This assumption is compatible with the following statements in ANA's 1982 Issue Paper on Status Clarification:

"From the perspective of ANA's mandate, [the policies of] non-recognition and termination stand as barriers to Indian social and economic self-sufficiency. Both policies undermine the ability of Indian leadership to represent their constituencies before non-Indian entities. Both inhibit the exercise of lawful rights. Both fragment tribal cohesiveness. And, felt as affronts to tribal heritage, both produce attitudinal barriers to community development."

In other words, ANA's Status Clarification Program was intended to assist groups to obtain some type of formal recognition. We stress this point here, because several ANA staff implied to us that formal recognition (either Federal or State) did not, in fact, have to be a community's intention when obtaining ANA status clarification funds. We believe this interpretation inconsistent with documented policy and program announcements and have proceeded with our study on the assumption that the statements in the above referenced Issue Paper remain true with respect to ANA's posture.

Although 1982 represented the last year in which ANA published a specific Status Clarification Program Announcement, the agency has since 1981 permitted its regular SEDS grants to be used for the same purpose viewing status clarification as (1) an essential ingredient to any future true self-determination efforts of an unrecognized Indian community, and (2) a precursor to being able to effectively govern or develop social and economic infrastructures necessary for a community's self-sufficiency. In other words, status clarification went hand in hand with ANA's overall SEDS initiatives. Since 1981, ANA has, in fact, funded over 118 grants which have been in part or exclusively directed toward status clarification initiatives at the local level. These 118 grants have provided money to at least 35 unrecognized communities, located in 15 states. Unfortunately neither ANA Program Information and Evaluation System (PIES) data nor ANA grant records enabled ORBIS Associates to determine the total funding amount which these grants represent. Listed on the next page are 35 of the communities that have benefitted from ANA status clarification funding and which are the study sample for this evaluation report.

ANA Status Clarification
Grantees In Study Sample

1. Abenaki Tribal Council, also known as Abenaki Self Help Association, Inc. (VT) 2. American Indian Council of Mariposa County, also known as Yosemite Tribe (CA) 3. Aroostook Band of Micmacs (ME)

4. Brothertown Indian Tribe of Wisconsin, also known as Brotherton Nation, Inc. (WI) 5. Central Valley Wintu, Inc. (CA)

6. Chinook Indian Tribe (WA)

7. Clifton Choctaw Indians (LA)

8. Coastal Band of Chumash Indians (CA)

9. Coharie Intra-Tribal Council (NC)

10. Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians (OR)

11. Confederated Tribes of Grand Ronde (OR)

12. Cow Creek Band of Umpqua Indians (OR)
13. Duwamish Indian Tribe (WA)

14. Florida Tribe of Eastern Creeks, Inc. (FL)
15. Haliwa Saponi Indian Tribe, Inc. (NC)
16. Jena Band of Choctaw Indians (LA)

17. Juaneno Band of Mission Indians (CA)

18. Little Shell Tribe of Chippewa Indians of Montana (MT)

19. Lumbee Regional Development Association, Inc. (NC)

20. Mashpee Wampanoag Tribal Council, Inc. (ME)

21. Miami Nation of Indians of the State of Indiana, Inc. (IN)

22. Mowa Band of Choctaw Indians (AL)

23. Nor-El-Muk Band of Wintu Indians, also known as Hayfork Band of Norelmuk Wintu Indians (CA)

24. Northern Cherokee Tribe of Missouri and Arkansas (IN)

25. Poarch Band of Creek Indians (AL)

26. Pokagon Band of Potawatomi Indians, also known as Potawatomi Indian Nation, Inc. (MI)

27. Samish Tribe of Indians (WA)

28. San Juan Southern Paiute (AZ)

29. San Luis Rey Band of Mission Indians (CA)

30. Snoqualmie Indian Tribe (WA)

31. Steilacoom Tribe (WA)

32. Tuscarora Tribe of North Carolina, Inc. (NC)

33. United Houma Nation, Inc. (LA)

34. Waccamaw Siouan Development Association, Inc. (NC) 35. Wampanoag Tribal Council of Gay Head, Inc. (MA)

II. METHODOLOGY

The study sample of 35 Indian groups was determined through consideration of several factors. To begin with, we noted that although the RFC Scope of Work statement referred to 48 grantees, the actual number of grantees listed in Appendix A of the RFC was 46. Through a review of project files in the ANA offices, we discovered that eight of the listed grantees were duplicates, i.e., one grantee community under different names or the same grantee listed under two States. Specifically, these were:

