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OMB Reforms: Financial Management for Tribal Governments and Federal Grants

January 15, 2014

On December 26th, 2013 the Office of Management & Budget (OMB) and the Council on Financial Assistance Reform (COFAR) published reforms to OMB Guidance titled "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards."

NAFOA has been advocating for tribal governments in working with the OMB as it prepared the guidance. NAFOA, Indian tribes, and other organizations had many common concerns related to how OMB was considering financial reforms. The final guidance addressed many of the recommendations, including removing the proposal that would require tribes to publish their entire Single Audit reporting package containing audited financial statements. This would have placed tribes at a disadvantage when negotiating compacts and maintaining a competitive advantage for tribal enterprises. However, further clarification is needed to ensure all tribal entities are protected.

Noteworthy Changes Affecting Tribes

  1. The guidance removed tribes from the definition of state.  
  2. A Single Audit will not be required for tribes or tribal organizations that expend less than $750,000 in federal awards during the fiscal year. 
  3. Tribes will have the option to opt out of the Report Submission. If they choose to exercise this option, they are responsible for providing their audit reports to any pass-through entities.
  4. The guidance now includes language that permits up to 50% of the salaries and expenses of tribal leaders and governing bodies directly attributable to managing and operating federal programs to be treated as allowable indirect costs without documentation.
  5. The notice of funding opportunities will now be open a minimum of 60 days in advance.

Over the next few months, NAFOA will host a series of webinars, which will cover changes to Administrative Requirements, Cost Principles, and Audit Requirements as it relates to tribes. An overview session will also be featured at the 32nd Annual Conference, April 14th-15th in New Orleans, LA.

For questions or comments, please contact Jennifer Parisien at Jennifer@nafoa.org or 202-558-8040.

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