Here is the opinion in In re M.H.:
An excerpt:
Father is correct that the Act requires that a party seeking to terminate the parental rights of a child that may be Native American must follow specific procedures for notifying the child’s potential tribe about a termination-of-parental-rights hearing. See 25 U.S.C. § 1912(a) (2012). Though the best way for a court to ensure compliance with the Act is for the State to file the notices it has sent and the return receipts it has received with the district court before a termination hearing, the State’s failure to do so here doesn’t require reversal. The State filed the required notice and receipts after the hearing in this case, and those filings prove that the district court complied with the Act.
Turtle Talk 
Hi Matthew–The court opinion says that “the State did comply with the Act. The State sent notice to the Ramapough Lenape Nation, which received it on June 12, 2013. The hearing to terminate Father’s rights did not begin until November 5, 2013—nearly 4 months later—clearly after the 10-day period the Act required.” But your headline says the court held that the notice may be sent to the tribes “After Parental Rights Termination Hearing.” ?? Thanks, Lucy Braun
You’re right–the headline should say the State can file the *evidence* of notice after the TRP hearing.
-Kate