Thus, the initial study group list was reduced from 46 to 42. Of those 42, one listed grantee (Schaghticoke Indian Tribe) was found to have terminated its FY 1982 grant. Another grantee (Narragansett Tribal Education Project, Inc.) was eliminated from the study sample by technical direction from ANA Four other grantees had no files available for review (Nelechundum, Shasta, New Hampshire Indian Council, and Pee Dee.) Thus, the study sample decreased to 36 Indian groups.

Again, through the review of file materials and/or PIES data, we determined that five of the remaining 36 grantees did not use their ANA funding for status clarification activities as defined by the study team. The definition of status clarification as used by the team was taken from the ANA Program Announcement (No. 13612-815) for status clarification minigrants to Indian groups "for community applied research to clarify their

status as Indians and as tribes within their States and/or with the Federal government." Brief profiles of these five grantees are in Appendix C. The sample group was,

therefore, further reduced to 31.

Thus, included in our study sample there were a total of 31 grantees from the original RFC list. In an effort to offset some of this difference in numbers, through the file review and discussions with ANA staff, we located four grantees who had used ANA money for status clarification purposes, and although not included on ANA's RFC list, were therefore, added as part of the study sample. These four grantees were:

San Luis Rey Band of Mission Indians (California)

United Houma Nation (Louisiana)

The Wampanoag Tribal Council of Gay Head (Massachusetts)
Abenaki Self-Help Association, Inc. (Vermont).

This project's evaluation methodology required data collection from a number of sources. As noted above, the first source of data which the study team reviewed was ANA grant files. To the extent files were available, grant documents were reviewed for the communities/groups that appeared on the RFC list. Files were expected to contain grant applications (including general demographic data for each community), grant award documents, evaluation reports, correspondence regarding grant implementation and, to the extent appropriate, ANA staff notes regarding grant monitoring. The completeness as well as comprehensiveness of grantee files varied considerably from one grant year to the next as well as from one grantee to the next. The lack of consistent information presented certain impediments to this study with respect to comparability of data across grantees. It was hoped that, to some extent, the gaps in information found in the files, could be supplemented through direct contact with grantees, the Bureau of Indian Affairs BAR staff, and, for the nine case study communities, through collection of on-site information. This ANA file search was also supplemented by review of ANA PIES data and other documents provided by staff.

After completing the ANA file search and review of other ANA information, ORBIS prepared the framework for a composite profile of each grantee. The profiles were intended to yield a descriptive and statistical context against which data could be meaningfully reviewed. The profiles include an overall description of each community, a history of its status clarification effort and the use to which it put its ANA funding (e.g., objectives by grant year) with respect to supporting status clarification activities.

The second step in data collection involved contacting the ANA study group grantees directly via telephone. This step in fact overlapped in time with the latter part of the file review process: While initially our intention was to speak with appropriate personnel at each of the 35 sites, this strategy was changed. After contacting approximately 37 percent of the grantees, we found that for the most part we were either collecting data which we were already ascertaining through the file reviews, or we were being given information which was difficult to verify and which was often in direct conflict with ANA files or PIES information. Perhaps more importantly, more than half of the communities we contacted were unable to furnish us with any information at all as to how ANA grant funds had been used or what the short or long term impact had been of ANA supported activities. This was largely due to substantial change in board members or staff, the absence of whom left gaps in the institutional memory. It was determined that it was not cost effective to complete the telephone contacts as the supplemental information we were gathering was negligible at besi.

In November 1987, the Evaluation Schema (Deliverable No. 1) was submitted to ANA. The schema delineated specific issues and considerations as they related to specific subsets of the study sample. These issues were based on information culled from the grant files, ANA and BAR documents, telephone contact with grantees, and consultants' knowledge about specific grantees. The evaluation schema served as a conceptual framework for organizing the issues to be addressed in the evaluation study. There were nine issues presented in the schema. These issues were: