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OMB Uniform Administrative Requirements

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 in many respects. This course will highlight the differences and 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 the new regulations 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 American Jobs Plan Act has not been enacted, funds under the new legislation will be governed by the OMB Uniform Administrative Requirements.

The OMB regulations govern annual audits, grant proposals and grant administration, cost principles, indirect costs, and annual single agency audits. The regulations apply to Indian tribes, tribal organizations, states and local governments, non-profit organizations, hospitals, universities, etc. This course will address the similarities and differences in OMB rules as they pertain to discretionary grant programs; and 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 You Will Learn.

  • Purpose of the OMB Super Circular
  • Comparison of discretionary grant programs vs. entitlement programs
    (Pub. L. 93-638)
  • 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)
  • KIVA Cost Principles Matrix
  • Audit Requirements (major program determinations,  high risk determinations, sanctions for non-compliance)
  • Special Focus on CARES Act and American Rescue Plan Act (ARPA) funding, compliance & reporting

Contact Us to Register:
KIVA Institute, LLC