OMB Super Circular 6/9 – 6/11/2020
Why I Should Attend?
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.
The Office of Management & Budget (OMB) issued new regulations to consolidate several OMB Circulars into one set of regulations (2 CFR Part 200) that many refer to as the “Super Circular”. The intent of the Super Circular is to prevent waste, fraud, and abuse; and as such, it focuses on risks associated with the tribal capacity to operate these programs. It captures rules governing audits, grant proposals, cost principles, conflicts of interest, and grant performance. The Super Circular applies to Indian tribes, tribal organizations, states and local governments, non-profit organizations, hospitals, universities, etc. The Single Audit Act (Subpart F) applies to all federal awardees that spend $750,000 or more in a fiscal year. Simiarly, Subpart E – Cost Principles now applies to Pub. L. 93-638 awards because former OMB Circular A-87 is now incorporated into the Super Circular as Subpart E.
KIVA provides a unique method of explaining the similarities and differences in OMB rules as they pertain to discretionary grant programs; and entitlement programs (Indian Self-Determination Act programs). For example, the course covers the differences in rules covering cost principles, program income, indirect costs, carry over of savings, grant match requirements, recurring funds, disallowed costs.
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.