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Contracts & Grants Compliance Training Series

Contracts & Grants Compliance Training Series

KIVA provides the following courses designed to educate, inform and advise tribes and tribal organizations of various federal laws and regulations that apply to certain federal awards to ensure tribes and tribal organizations remain in compliance with their federal awards. Courses include, but are not limited to:


$850  OMB Uniform Administrative Requirements (CARES Act/ARPA); (3 Days)

Indian tribes and tribal organizations operate two basic types of federally funded programs: (1) Discretionary Grant Programs; and (2) Entitlement Programs.  Discretionary grants are one-time competitive grants. Entitlement Programs, such as Public Law 93-638 contracts and compacts, are recurring programs.  Federal rules that apply to these programs differ in many respects, yet there are similarities. OMB issued new regulations in 2013 to consolidate several OMB Circulars into one set of regulations (2 CFR Part 200) that many refer to as the “Super Circular”.  OMB revised the regulations in 2020 to specifically address the CARES Act (Public Law 116-136) and the American Rescue Plan Act (ARPA), (Public Law 117-2).  While the Bipartisan Infrastructure Investment and Jobs Act has not been enacted, funds under the new legislation will be also governed by the OMB Uniform Administrative Requirements.

The OMB regulations govern federal grant management, grant reporting, cost principles, indirect costs, grant match and cost-sharing, and annual audits.  The regulations apply to Indian tribes, tribal organizations, states and local governments, non-profit organizations, hospitals, universities, etc.  With the outbreak of COVID-19 pandemic, Congress provided special emergency relief funding through the CARES Act of 2020, Public Law 116-136, the American Rescue Plan Act of 2021 (ARPA), Public Law 117-2.  Congress is currently in deliberations on a new Bipartisan Infrastructure Investment and Jobs Act to provide for the nation’s infrastructure needs.  These funds are subject to certain provisions of the OMB Uniform Administrative Requirements, including annual audits. Office of Management & Budget (OMB), in August 2020, published its amendments to the 2014 Uniform Administrative Requirements; and in December 2020, it issued an Addendum to the FY 2020 Audit Compliance Supplement to specifically respond to the federal emergency relief funds related to the coronavirus pandemic.

This course will address the similarities and differences in OMB rules as they pertain to discretionary grant programs; entitlement programs (Indian Self-Determination Act programs); and will provide a special focus on CARES Act and ARPA compliance and reporting requirements.

Who Should Attend?

Tribal council members, chartered organizations school boards, health boards, tribal, program directors and managers; tribal grants/contracts staff, finance and accounting staff; tribal attorneys, tribal consultants.  Federal officials and federal awarding officials, federal contracting officers and their subordinates should also attend.

What Will I Learn?

  • Purpose of the OMB Super Circular
  • Comparison of discretionary grant programs vs. entitlement programs
  • Pre-award requirements (federal merit reviews, tribal capacity issues, risk assessments)
  • Impacts on “High Risk” tribes
  • Conflicts of interest required certifications and disclosures
  • Post-award requirements (performance management requirements; advances & payments)
  • Cost-sharing and matching requirements
  • Budgets & program plans
  • Program income rules
  • Grant administration and closeout rules
  • Cost Principles – Select Items of Cost (discretionary grants and entitlement program differences)
  • Audit Requirements (major program determinations, high-risk determinations, sanctions for non-compliance)

$1000  Practicum for Federal Line Officials & Awarding Officials; (4 Days)

Federal Awarding Officials play a vital role in many aspects of contracts awarded under the Indian Self-Determination Act (Pub. L. 93-638), including awarding, administering, monitoring, ensuring proper closeout; and taking remedial action to address contract compliance issues when necessary. Approving Officials are responsible for addressing pre-award issues such as funding levels, declination issues, etc. They also must make an important decision whether to invoke a reassumption of a contracted program. Awarding Officials are responsible for ensuring contract compliance, and ensuring annual audits are conducted and those audit findings are addressed, and issuing determinations and findings; taking appropriate action to address contract compliance issues, and ensure tribes and tribal organizations are provided technical assistance.

