Bureau of Indian Affairs Contract Support Cost Workgroup TIBC ...

Bureau of Indian Affairs Contract Support Cost Workgroup TIBC ...

Bureau of Indian Affairs Contract Support Cost Workgroup TIBC Meeting May 20-21, 2015 Contract Support Costs Funding Funding and Shortfall Report (SFR) 2007: $143,628,000 2008: $149,066,000 2009: $147,294,000 (72.60%) 2010: $166,000,000 (75.16%) 2011: $219,200,000 (97.46%) 2012: $219,200,000 (94.86%) 2013: $207,743,000 (92.09%) 2014: $242,000,000 (100%) 2015: $246,000,000 (100%) 2016: $277,000,000 (100%) 2017: Mandatory Appropriations Contract Support Costs Appropriation FY2014 & FY2015 CSC Appropriation Language SHORT TERM--Full Funding for 2 years No CSC Line item: Agency to find the funds within its budget Untenable position: Mandatory CSC requirement vs Discretionary Funding LONG TERM--Consultation to address solutions for the long run Consider a standardized, streamlined approach keeping in mind that IDC rates change annually Contract Support Costs Workgroup Workgroup Recommendations Sept. 2014: Full CSC Funding - NO Program Cuts Mandatory indefinite appropriation No change in ISDEAA CSC Provisions Simplify IDC Negotiation Over two-thirds of Tribes do NOT have current rates Workgroup work with IBC & OMB to determine if: IDC Rates can be deemed approved if no correspondence received from IBC after 90 days Fixed multi-year rates are allowable Contract Support Costs Workgroup

Workgroup Recommendations Sept. 2014, continued DCSC - change amount allowed from 15% to 18% of salaries Timely distribution of Funds Budget CSC with all program increases Training on policy and Short Fall Report (SFR) Overpayments - fair, predictable consistent resolution Adequate notice with appeal rights Options Repay CSC in current year Off-set in the following year Contract Support Costs Workgroup Workgroup Recommendations Sept. 2014, continued Office of Self-Governance (OSG) 1. OSG-CSC Calculation Form (BIA-CSC calculation Form) Recommendation: To develop submission form that captures all data elements necessary to complete the CSC calculation and seek OMB approval for future years. 2. Timely distribution of funds Recommendation: a) Deadline should be established for all programs; b) Review of distribution/obligation process to reduce backlog; c) Tribes provide required documentation as soon as possible; d) Disseminate information on any funding increases or decreases as soon as possible; and e) Hiring of a budget analyst. CSC Distribution from OSG Balance need for full CSC Funding to Tribes with the need to avoid overpayments by the Agency in this full Funding Environment Transition years 2014/2015 OSG Payment Procedure = Payment of 90% of Prior Year Funding (CRs apply) when Budget approved with remaining 10% later in the year Annual CSC Information Request is Key to Accurate CSC Funding - Old Form can be used (exclusions and updated rates) Process for FY 2016 Distribution Options: Pay 90% upon Federal Allocation then 10% later in year as in 2014/2015 Pay 85% upon Federal Allocation then 15% later in year in 2016 Pay as you go 2 CFR Part 200 OMB Super Circular Exclusions the portion of each subaward or subcontract in excess of $25,00. This also includes equipment costs over $5,000 and capital expenditures.

Pass-through funds funds that are received from a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program. How do I know if I am receiving 100% CSC Funding? TRIBE: (B) A CONTRACT NUMBER 45.53% B CONTRACT TERM C D E PROGRAM TITLE TOTAL CONTRACT or GRANT'S AWARDED AMOUNT LESS (-) OTHER DIRECT EXCLUSIONS & PASS-THROUGH (I) 'Applicable IDC Rate F G PROGRAM SALARIES H TOTAL DCSC NEED AT 100% (F x 15%)

1/1-12/31/14 CTGP Road Maintenance Forestry Youth Initiative CSC Awarded CTGP Roads Maintenance Forestry Youth Initiative $109,000 $0 $0 (J) Year Rate was Established CY 2014 On-going Awards Adjusted (Subtotal) (D + E + G) FCF (K) Type of IDC Rate TDC LESS PT (L) Basis of IDC Rate I J K TOTAL IDC NEED AT 100% 100% IDENTIFIED TOTAL CSC NEED SHORTFALL AMOUNT

(Overpaid) (IDC Rate x H) (G + I) (J Amount CSC Awarded) $214,608 -$23,723 $101,010 $15,152 $206,037 $93,808 $108,960 ($40) $9,660 $0 $2,221 $333 $9,993 $4,550 $4,883 $0 $26,545 -$26,545 $0 $0

