bureau of indian affairs contract support cost workgroup tibc meeting may 20-21, 2015
TRANSCRIPT
Bureau of Indian AffairsContract Support Cost Workgroup
TIBC MeetingMay 20-21, 2015
Contract Support Costs Funding
• Funding and Shortfall Report (SFR)
2007: $143,628,0002008: $149,066,0002009: $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) 45.53% (I) 'Applicable IDC Rate CY 2014 (J) Year Rate was Established
FCF (K) Type of IDC Rate
TDC LESS PT (L) Basis of IDC Rate
A B C D E F G H I J K
CONTRACT NUMBER
CONTRACT TERM PROGRAM TITLE
TOTAL CONTRACT or GRANT'S AWARDED
AMOUNT
LESS (-) OTHER DIRECT EXCLUSIONS
& PASS-THROUGH
PROGRAM SALARIES
TOTAL DCSC NEED AT 100%
On-going
Awards Adjusted (Subtotal)
TOTAL IDC NEED AT 100%
100% IDENTIFIED TOTAL CSC
NEED
SHORTFALL AMOUNT(Overpaid)
(J – Amount CSC Awarded) (F x 15%) (D + E + G) (IDC Rate x H) (G + I)
1/1-12/31/14 CTGP $214,608 -$23,723 $101,010 $15,152 $206,037 $93,808 $108,960 ($40)
Road Maintenance $9,660 $0 $2,221 $333 $9,993 $4,550 $4,883 $0
Forestry Youth Initiative $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 $0
$250,813 -$50,268 $103,231 $15,485 $216,030 $98,358 $113,843
CSC AwardedCTGPRoads MaintenanceForestry Youth Initiative
$109,000 $0 $0
President’s 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: What’s Next?
• Recommendations approved• Workgroup meeting to be scheduled
• Update CSC Policy• Workgroup input critical
• Advocacy for Mandatory Appropriations Proposal
Workgroup MembersPrimary Tribal Representatives: Tribe (BIA Region) Phone Email
Amy Fredeen Cook Inlet (Alaska) 907-793-3431 [email protected]
Patty LeBlanc Chitimacha (Eastern) 337-923-4973 [email protected]
Vickie Hanvey Cherokee (Eastern Oklahoma) 918-931-0745 [email protected]
Lisa D. Drum Omaha (Great Plains) 402-837-5391 x108 [email protected]
Annette Johnson Red Lake Band of Chippewa Indians (Midwest) 218-679-1800 [email protected]
Cordell Shortey Navajo (Navajo) 928-871-6033 [email protected]
Greg Anderson Port Gamble (Northwest) 360-297-2646 [email protected]
Jim Mackay (Co-Chair) Susanville (Pacific) 530-260-3240 [email protected]
Darwin St. Clair, Jr. Chairman, Eastern Shoshone (Rocky Mt.) 307-332-3532 [email protected]
Rhonda Butcher Potawatomi (Southern Plains) 405-275-3121 [email protected]
Linda Austin Ysleta del Sur Pueblo (Southwest) 915-859-7913 x7725 [email protected]
Valerie Barr Ft. McDermott Paiute Shoshone Tribe (Western) 775-532-8259 [email protected]
Gary Hayes Chairman, Ute Mountain Ute Tribe (TIBC) 970-564-5600 [email protected]
Olivia Grass Oglala Sioux (TIBC) 605-867-8441 [email protected]
Workgroup MembersAlternate Tribal Representatives: Tribe (BIA Region) Phone Email
James Angaiak Nunapitchuk (Alaska) 907-527-5665 [email protected]
DeMakus Staton Eastern Band of Cherokee (Eastern) 828-497-7032 [email protected]
Edward Mouss Thlopthilocco Tribal Town (Eastern Oklahoma) 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]