The Practicum is a comprehensive course that provides special insight into the authorities, duties, and responsibilities of federal Line Officers and Awarding Officers and their subordinates. The course provides information on a special federal code of ethics and rules that govern the conduct of awarding officials and their subordinates. This course is a recommended course for all federal line officers and awarding officials to receive and maintain their annual certification requirements. This course can also be valuable to tribes that operate programs under Pub. L. 93-638.

Who Should Attend?

All federal awarding officials, awarding officials’ technical representatives (AOTRs), subordinate awarding officials’ technical representatives (SAOTRs); federal line officers, tribal contract/grant officers, tribal administrators, tribal program directors, and managers,

What Will I Learn?

  • Roles and responsibilities of federal line officers and awarding officials
  • Statutory and regulatory requirements of Pub. L. 93-638 (Indian Self-Determination Act)
  • What are Programs, Functions, Services & Activities (PFSAs)?
  • Contract application, review, award (and declination)
  • Tribal sovereignty and rights of Indian tribes
  • Bureau of Indian Affairs and Indian Health Service Delegation of Authority
  • Congressional appropriations & appropriations laws
  • Financial management and reporting requirements
  • Contract preparation phase & contract proposal submittal phase
  • Statutory contract declination criteria, declination process, litigation
  • Contract administration, monitoring & closeout
  • Secretarial Funding Levels and funding protections
  • Types of contract awards (Model 108 Non-Construction Contract & Subpart J Construction Contract
  • Team Exercises: Developing Annual Funding Agreements
  • Special session on Indirect Cost Rates & how indirect cost rates apply to Pub. L. 93-638 agreements
  • Contract Support Costs & the BIA/IHS Contract Support Cost policies
  • Pre-award appeals and process
  • Contract Disputes Act (documentation requirements to awarding officials’ decisions; disputes resolution)
  • Alternative Dispute Resolution Act (mediation process, dispute resolution process)
  • Federal Tort Claims Act
  • Single Audit Act and audit compliance supplement (procedures and sanctions)

$850  Federal Grant Management Principles (3 Days)

Most, if not all Indian tribes, tribal organizations, nonprofit organizations, etc., operate programs funded by the federal government.  As such, they must know federal rules that apply to their specific awards; and to grant awards in general, from applying for discretionary grants to receiving and accepting the grant awards, to administering the grant award, financial reports and narrative reports, grant closeout; and annual audits.  Awardees need to know financial management rules and cost principles that apply to their awards; grant matching requirements, rules that apply to equipment purchases, etc.  This course covers the regulations in the Office of Management & Budget’s Uniform Administrative Requirements, commonly referred to as Super Circular.

Who Should Attend?

Tribal council members, boards of directors, tribal executive directors, program directors and managers, tribal grant writers, finance and accounting staff, tribal audit firms, tribal consultants.

What Will I Learn?

  • Differences between two major types of federal awards: (1) Entitlement Programs; and (2) Discretionary Grants
  • Grants Management Cycle
  • Notices of Funding Opportunities (NOFOs)
  • The New SAM Grant Changes (Unique Entity Identifier)
  • Highlights of OMB Super Circular
    • Pre-Award Requirements
    • Grant Proposal Review Requirements
    • Post-Award Requirements
    • Cost Principles
    • Grant Close-Out
    • Single Audit Act
    • Mandatory Disclosure Requirements
  • Indirect Cost Rate Agreements (Application of IDC Rates to Grant Awards)
  • Incremental Funding Requirements
  • Financial Reporting Requirements (SF-425s)
  • Cost Sharing & Grant Match Requirements (Cash and In-Kind Match Requirements)
  • Rules on Program Income
  • Program Budgets
  • Rules on Equipment & Property (Acquisition, Management, Use, Disposal)
  • Program Monitoring Requirements
  • Remedies for Non-Compliance
  • Special Review of KIVA’s Cost Principles Matrix (Customized for Tribal Use)

$850  Contract Scopes of Work & Annual Funding Agreements (3 Days)

Pub. L. 93-638 authorizes three types of contracts/compact agreements: (1) Non-Construction Contracts; and (2) Construction Contracts under Subpart J of the regulations; and (3) Self-Governance Compacts. Self-Determination contracts and Self-Governance Compacts require an Annual Funding Agreement (AFA) that is negotiated each year. AFAs are required to be submitted to the funding agency at least 120 days prior to the ending of the current contract period.

