Public Law 102-477 (often referred to as “477”) is the Indian Employment, Training and Related Services Demonstration Act, which was passed in 1992 and amended in 2000.
The goal of the law is to reduce unemployment through workforce development and job training in tribal communities by reducing and streamlining administrative requirements.
This permanent legislation with no expiration date gives tribes the authority to integrate federal employment and training-related services into a single plan for their tribal members.
Participation is voluntary, and the Bureau of Indian Affairs (BIA) is the lead federal agency for the inter-departmental project.
How 477 Plans Work
Each participating tribe decides which eligible employment and training related federal programs to include in its 477 plan.
Public Law 102-477 applies to any federal formula-funded program intended for employment, training, and services that may enhance a person’s ability to become self-reliant.
Examples of eligible programs include BIA’s Job, Placement and Training Program, the Department of Labor’s WIA section 166 Comprehensive Services Program, and the Department of Health and Human Services’ Native Employment Works Program.
A 477 plan is an opportunity for a tribe to develop an employment and training service that is based on their unique tribal goals. In the past, tribes have developed plans that focused on raising educational achievement, addressing the needs of tribal youth, increasing self-sufficiency, and fostering tribal economic development.
Requirements for 477 plans are found in Section 6 of Public Law 102-477.
There is no separate funding associated with Public Law 102-477 itself.
All the funds involved in a tribe’s 477 plan are those which the tribe would have otherwise received from the individual federal programs that are part of their plan.
How to Participate
A tribe wanting to take advantage of Public Law 102-477 should submit an integrated service plan and budget to BIA Indian Services.
A review of their plan is coordinated with BIA’s federal partners who will also decide on its approval. Once approved, the agencies whose programs are included in the plan will transfer funds for the tribe to BIA. After BIA receives the funds, they’ll provide them to the tribe through a Public Law 93-638 grant award designed for 477 or a 477 modification to a Public Law 93-638 self-governance compact.
The tribe is then able to implements its services under the approved plan and budget. Tribal 477 plans are approved for three years at a time.
Benefits of Participating
Tribes have reported several benefits of participation:
- Improved client services: Increased number of clients served, and improved outcomes for clients
- Better utilization of program staff: Counseling staff can now serve clients based on client needs, not based on where the money for their salaries originates. Line staff can also focus on providing services to all clients who need them.
- A single intake system: With only one file for each client, it eliminates the need for multiple files for the same person. The amount of information maintained on each client is also reduced because the federal 477 report form is often simpler than those used for any of the individual programs.
- Reduction in federal paperwork: Statistics show that the number of reports that must be provided to federal funding agencies is reduced by over 90% from what was required of a tribe before 477 was introduced.
- Tribal plans can follow tribal, rather than federal priorities: Public Law 102-477 aims to empower each participating tribe to set their own goals for services.
- A single budget: The public law specifically states that a tribe will submit only one budget for all the funds included in their 477 plan.
Encouraging Economic Development
Title XI of Public Law 106-568 authorizes tribes participating in Public Law 102-477 to devote up to 25% (depending on their local unemployment rate) of their 477 resources to economic development efforts. This overrides any statutory or regulatory prohibitions that part of the individual federal programs in the tribe’s 477 plan.
Title XI also allows tribes to request a statutory waiver of program provisions that could inhibit the successful implementation of their approved 477 plan.
This creates even more flexibility in a participating tribe’s ability to effectively deliver 477 services.