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PL 477 Amendment Implementation

PL 477 Amendment Implementation. Steve Osborne, Katie Klass, Geoff Strommer Hobbs , Straus, Dean & Walker, LLP. Indian Employment, Training and Related Services Consolidation Act of 2017 Public Law 115-93.

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PL 477 Amendment Implementation

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  1. PL 477 Amendment Implementation Steve Osborne, Katie Klass, Geoff Strommer Hobbs, Straus, Dean & Walker, LLP

  2. Indian Employment, Training and Related Services Consolidation Act of 2017Public Law 115-93 • Amends Indian Employment, Training and Related Services Demonstration Act, more commonly referred to as PL 477, codified at 25 U.S.C. §§ 3401–3417. • Major Changes • Reauthorizes PL 477 program as permanent rather than demonstration project. • Expands types of programs and funding that may be integrated in PL 477 plans, including by including more agencies. • Clarifies PL 477 plans require only one annual report or audit and do not require reporting dollar-for-dollar by program. • Creates strict deadlines and processes for review and approval of PL 477 plans, including for agencies to waive requirements of integrated programs.

  3. Implementation of PL 477 AmendmentPrograms Eligible for Inclusion

  4. Implementation of PL 477 AmendmentPrograms Eligible for Inclusion

  5. Implementation of PL 477 AmendmentPrograms Eligible for Inclusion

  6. Basic Steps Implementation of PL 477 AmendmentProcess – Submission

  7. Implementation of PL 477 AmendmentProcess – Review

  8. Implementation of PL 477 AmendmentProcess – Approval

  9. Implementation of PL 477 AmendmentProcess – Implementation

  10. Implementation of PL 477 AmendmentProcess – Waiver

  11. Implementation of PL 477 AmendmentProcess – Waiver

  12. Implementation of PL 477 AmendmentProcess – Waiver

  13. Implementation of PL 477 AmendmentProcess – Appeal

  14. Implementation of PL 477 AmendmentMemorandum of Agreement • Agencies included in amended PL 477 have statutory deadline of one year from enactment to develop and enter into interdepartmental Memorandum of Agreement on implementation of new PL 477 legislation. MOA was completed in December 2018. • No tribal participation or consultation during drafting.

  15. Importance of PL 477 • PL 477 program allows tribes to combine federal funds made available for employment, training, or related services from varied sources into one single plan with one single budget and reporting system. • Creates more flexibility for tribes in deciding how to spend these federal funds so they can design more successful programs based on unique needs of each tribe’s community members. • Allows tribes to streamline administrative processes, including program applications and federal reporting, thereby lowering administrative costs and making more funds available for direct services. • Provides room for more robust exercise of tribal sovereignty. • Concept could eventually expand beyond employment and training.

  16. Questions? Steve Osborne sosborne@hobbsstraus.com 503-242-1745

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