An Annual Funding Agreement (AFA) must describe the Programs, Functions, Services, and Activities (PFSAs) that the subject of the contract and compact. It identifies the general budget categories and funds to be provided; and the method of payment; and other provisions that the parties agree to.  Unfortunately, the current construction of AFAs does not meet the statutory requirements under section 108(f) of the Act.  Construction contracts require extensive scopes of work that detail the duties and responsibilities of the construction contractor, and it is a vital part of a construction contract, or can be prepared as an individual document to let the contractor know what he needs to do for the customer. This is included in a construction contract as a Contract Scope of Work (SOW) is a formal agreement document that specifies all the criteria of a contract between a service provider (vendor) and the customer. It clearly documents the project requirements, milestones, deliverables, end products, documents and reports that are expected to be provided by the vendor.

Who Should Attend?

This course is intended for all tribal program administrators, program managers, tribal grants and contracts staff, tribal chief financial officers, tribal finance and accounting staff.  It is highly recommended that federal line officers and awarding officials are required to attend this course.

What Will I Learn?

Attendees will learn the statutory requirements under the Act and what AFAs should contain.  Attendees will learn the fundamentals of developing construction contract scopes of work.

  • Tribes and tribal organizations often do not assume the full operation of all PFSAs under their contracts and compacts, thus it is important to differentiate what PFSAs is the subject of the contract/compact; and what remains as Residual Functions
  • Federal agencies often incorporate provisions that do not specifically apply to tribes under the Act, such as the Federal Acquisition Regulations (FAR), but tribes and tribal organizations are not aware that they are not liable for complying with unpublished regulations and unknowingly sign the AFAs
  • Learn how to identify all funding sources under the Secretarial Funding Levels, including Direct Costs, associated Administrative Costs (referred to as Tribal Shares); and Contract Support Costs, to capture the full suite of funding sources made available to the federal agencies
  • Developing the Program of Requirements (POR) and resulting engineer’s cost estimates under-construction projects are often a point of contention between funding agencies and tribes and may result in a contract declination
  • Learn the basics or fundamentals of preparing construction contract scopes of work; and required budgets
  • The scope of work functions much the same as a business services contract.
  • Obtain general writing guidelines for writing guidelines for developing contract scopes of work
  • Learn the SOW Format; and how to divide the SOW into distinct sections, including a glossary and project benchmark measurements.

$850  Contract Law & Administration (3 Days)

Contract law is not exactly a science or an art, but it is a little of each.  As a science, contract law is governed by certain principles and rules.  As an art, contract law often requires creativity as courts apply the rules and interpret the language of contracts.  Contract law is not just a bunch of rules and regulations that govern agreements between parties. It is not developed and imposed from above by some rule-making authority. It developed naturally over the course of years through interactions and transactions between parties - parties who form contracts.

Indian tribes operate federally funded contracts and grants which they, in turn, often outsource to private contractors and vendors. In this regard, tribes and tribal organizations must incorporate contractual principles into their sub-awards with private contractors. Under some federal awards, like awards made under Pub. L. 93-638, Indian Self-Determination Education & Assistance Act (Act), federal procurement laws and regulations are waived, and thus do not apply to these awards, be it non-construction or construction contracts.  While federal discretionary grants do not directly impose federal procurement rules on tribal grantees, federal Office of Management & Budget rules requires that tribes incorporate their procurement management policies and procedures to ensures there is adequate competition, accountability for funds in their sub-awards and pass-through entities. An important element in tribal contracting and subcontracting is a tribal sovereignty and sovereignty immunity protection from suit; and how tribes should adopt the appropriate contractual language, develop protocols to ensure tribal sovereignty is protected.

This course focuses on commercial contracts and teaches the essential elements of commercial contracts to provide guidance for tribes as they outsource their federal awards, or enter into commercial contracts with subcontractors using their own funds, with emphasis on protecting tribal sovereignty. The course highlights the differences between commercial (or procurement) contracts and non-procurement federal awards, with a special emphasis on non-procurement awards under Pub. L. 93-638 (self-determination contracts, self-governance compacts, self-determination construction contracts).  We recommend attendees also attend the course on “Contract Scopes of Work & Annual Funding Agreements”; and “Contract Disputes, Appeals & Federal Tort Claims Act”.

Who Should Attend?

This course is recommended for tribal administrators & chief executive directors, contracts and grants staff, tribal finance and accounting staff, tribal program directors & managers, tribal consultants.  Federal grant management specialists, federal line officers and awarding officials (and their subordinates), federal program specialists who often serve as AOTRs on Pub. L. 93-638 awards.

What Will I Learn?

  • Contract law and formation essential elements of contract formation (offer, acceptance, consideration)
  • Tracing contract law roots and foundation
  • Understanding contract formation
  • Exploring common contract law – tradition and precedent
  • Shaping tribal contract laws, ordinances, codes & standards
  • Determining whether a contract is void, voidable, or unenforceable
  • Analyzing contract terms and their meaning
  • Performing the contract and determining whether is a breach, and exploring remedies for breach
  • Tips and insights when analyzing a contract problem
  • Use of Uniform Commercial Code vs. tribal adopted codes and standards
  • Court jurisdiction (tribal jurisdiction, federal jurisdiction, tribal jurisdiction, state jurisdiction)
  • Contract disputes, mediation, third party mediation processes
  • Tribal procurement management policies and protocols

$750  Contract Appeals, Disputes & under Pub. L. 93-638 (2 Days)

Pub. L. 93-638, Indian Self-Determination & Education Assistance Act provides that tribal nations and tribal organizations operating programs under the Act may file an appeal of pre-award decisions rendered by federal line officers, such as a decision to decline a Pub. L. 93-638 contract application, or a self-governance compact proposal.  Tribes may also file an informal, or a formal appeal of the pre-award decision, or take direct legal action in federal district courts opposing the pre-award decision.  Tribes also have a right to file a contract dispute challenging the decision of the federal awarding officials under the Contract Disputes Act (CDA) or the Alternative Dispute Resolution Act (ADR).  Contracts under Pub. L. 93-638 also provide for third-party mediation and ways of informal resolution of disputes arising out of decisions rendered by federal officials

This course provides an overview of Pub. L. 93-638, Indian Self-Determination Act to establish a foundation on the rights of tribal nations and tribal organizations under the Act; and focuses on the specific decisions and actions of the federal agencies that may give rise to an appeal or a contract dispute.  The course identifies the contract appeals process, and contract disputes process; and identifies appealable and disputable actions.  The implementing regulations at 25 CFR Subpart L – Appeals; and Subpart N – Contract Disputes, provides guidance on decisions that may be appealed; and guidance on how tribes may file disputes under the Contract Disputes Act (or Alternative Dispute Resolution Act).

Who Should Attend?

Federal awarding officials, AOTRs & SAOTRs, federal line officers; tribal councils, tribal executive directors and administrators; tribal contracts and grants staff, tribal finance and accounting staff; tribal attorneys; tribal consultants.

What Will I Learn?

  • Congressional intent of Pub. L. 93-638, Indian Self-Determination & Education Assistance Act
  • Appealable decisions (declination to award contracts, declination to amend contracts, declination to permit program redesign, declination to award construction contracts, refusal to grant requests to waive regulations, disagreements over reporting requirements)
  • 25 CFR Subpart L – Appeals (appealable decisions; and appeals process)
  • 25 CFR Subpart N - Contract Disputes (disputable decisions; and disputes process)
  • Review of implementing regulations pertaining to appeals and disputes (Subpart A-General Provisions; Subpart D – Review & Approval of Contract Proposals; Subpart E – Declination Procedures; Subpart G – Programmatic Reports & Data Requirements; Subpart K – Waiver Procedures; Subpart L – Appeals; Subpart N – Post Award Decisions; Subpart P – Retrocession & Reassumption)
  • Contract Disputes Act of 1978 (CDA)
    • What is a Claim?
    • How is a Claim Filed?
    • What is the Equal Access to Justice Act (EAJA)?
  • Alternative Dispute Resolution Act (ADR)
  • Third-Party Mediation process
  • Federal Tort Claims Act Coverage under Pub. L. 93-638

$850  Accounting Basics for Tribes (3 Days)

Indian tribes and tribal organizations often have difficulty complying with the Single Audit Act and have difficulty completing their annual audits within the required deadlines.  Consequently, many tribes and tribal organizations are designated by federal awarding agencies as “high risk” tribes.  Sanctions are imposed on the tribes which subsequently affect their chances of receiving future federal grants and contracts.  The most common cause of these problems is the lack of fully trained and qualified finance and accounting staff.  Lack of proper training impacts the tribes’ annual audit report.  Because of the lack of training, some transactions are incorrectly recorded, requiring account reconciliations and adjusting entries. Without reconciled accounts, the resulting income statements and trial balances will not be correct.

The course focuses on fund categories, such as: when to use different fund types, the basis of accounting, when to capitalize a purchase, how to record a capital asset in both the fund account and government-wide reporting, power of financial reporting, the purpose of budgeting and basic understanding the budgeting process.  The course provides a basic overview of managing federal grant awards, with a focus on the financial reporting aspects of grants management.  It provides highlights of the differences between the two basic types of federal-funded programs that tribes operate: (1) Discretionary Grant Programs & (2) Entitlement Programs.

Who Should Attend?

Tribal finance and accounting staff, tribal program managers and project accountants, tribal boards of directors, tribal council members, tribal administrative personnel.

What Will I Learn?

This course provides instruction on accounting fundamentals and protocols to arm the attendees with a basic understanding of accounting, including but not limited to:

  • Governmental Accounting (how it applies to tribes and tribal organizations)
  • Purpose and Role of the Financial Accounting Foundation (FAF), Government, Government Accounting Standards Board (GASB), Financial Accounting Standards Board (FASB)
  • Basic Accounting Concepts (“The Accounting Equation”)
  • Double Entry Accounting (debits & credits, T-accounts, normal balances, activity, journals, ledgers, how transactions are processed)
  • Accounting Records (journals, ledgers, processing transactions)
  • Accounting Transactions (accounts receivables, accounts payables, general ledger, payroll, activities)
  • Fund Accounting (purpose, fund categories, inter-fund loans, inter-fund transfers, activities)
  • Basis of Accounting (cash, accrual, modified accrual, measurement focus)
  • Budgeting (objectives, approaches, process, budgetary controls)
  • Capital Assets (examples, activities)
  • Tribal Accounting Specifics (federal grants & contracts, i.e. Pub. L. 93-638 & discretionary grants, federal financial reporting, i.e. SF-425s)
  • Tribal Accounting (budgeting, governmental operations, revenues & expenses, grants & contracts management, program revenues)
  • Becoming Audit Ready (accounting transactions, monthly reconciliations, grants management, indirect costs, narrative reports, fixed assets, trial balance, internal controls, council minutes, investments, loans, etc.)

$850  Single Audit Act: Preparation & Follow Up (3 Days)

The Single Audit Act of 1984 (Pub. L. 98-502; and as amended by the Single Audit Act Amendments of 1996) provides that tribes and tribal organizations that expend at least $750,000 annually in federal funds (new threshold under the Super Circular), must conduct single audits, or program-specific audits, at least 9 months after the end of their fiscal year.  The new OMB Super Circular, at Subpart F, replaced the previous OMB Circular A-133, to provide for consistency and uniformity among federal agencies. Each year the OMB updates a special audit compliance supplement that requires the tribes and their auditors to pay special attention to certain critical aspects of federal programs.

Indian tribes & tribal organizations are required to conduct annual audits as a requirement for receiving federal assistance.  Many tribes, however, experience problems in completing their audits causing contract and grant compliance issues.  Some tribes are designated as “High Risk” because they are unable to complete their annual audits.  Because they are unable to complete their annual audits, they are often not able to negotiate enter into Indirect Cost Rate Agreements and may have difficulty securing future federal grants. Audit deficiencies and resulting sanctions will impact a tribe’s ability to compete for and receive federal grants.

This course provides detailed instruction of the Single Audit Act, federal audit requirements, how to prepare for annual audits; and how to avoid disallowed costs.  Learn what the auditors look for, what federal agencies look for in reviewing your audits; and how to draft & reconcile Statement of Expenditures for Federal Awards (SEFA). It will help you to understand the importance of how performing the basic and routine accounting functions can help avoid disastrous audits.

Who Should Attend?

Tribal council members, chartered organizations school boards, health boards, tribal, program directors and managers; tribal grants/contracts staff, finance and accounting staff; tribal attorneys, tribal planners, grant writers, tribal consultants.  Federal officials and federal awarding officials, federal contracting officers and their subordinates should also attend.

What Will I Learn?

  • A review of the Single Audit Act
  • A Review of the new OMB Super Circular, Subpart F – Audit Requirements
  • Review of Indian Self-Determination Act financial reporting requirements
  • The Financial Statement Audit – What is it?
  • How to Prepare for Audits (Preparing Schedules)
  • What government agencies look for (cash surplus/deficit, grant receivables, “Due To – Due From”, accounts, deferred revenues, balance sheet reconciliation; closing entries)
  • What auditors look for (Statement of Expenditures for Federal Awards (SEFA) Schedule, audit report findings, significant deficiencies, material weaknesses)
  • What is a reportable condition?
  • Common types of findings – How to avoid them (lack of reporting, lack of documentation, questioned costs, segregation of duties)
  • Resolving disallowed costs
  • Federal sanctions for non-compliance
  • How non-compliance affects your organization for future federal awards
  • Collection of disallowed costs under Indian Self-Determination Act and OMB Super Circular
  • Tribal/federal roles and responsibilities

$750  Indirect Cost Principles: Contract Support Costs (2 Days)

Tribal organizations incur administrative overhead costs as part of providing essential governmental services, including operating federal programs.  Pub. L. 93-638, the Indian Self-Determination & Education Assistance Act, provides a unique mandate that requires agencies within the Department of Interior and Department of Health & Human Services that have agreements with tribes and tribal organizations under Pub. L. 93-638, to provide for full funding for tribal overhead costs, called Contract Support Costs.  Tribes also operate discretionary grant programs awarded by other federal agencies. These grant awards also require that tribes must have current negotiated indirect cost rates to be applied to these grants.

Tribes and tribal organizations must have a good understanding of how indirect cost rates work as they are responsible for preparing indirect cost rate agreements.  They need to know what constitutes an indirect cost pool, a direct cost pool; and types of indirect cost rates.  Tribes need to learn about the different funding sub-pools under Contract Support Costs (Direct Contract Support Costs, Start-Up Costs, Pre-Award Costs); and how to calculate Direct Contract Support Cost each funding year.

A recent U. S. Supreme Court decision in Salazar vs. Ramah Navajo Chapter required that the Bureau of Indian Affairs and Indian Health Service must abide by the statutory requirements under Pub .L. 93-638 to provide full funding.  Both agencies recently revised their Contract Support Costs policies to cover rules on paying tribal overhead costs for awards under the Indian Self-Determination Act.

Who Should Attend?

Tribal council members, chartered organizations school boards, health boards, tribal, program directors and managers; tribal grants/contracts staff, finance and accounting staff; tribal attorneys, tribal consultants.  Federal officials and federal awarding officials, federal contracting officers and their subordinates should also attend.

What Will I Learn?

  • Funding provisions in the Indian Self-Determination Act regarding Direct Costs and Contract Support Costs (Direct Contract Support Costs, Pre-Award Costs, Start-Up Costs)
  • Principles of indirect costs and indirect cost rates
  • How indirect cost rates work
  • Types of indirect cost rates, including fixed with-carry forward, final rates and provisional rates
  • What happens when funding agencies do not pay indirect costs
  • What happens when tribal councils waive indirect cost rates
  • Differences between the Indian Self-Determination Act contracts and discretionary grants
  • Special Presentation: Current status of the Salazar v. Ramah Navajo settlement and distribution; and what is ahead in the future
  • Special Presentation: Detailed instruction on the new BIA & IHS Contract Support Cost Policies; and How to calculate Direct Contract Support Costs to add new funds to Self-Determination awards.


$750  Preparing Indirect Cost Rate Proposals (2 Days)

Administrative Costs, Overhead Costs, or Indirect Costs is a cost of doing business. It is cost tribes and tribal organizations incur in operating the tribe and when operating programs. To cover their indirect costs, tribes must develop and negotiate the Indirect Cost Rate Agreement with the federal government to be applied to their federal and non-federal awards. Tribes that are unable to complete their annual financial audits are not able to negotiate indirect cost rate agreements. Some tribes have old indirect cost rate agreements that do not accurately reflect true tribal overhead costs.  Many federal agencies, by regulation, cannot provide funding for outdated Indirect Cost Rate Agreements.  It is important that tribes and tribal organizations learn how to prepare their own Indirect Cost Rate Proposals instead of relying on outside accountants.  The Office of Management & Budget issued new rules, commonly referred to as the “Super Circular” affecting tribal indirect cost rates.  The Bureau of Indian Affairs and Indian Health Service also issued their Contract Support Cost Policies addressing Contract Support Costs (Indirect Costs) and how they can comply with full payment provisions in the Indian Self-Determination Act.  Many tribes are not aware of Contract Support Cost policies so they are not able to take full advantage of additional funding for their programs such as Direct Contract Support Costs.

Who Should Attend?

Tribal administrators, tribal chief finance officers, tribal finance and accounting staff, program directors and managers.  The course is highly recommended for federal awarding officials, and program managers.

What Will I Learn?

KIVA developed a hands-on course to cover techniques of preparing tribal cost allocation plans, reviewing tribal indirect cost pools, assessing tribal organizational structures; and addressing other issues that will have financial impacts to the tribes, prior to preparing an Indirect Cost Rate Proposal.  Tribes should be able to structure the best indirect cost strategy that will maximize the recovery of overhead costs:

  • Overview of How Indirect Cost Rates Work
    • What is a Direct Cost Pool (Base); What is an Indirect Cost Pool
    • What is an Indirect Cost Rate; Types of Indirect Cost Rates
    • Special Indirect Cost Rate Options
  • How to Tie Indirect Cost Rates to Audits
  • Rules for Preparing Indirect Cost Rate Proposals:
    • Details of What Is Included In a Proposal
    • Frequently Missing Information
    • Preparing Indirect Cost Rate Policy
    • Preparing the Schedule of Expenditures for Financial Awards (SEFA)
  • Practical Issues:
    • Tying to the Audit; Supplementary Audit Schedules; How to Book Indirect Expenses
    • What Happens When Tribes Do Not Receive Full Indirect Cost Funding
    • What Really Happens During IDC Rate Negotiations
  • Contract Support Cost Policies of BIA and IHS
  • Brief Overview of OMB Super Circular
  • Tribal Indirect Cost Rate Case Study: Preparing Your IDC Rate Proposal; a “hands on” exercise.

$750  Financial Management Systems and Reporting Requirements (GASB) (2 Days)

The Indian Self-Determination Act (Act) requires that tribes and tribal organizations maintain financial records to document how funds are used in the agreements under the Act; and that such records are maintained in a manner that will facilitate annual audits.  Indian Self-Determination Act regulations at 25 CFR Subpart F – Standards for Tribal or Tribal Organization Management Systems, prescribes minimum standards for tribal financial management systems, including financial reporting, accounting records, internal controls, budget controls, allowable costs, source documentation, and cash management. Financial reporting requirements include submitting quarterly and annual financial reports on the OMB Federal Financial Report SF-425.

The General Accounting Standards Board (GASB) was created in 1984 to establish generally accepted accounting principles (GAAP) for state and local government entities.  Its standards guide the preparation of external financial reports of those entities.  In June 1999, GASB made changes, through GASB Statement 34, in how tribes will now submit financial reports.  GASB 34 now requires an accrual-basis accounting versus the former cash-basis accounting; and report on the value of their infrastructure assets, which most tribes have not adopted.  In the Fiscal Year 2010, OMB combined the Financial Status Reports (SF-269 and SF-269A) and the Federal Cash Transactions Report (SF-272) into one form, Standard Form 425 (SF-425).

The above financial reporting requirements affect all tribes and tribal organizations that operate federal programs under the Act and their discretionary grants.  There are distinct differences in the treatment of costs under the Self-Determination contracts and discretionary grants that impose challenges for tribes on how they prepare and submit their financial reports. This course will provide tribal and federal officials an understanding of the financial reporting requirements; and what information is reported on the SF-425’s.

Who Should Attend?

All federal awarding officials, awarding officials’ technical representatives (AOTRs), subordinate awarding officials’ technical representatives (SAOTRs); tribal chief finance officers, tribal finance staff, tribal contract/grant officers, tribal administrators, tribal program directors and managers, auditors, tribal consultants.

What Will I Learn?

  • Basics of governmental accounting and how accounting practices affect federal awards
  • Impacts of GASB requirements on tribes and tribal organizations.
  • How to properly complete SF-425s’s
  • Reporting contract and grant expenditures, reporting contract savings for carryover; reporting program income
  • Requirements for tribal financial management systems
  • Federal audit and audit follow up requirements

$850  Accounting Principles QuickBooks™ for Tribal Programs & Organizations (3 Days)

QuickBooks™ is an accounting software package that can be customized to meet the needs of tribal programs and departments, tribal organizations, non-profit organizations, and entrepreneurs.  QuickBooks™ Desktop can be used for internal accounting applications to manage program income, budgets, expenses, accounts receivables, accounts payables, and more.  QuickBooks™ utilizes intuitive modules that make the accounting process easy to understand and navigate.

This course is a hands-on course that provides a working knowledge and understanding of basic accounting principles to help managers, entrepreneurs and their assistants to properly account for federal funds (contracts and grants), tribal funds, and company finances.  The course starts with a review of basic accounting principles to ensure sound accounting principles are applied properly in QuickBooks™.  Participants will learn how to organize the accounting system for the program, customize the chart of accounts, properly post income, revenues, expenses, and obligations.  Participants will learn how to reconcile the accounts with bank statements. Vendor files can be set up to provide for use of credit cards and travel advances. Participants will learn how to generate customized financial reports and prepare for audits.

Who Should Attend?

Tribal program directors and managers; accounting staff; non-profit organizations, tribal boards of directors, and entrepreneurs. To get the most out of this session, bring your laptops, a copy of your program budget, tribal/program chart of accounts. KIVA provides post-training consultation and technical assistance.

What Will I Learn?

  • Accounting Principles (Generally Accepted Accounting Principles)
  • Government Fund Accountability Standards
  • Effects of Business Transactions on the Accounting Equation
  • Who, What, When, Where and Why: Making sense of the Accounting Process
  • Understanding Financial Reports
  • Making QuickBooks™ Meet Your Needs (Setting Up Chart of Accounts, Using “Classes” for Fund Identification, Customizing Preferences, Forms, Customers, Vendors, Inventories, Understanding Expenses v. Cost of Goods Sold, Understanding Depreciation & Pre-Paid Expenses)
  • Routine Tasks (Accounts Receivables: Preparing and Processing Invoices, Sales Receipts, Customer Statements, Accounts Payables: Entering and Processing Checks, Bills and Payments, Vehicle Expense Monitoring, Trial Balance, Financial Reports)
  • Unique Situations (Customizing QuickBooks™, Using Credit Cards for Expenses, Travel Advances, Receiving Credit Card Payments, Reconciling the System with Bank Statements and Online, Closing the Books, Preparing for Audit, an Overview of QuickBooks™)
  • Overview of The Payroll / Employee Module
  • Getting the Right QuickBooks™ Edition

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