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $250,813 -$50,268 $103,231 $15,485 $216,030 $98,358 $0 $113,843 Presidents Budget Solution Mandatory Appropriations Primary Goal: FULLY FUND CSC WITHOUT REDUCING PROGRAM FUNDING Proposal in FY 2016 Appropriations to implement in FY 2017 (Time for Consultation and Planning) Move CSC to 3 year mandatory appropriation separated from discretionary Program Funding Allow no-year funds to carry over fiscal years Update funding levels with reauthorization FY 2017 FY 2018 FY 2019

$307 mil. $322 mil. $338 mil.* *Up to 2% can be used for Administration of CSC Mandatory CSC Comments Implementation Timeline: Can the proposal be implemented in 2016 rather than 2017? Timeframe: Rather than three year appropriation, can the funding be of unlimited duration? Identified Amounts and CBO Score: Are the amounts necessary for passage or can it be amounts as needed? 2% Set-Aside: Can this amount be reduced? Full Support for the Proposal: As-is or with Changes Contract Support Costs: Whats Next? Recommendations approved Workgroup meeting to be scheduled Update CSC Policy Workgroup input critical Advocacy for Mandatory Appropriations Proposal Workgroup Members Primary Tribal Representatives: Tribe (BIA Region) Phone Email Amy Fredeen Patty LeBlanc Cook Inlet (Alaska) Chitimacha (Eastern) 907-793-3431 337-923-4973 [email protected] [email protected] Vickie Hanvey Cherokee (Eastern Oklahoma) [email protected]

Lisa D. Drum Omaha (Great Plains) 918-931-0745 402-837-5391 x108 218-679-1800 [email protected] 928-871-6033 [email protected] [email protected] Cordell Shortey Red Lake Band of Chippewa Indians (Midwest) Navajo (Navajo) Greg Anderson Port Gamble (Northwest) 360-297-2646 [email protected] Jim Mackay (Co-Chair) 530-260-3240 [email protected] 307-332-3532 [email protected] Rhonda Butcher Susanville (Pacific) Chairman, Eastern Shoshone (Rocky Mt.) Potawatomi (Southern Plains) [email protected]

Linda Austin Ysleta del Sur Pueblo (Southwest) 405-275-3121 915-859-7913 x7725 775-532-8259 [email protected] 970-564-5600 [email protected] 605-867-8441 [email protected] Annette Johnson Darwin St. Clair, Jr. Valerie Barr Gary Hayes Olivia Grass Ft. McDermott Paiute Shoshone Tribe (Western) Chairman, Ute Mountain Ute Tribe (TIBC) Oglala Sioux (TIBC) [email protected] Workgroup Members Alternate Tribal Representatives: James Angaiak DeMakus Staton Edward Mouss Tribe (BIA Region) Nunapitchuk (Alaska) Eastern Band of Cherokee (Eastern) Thlopthilocco Tribal Town (Eastern Oklahoma)

Phone Email 907-527-5665 [email protected] 828-497-7032 [email protected] 918-560-6198 [email protected] Jeremy Gone Omaha Tribe (Great Plains) 402-837-5391 [email protected] Carrie Carlson Little Traverse Bay Band of Odawa Indians (Midwest) 216-838-6850 [email protected] Rachael Arviso Navajo (Navajo) 928-871-6033\6041 [email protected] Renee Veregge Port Gamble (Northwest) 360-297-6236 [email protected] Elizabeth Hansen

Redwood Valley Rancheria (Pacific) 707-485-0361 [email protected] Need Representative (Rocky Mt.) Need Representative (Southern Plains) Peggy L Vigil Mescalero Tribe (Southwest) 575-464-9328 [email protected] Terry Rambler San Carlos Apache Tribe (Western) 928-475-2361 x5 [email protected] Workgroup Members Federal Members: BIA Region Phone Email Terry Parks (Co-Chair) OIS - DSD 202-513-7625 [email protected]

Hankie Ortiz Deputy Director, OIS 202-208-2874 [email protected] Judy Mitchell OIS - DSD 202-208-4506 [email protected] Debra Peebles Central Office West - DSD 505-563-3677 [email protected] Kirk G Meyer Eastern 615-564-6962 [email protected] Yvonne LaRocque Great Plains 605-226-7426 [email protected] Michelle McCormick Midwest 612-725-4588 [email protected] Sunshine Jordan

OIS - DSD 202-513-7616 [email protected] Stella Corbin Rocky Mt. 406-247-7984 [email protected] Kelly Moore Southern Plains 405-247-1574 [email protected] Nick Longley Office of Self Governance 360-699-1010 [email protected] Tom Gubatayao Office of Self Governance 360-699-1010 [email protected]

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