Public Comments

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OMAHA TRIBE OF NEBRASKA
Executive Officers

Jeff Gilpin, Chairman
Jason Sheridan, Vice-Chairman
Leander Merrick, Secretary
Cheyenne Robinson, Treasurer

Members

Galen Aldrich Sr.
Alan Harlan
Jazelle Miller

Omaha Tribe of Nebraska
Administration for Children and Families
Proposed Information Collection Activity: Guidance for Tribal Temporary Assistance for
Needy Families Program (Form ACF-123)
The Omaha Tribe of Nebraska appreciates the opportunity to submit written comments regarding
the proposed revisions to the Guidance for the Tribal Temporary Assistance for Needy Families
Program.
The Omaha Tribe of Nebraska is a federally recognized Tribal Nation headquartered in Macy,
Nebraska, with a reservation located in northeastern Nebraska along the Missouri River. The
Tribe exercises its inherent sovereign authority to provide governmental services to its citizens
and remains committed to strengthening Tribal families through culturally appropriate human
services, economic development, education, public safety, and community wellness. The Tribal
Temporary Assistance for Needy Families Program is an essential component of these efforts,
allowing the Tribe to design and administer family assistance programs that reflect the unique
needs, values, and priorities of the Omaha people.
The Omaha Tribe supports the Administration for Children and Families' efforts to modernize
and reorganize the Tribal Temporary Assistance for Needy Families guidance to make it more
accessible and easier to navigate. Improving the organization of the guidance and reducing
unnecessary administrative burden are positive steps that can allow Tribal governments to
dedicate more time and resources to serving families rather than completing paperwork.
However, any revisions to the guidance must continue to recognize Tribal sovereignty, uphold
the federal trust responsibility, and preserve the flexibility Congress intended when authorizing
Tribal administration of the Temporary Assistance for Needy Families Program.
The Omaha Tribe respectfully offers the following comments.
Tribal Self-Determination Must Remain the Foundation
The Tribal Temporary Assistance for Needy Families Program was established to allow Tribal
Nations to design programs that reflect their own governmental priorities and community needs.
Tribal governments understand the barriers facing their citizens and are best positioned to
determine how services should be delivered.
The Tribal Family Assistance Plan should remain in a strategic planning document that
demonstrates how each Tribal Nation intends to achieve program goals while preserving the

497 Main Street P.O. Box 368 Macy, Nebraska 68039 • Phone (402) 837-5391 • Fax (402) 837-5308

OMAHA TRIBE OF NEBRASKA
Executive Officers

Jeff Gilpin, Chairman
Jason Sheridan, Vice-Chairman
Leander Merrick, Secretary
Cheyenne Robinson, Treasurer

Members

Galen Aldrich Sr.
Alan Harlan
Jazelle Miller

flexibility necessary to develop culturally appropriate approaches. The guidance should avoid
creating unnecessary prescriptive requirements that limit innovation or encourage state-based
program models.
Recognize the Unique Needs of Rural Tribal Communities
The Omaha Reservation is located in a rural area where families often experience barriers that
differ significantly from those encountered in urban communities. Limited employment
opportunities, inadequate public transportation, shortages of affordable housing, childcare
challenges, behavioral health needs, and limited access to broadband all affect family stability
and economic opportunity.
These realities directly influence the administration of the Tribal Temporary Assistance for
Needy Families Program. The guidance should recognize that successful employment and selfsufficiency strategies may require greater flexibility for rural Tribal Nations, including support
for transportation, workforce development, education, and culturally appropriate case
management.
Support Coordination Across Tribal Programs
Many Tribal citizens receive services through multiple Tribal programs administered by the
Omaha Tribe, including child welfare, child care, behavioral health, workforce development,
housing, education, and other family support services.
The Administration for Children and Families should continue working to align planning and
reporting requirements across federal human services programs. Reducing duplicative
administrative requirements would allow Tribal governments to better coordinate services,
improve outcomes for families, and maximize limited staff resources.
The Omaha Tribe also encourages continued coordination with employment and training
programs authorized under Public Law 102-477 to better support integrated service delivery for
Tribal citizens seeking education, employment, and economic independence.
Provide Ongoing Technical Assistance

497 Main Street P.O. Box 368 Macy, Nebraska 68039 • Phone (402) 837-5391 • Fax (402) 837-5308

OMAHA TRIBE OF NEBRASKA
Executive Officers

Jeff Gilpin, Chairman
Jason Sheridan, Vice-Chairman
Leander Merrick, Secretary
Cheyenne Robinson, Treasurer

Members

Galen Aldrich Sr.
Alan Harlan
Jazelle Miller

While improvements to the guidance are welcome, many Tribal governments continue to operate
with limited administrative capacity. Successful implementation of revised guidance requires
ongoing support beyond publication of the final document.
The Omaha Tribe recommends that the Administration for Children and Families provide:
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National and regional training following the implementation of revised guidance.
Model Tribal Family Assistance Plans that may be adapted to local circumstances.
Individual technical assistance for Tribal administrators.
Plain-language implementation guides and planning tools.
Opportunities for peer learning among Tribal Temporary Assistance for Needy Families
programs.

These resources would improve implementation while respecting Tribal sovereignty and local
decision-making.
Respect Tribal Data Sovereignty
The Omaha Tribe supports responsible data collection that improves program quality and
accountability. However, data generated through Tribal programs belong to Tribal Nations and
should be governed accordingly.
Future revisions to reporting requirements should recognize Tribal ownership of program
information and ensure that any additional data collection is developed in consultation with
Tribal Nations. Data should support Tribal decision-making, improve service delivery, and
reduce administrative burden rather than create additional reporting obligations without
corresponding benefits.
Reduce Administrative Burden
Although the proposed revisions simplify the guidance, Tribal governments continue to
experience significant administrative responsibilities associated with plan development,
amendments, reporting, and monitoring.
The Omaha Tribe encourages the Administration for Children and Families to continue
identifying opportunities to:

497 Main Street P.O. Box 368 Macy, Nebraska 68039 • Phone (402) 837-5391 • Fax (402) 837-5308

OMAHA TRIBE OF NEBRASKA
Executive Officers

Jeff Gilpin, Chairman
Jason Sheridan, Vice-Chairman
Leander Merrick, Secretary
Cheyenne Robinson, Treasurer

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Members

Galen Aldrich Sr.
Alan Harlan
Jazelle Miller

Simplify Tribal Family Assistance Plan amendments.
Eliminate duplicative reporting requirements.
Improve electronic submission processes.
Coordinate review timelines.
Reduce unnecessary documentation requirements where permitted by law.

Every hour devoted to administrative compliance is time that cannot be spent serving Tribal
families.
Honor the Federal Trust Responsibility
The Tribal Temporary Assistance for Needy Families Program reflects the unique governmentto-government relationship between the United States and federally recognized Tribal Nations.
The federal trust responsibility requires meaningful consultation whenever policies affecting
Tribal governments are developed or revised.
The Omaha Tribe encourages the Administration for Children and Families to continue engaging
Tribal Nations early and throughout the policy development process to ensure that future
guidance reflects Tribal priorities and operational realities.
Conclusion
The Omaha Tribe of Nebraska appreciates the Administration for Children and Families' efforts
to improve the Tribal Temporary Assistance for Needy Families guidance and reduce
administrative burden. These revisions represent meaningful progress toward making the
guidance more useful and accessible for Tribal governments.
As the Administration for Children and Families finalizes this guidance, we encourage continued
emphasis on Tribal sovereignty, self-determination, administrative flexibility, rural service
delivery challenges, Tribal data sovereignty, and ongoing government-to-government
consultation. Strengthening these principles will better equip Tribal Nations to provide effective
services that improve the health, stability, and economic well-being of Tribal families.
The Omaha Tribe of Nebraska thanks the Administration for Children and Families for the
opportunity to provide these comments and looks forward to continued partnership in
strengthening Tribal family assistance programs.

497 Main Street P.O. Box 368 Macy, Nebraska 68039 • Phone (402) 837-5391 • Fax (402) 837-5308