1. FINANCIAL MANAGEMENT: OMB PROPOSES REVISIONS TO UNIFORM GUIDANCE
The Office of Management and Budget (OMB) posted proposed revisions for the uniform guidance into the Federal Register on October 5, 2023. A redline version of the proposed changes can be viewed here. Comments are due to the OMB by December 4, 2023.
Overview of ProposedOverview of Proposed Uniform Guidance
The proposed guidance includesThe proposed guidance includes clarification to the applicability of requirements and terminology and some relaxation and clarification to certain requirements that required prior approval from federal regulators. A few key proposed changes include the following:
- Increase the audit threshold to $1 million from $750,000
- Increase the de minimis indirect cost rate from 10% to 15%
- Require the Schedule of Expenditures of Federal Awards (SEFA) to identify recipient of federal award for audits that cover multiple recipients
Although OMB is proposing a change to the audit threshold, as noted above, OMB isn’t proposing an increase to the threshold for type A and type B determination, related to major program determination.
Other proposed changes include additional requirements related to acts that directly support or advance trafficking in persons, additional requirements related to discrimination and changes to whistleblower protections.
Reviewing the proposed guidance and submitting any comments about the proposed changes by the December 4, 2023, deadline is recommended.
Source: Moss Adams
2. ENERGY: IRS ANNOUNCES VIRTUAL WORKSHOP FOR TRIBAL CLEAN ENERGY CREDITS
The Internal Revenue Service (IRS) has announced a virtual outreach workshop on Tuesday, December 12th at 12:00 p.m. Eastern Time to discuss clean energy tax credits for tribes. These credits were included as part of last year’s Inflation Reduction Act (IRA) and opened up new options to tribes through Elect/Direct Pay tax credits.
The IRS will be sending a Microsoft Teams invite in a future email.
The IRA allows Indian tribal governments and Alaskan Native Corporations to benefit from certain clean energy tax credits through elective pay. For tax years beginning after December 31, 2022, an applicable entity that qualifies for a clean energy tax credit can make an elective payment election. This election will treat certain credits as a payment against their federal income tax liabilities rather than as a nonrefundable credit. The amount of the credit will first offset any tax liability of the entity and any excess will be refundable.
Source: Internal Revenue Service
3. MUST READ: NATIVE AMERICAN POPULATIONS ARE ‘INVISIBLE’ TO BANKS. THAT NEEDS TO CHANGE
Growing up on the Rosebud Indian Reservation in South Dakota, Dawson Her Many Horses was rich in culture. But he and his family lacked many other critical resources.
“When I was a kid we had an outhouse, our home was heated by a wood burning stove,” he told CNN. “I understand what it’s like to live in a rural community without financial resources.”
That connection has motivated Her Many Horses to advocate for Native American and Alaskan Native communities throughout his career in finance. He currently serves as head of Native American banking for Wells Fargo and in July the bank announced he would become a managing director.
Her Many Horses, a member of the Rosebud Sioux Tribe of South Dakota, is one of the first enrolled tribal members to be promoted to managing director at a major US bank, according to a statement from Wells Fargo.
“I’ve made most of my career decisions based on how I can be a better advocate and champion for tribal communities,” he told CNN. “So for me personally, just the fact that I grew up on a reservation and that I still have family there keeps me grounded. It reminds me of why I do this work.”
Source: CNN Business
4. IN THE NAFOA NAVIGATOR: TRIBES PROTECTING TRIBES
By Tina Duncan, Director of Business Development, AMERIND
In 1986, the insurance industry was rocked by instability and financial uncertainty. As a result, Indian Country was faced with limited coverage options and exorbitant premiums with no guarantee that the policies wouldn’t be canceled. Tribal leaders came together with a radical vision and over 400 Tribes pooled their resources to form an insurance company rooted in the fundamental principle of “Tribes Protecting Tribes.” Today, AMERIND remains the only 100 percent Tribally-owned and operated insurance provider committed to keeping Tribal money in Indian Country to strengthen tribal nations, citizens, and enterprises. Through our fiscally sound and culturally responsive insurance products, Tribes can exercise their sovereignty and self-determination over their economies by protecting their people and keeping Tribal money in Indian Country.
5. JOBS: ALABAMA-COUSHATTA TRIBE OF TEXAS SEEKING CFO
The Chief Financial Officer will be leading the day-to-day leadership and management of all fiscal operations of the government including planning, organizing and controlling financial resources and expenditure processes.
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