The Indian Self-Determination & Education Assistance Act” requires the BIA and IHS to provide full funding for direct costs and indirect costs to tribes operating programs under PL 93-638.  A separate federal appropriation called Contract Support Costs (CSC) provides funding for tribal indirect cost rates (or administrative cost grants) on an annual basis for PL 93-638 awards.  Tribes apply their Negotiated Indirect Cost Rate Agreements (NICRAs) to the awards to determine the amount of CSC they are entitled to under the awards.  No other federal awards, including Federal Emergency Relief Funds, provide a separate appropriation for indirect costs, so recipients to must charge their administrative & overhead costs to direct funds to recover their administrative costs.

Relating to the Federal Emergency Relief Funds, the U.S. Treasury Department determined that where specific legislation does not permit the use of NICRAs tribes may charge a reasonable amount of administrative costs to the awards.  Relating to indirect costs, OMB recently issued an exception to 2 CFR §200.405(b), Allocable Costs, in instances where tribes are permitted to apply their NICRAs, to allow tribes to exclude any CARES Act funds from the Direct Cost Base that deny indirect cost recovery.

This course will explain what an indirect cost rate is, and how it is calculated and applied to federal awards.  It will explain the various types of indirect cost rates, and associated types of direct cost bases.  The course will explain classification of costs, treatment and application of costs to federal awards.  The course also covers the CSC policies of the BIA and IHS and how the policies impact PL 93-638 awards. Special focus will be placed on how indirect cost rates, when applied to the Federal Emergency Relief Funds, will impact the recovery of indirect costs on other federal awards. In this regard, attendees will learn the importance of using the appropriate direct cost base in the indirect cost equation.