal funds and which ones they’re going to suspend until dollars come in, we do not have to deal with that.”
- Efficient Service Delivery: “One program has very limited administrative cost allowed under that program. And by being under 477, we are able to integrate it within our services more effectively so that we could provide services to participants faster and easier because they were already receiving 477 services.”
- Support for Cultural Goals: “We can support tribally driven goals and needs. We can help support living language and revitalizing our culture.”
- Program Stability: “We assist in providing stability of programs integrated in a 477 plan. So if that funding disappears in one year, it’s in 477 and we can continue with the action and support those things.”
- Emergency Response: “477 allows us to look at a unified emergency response and we are able to meet those challenges as needed.”
- Crisis Management: "We can step in at any time with 477 without having to maneuver multiple applications in a time of crisis. We can have one application and meet all the needs of the family, and so that can be crucial at times of emergency.”
These testimonials highlight how the integration of ACF programs under 477 enables tribes to deliver more effective, efficient, and comprehensive services to their communities, thereby enhancing the overall quality of life and self-sufficiency of tribal members.
Map of 477 Tribes and the ACF Programs They Integrate
FAQs
What is 477?
477 refers to the Indian Employment, Training, and Related Services Demonstration Act of 1992, Public Law No. 102-477 (October 23, 1992), as amended by the Indian Employment, Training and Related Services Consolidation Act of 2017, Public Law No. 115—93 (December 18, 2017, 25 U.S.C. section 3401 et seq.).
What does 477 do?
As per the 477 purpose provision of the statute, the law facilitates the ability of Indian tribes (as defined in 25 USC §5304) to integrate federally funded employment, training and related services from diverse federal sources into a consolidated and comprehensive program. The goal is to improve the effectiveness of those services, reduce joblessness in Indian communities, and serve tribally determined goals consistent with the policy of self-determination, while reducing administrative, reporting, and accounting costs.
A simpler way to think about the purpose of 477 is that it makes sense for tribes to be able to integrate employment, training, and related services funds in one plan because the funded activities are similar. Because the activities are similar, it makes sense to reduce the administrative burden of submitting plans and reports and operating programs.
Tribal participation is voluntary.
Who is the federal lead for 477?
Bureau of Indian Affairs (BIA ) within the Department of the Interior (DOI) is the lead agency for 477.
What are the benefits to tribes and tribal organizations?
The law allows tribes to integrate the employment, training, and related services they provide to improve the effectiveness of those services, reduce joblessness in Indian communities; serve tribally determined goals consistent with the policy of self-determination; and reduce administrative, reporting, and accounting costs. 477 facilitates the ability of tribes to integrate employment, training, and related services funds into one plan and allows for reduced reporting.
What is an Integrated Program?
An Integrated Program is a federal program as described in 25 USC §3404 that has been approved for integration under an approved 477 Plan.
What programs can be integrated into a 477 Plan?
Programs that are awarded for specific statutory purposes (25 U.S.C. §3404(a)(1)(A)) and are a certain type of grant (25 U.S.C. §3404(a)(1)(B)). The statutory purposes notes that qualifying programs “shall be only programs implemented for” the purpose of job training, welfare to work and tribal work experience, creating or enhancing employment opportunities, skill development, assisting Indian youth and adults to succeed in the workforce, encouraging self-sufficiency, familiarizing individual participants with the world of work, facilitating the creation of job opportunities, economic development, or any services related to those activities.
How do programs become integrated into a 477 Plan?
When a tribe wants to integrate a program for which they have been awarded a grant, they submit a proposed 477 Plan to BIA. BIA shares the plan with each Affected Agency so that they can review the plan in accordance with the 477 statute and the procedures described in the MOA. The Secretary of the Department of Interior approves or disapproves the 477 Plan and is responsible for notifying the Affected Agency and the tribe. 477 Plans are reviewed and approved on a case-by-case basis. After the 477 Plan is approved, funds are transferred to BIA pursuant to 25 USC §3412.
What ACF programs have been integrated under 477?
Child Care and Development Fund (CCDF), Community Services Block Grant (CSBG), Family Violence Prevention Services Act (FVPSA) program, Low Income Home Energy Assistance Program (LIHEAP), Native Employment Works (NEW), Temporary Assistance for Needy Families (TANF), Title IV-B, Subpart 1 (Child Welfare Services), and Title IV-B, Subpart 2 (Promoting Safe and Stable Families).
What is the history of 477?
Public Law 102-477, initially enacted on October 23, 1992, marked a significant step forward in empowering federally recognized tribes and Alaska Native entities. The law was designed to enhance the efficiency and effectiveness of employment, training, and related services by allowing the integration of various federal programs into a single, cohesive plan.
Over the years, the scope 477 has been expanded and its implementation processes refined.
Legislative Timeline of 477
- October 23, 1992: Public Law 102-477 (PDF) was enacted to authorize the integration of employment, training, and related services provided by Indian tribal governments. The primary goal was to reduce administrative costs and enhance the effectiveness of these programs by consolidating funding streams and reporting requirements. (U.S. Department of the Interior ) (Bureau of Indian Affairs ).
- December 27, 2000: The law was amended by Public Law 106-568 (PDF), known as the Omnibus Indian Advancement Act. This amendment provided additional flexibility and streamlined processes for tribes participating in the program (U.S. Department of the Interior ).
- December 2018: An Interagency MOA was signed by the Secretary of the Interior and other federal agency heads, formalizing the collaboration and coordination processes required by the 2017 amendment. This MOA established procedures for reviewing and approving tribal 477 plans within a 90-day statutory deadline (U.S. Department of the Interior ).
- October 7, 2022: An updated Memorandum of Agreement was implemented to further streamline the process and increase participation among federally recognized tribes. The updated MOA included more federal programs and aimed to provide better support for tribal workforce development (Bureau of Indian Affairs ).
- 2023: As of 2023, there are 78 approved 477 plans representing 298 federally recognized tribes. These plans integrate 38 individual federal programs, consolidating 544 funding streams to tribes and tribal organizations. The Division of Workforce Development facilitated the transfer of $316 million to 477 Program Tribes and Tribal Organizations (Bureau of Indian Affairs ).
How can I learn more about starting the process of integrating programs under 477?
To learn more about 477 program integration, please contact BIA.
Office of Indian Services
Division of Workforce Development
Bureau of Indian Affairs
1849 C Street, N.W.
MS-3645-MIB
Washington, D.C. 20245
Telephone: (202) 219-3938
Fax: (202) 513-0319
Other Resources
- Public Law 102-477 Act (PDF) as amended (PL 115-93)
- DOI BIA Division of Workforce Development webpage
- October 7, 2022 Interdepartmental Memorandum of Agreement signed by 12 federal departments (PDF)
- CCDF Program Instruction for 477 Tribes
- Press Release: First Tribal Integration of Title IV-B Child Welfare Programs Into a “477” Plan
- How ACF is Leveraging the 477 Program to Promote Tribal Sovereignty
* Download Option: Map of 477 Tribes and the ACF Programs They Integrate
Download 477 Data Map (PDF — 51.35 KB)