PL 102-477, as amended, aims to reduce unemployment through workforce development and job training opportunities in Tribal communities and by reducing and streamlining administrative requirements. The Bureau of Indian Affairs is the lead federal agency for the inter-departmental project, and participation is voluntary.
How 477 Plans Work
Public Law 102-477, as amended, applies to any federal formula-funded program intended for employment, training, and services that may enhance a person’s ability to become self-reliant.
An approved 477 Plan, also known as an Integrated Service Plan, allows a Tribe to develop an employment and training service tailored to its unique Tribal goals. Each participating Tribe decides which eligible employment and training-related federal programs to include in its plan. In the past, Tribes have developed plans that focus on raising educational achievement, addressing the needs of Tribal youth, increasing self-sufficiency, and fostering Tribal economic development.
All the funds involved in a Tribe’s 477 Plan are those the Tribe would have otherwise received from the individual federal programs that are part of its plan. No separate federal funding is associated with Public Law 102-477.
Examples of eligible federal programs include BIA’s Job Placement and Training Program, the Department of Labor’s Workforce Innovation and Opportunity Act Section 166 Adult Comprehensive Services, and the Department of Health and Human Services’ Native Employment Works Program.
Why Tribes Participate
- Improves client services by increasing the number of clients served and improving outcomes for clients.
- Empowers Tribes to set their own service goals because Tribal plans can follow Tribal rather than federal priorities.
- Consolidates funding sources into a single budget: The law requires a Tribe to submit only one budget that outlines how each federal program's funding will be used. This is outlined in the Tribe's 477 Plans.
- Reduces federal paperwork: Statistics show that the number of reports required to be submitted to federal funding agencies is reduced by over 90% compared with what was required of a Tribe before 477 was introduced.
- Service focused on client needs: Counseling staff can now serve clients based on their needs, not on where the money for their salaries comes from. This allows tribal services to reach all clients who need them.
- Provides a single intake system: With only one file per client, the need for multiple files for the same person is eliminated. This reduces the amount of information the program maintains because the federal 477 Report Form is often simpler than those used for individual programs.
How to Participate
A Tribe seeking to take advantage of Public Law 102-477 should submit an integrated service plan and budget to the BIA Indian Services, Division of Workforce Development at 477PlanSubmission@bia.gov.
A review of their Plan is coordinated with the BIA and affected agencies, which will provide recommendations. The Secretary of the Interior has exclusive authority to approve or disapprove a submission.
Once approved, agencies whose programs are included in the Plan will transfer funds to the BIA, which will then use the Tribe’s existing self-governance compact agreement or its 638 contract to provide funding to the Tribe.
The Tribe can then implement its services under the approved 477 Plan and budget for the specified performance period.
477 Plan Requirements
477 Plan requirements are defined in Section 6 of Public Law 102-477. For a plan to be acceptable, it must:
Identify the programs to be integrated.
Be consistent with the purposes of the Act authorizing the services to be integrated into a demonstration project.
Describe a comprehensive strategy that identifies the full range of potential employment opportunities on and near the Tribal government's service area and the education, training, and related services to be provided that will assist Indian workers with accessing employment opportunities.
Describe how the Tribe will integrate and deliver services and the expected results of a successfully implemented Plan.
Identify the projected expenditures in a single budget.
Identify the agency or agencies of the Tribal government to be involved in delivering the services integrated under the plan.
Identify any statutory provisions, regulations, policies, or procedures the Tribal government believes need to be waived to implement its Plan.
Be approved by the governing body of the affected Tribe.
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