IHS - CSC Update Self-Governance Meeting April 24, 2018

Topics CSC Fund Status CSC Need Methodology IHS CSC Policy Updates Tribal Consultation IHS Improvements Training

IHS CSC Fund Status

CSC Need Methodology

FY – 2016 IHS CSC Policy Changes/Updates Startup and Pre-Award are paid on a one-time basis - Awardee will certify that all startup funds were spent with 12 months of the program assumption. Medical Inflation Rate. Indirect CSC - Review the tribe’s total health care expenditures in the prior year to determine whether the tribe expended at least the amount of the Secretarial amount plus direct CSC funding (or salaries/salaries plus fringe) to be awarded.  90 day closeout after contract term available at option of the Tribe Incorporates alternate methods for calculating IDC associated with recurring service unit shares - Awardee’s option to elect a simplified method and use 97/3 “split”, 3% of the service unit funding will be considered IDC. Outlines closeout procedures for 2016 moving forward; once final agreement is reached the parties shall enter into a bilateral amendment/modification setting forth the agreed upon amounts.

Alternate methods for calculating IDC associated with recurring service unit shares - simplified method and use 97/3 “split”, 3% of the service unit funding will be considered IDC. On December 21, 2017, the IHS notified Tribes that it was necessary to temporarily suspend the IHS CSC policy, specifically § 6-3.2E(3) – Alternative Methods for Calculating Indirect Costs Associated with Recurring Service Unit Shares of the CSC policy. The IHS become aware that this section may not conform in all cases with the statutory authority of the Indian Self-Determination and Education Assistance Act (ISDEAA) at 25 U.S.C. § 5325(a). The IHS committed to seek input from the CSC Workgroup and initiate Tribal Consultation prior to making a final decision on how to amend the CSC policy. The March 7, IHS CSC Workgroup made a recommendation to the IHS Acting Director.  In addition to the recommendation, IHS included additional options in the DTL letter dated April 13 for 30 days or through May 18. IHS will review comments with the CSC Workgroup prior to issuing a final decision. IHS remains committed to our Tribal Consultation process and we look forward to a workable solution.  

IHS Business Process Improvements Committed to a simplified and streamlined business process Refer to the “Guiding Principles” established in the IHS CSC Policy Strive for consistency in ISDEAA negotiations Improve regular communication with internal communication to IHS negotiators Implement ISDEAA teams improvements

CSC Training Modules Overview of CSC Definitions of CSC Direct CSC Indirect CSC New Policy Changes https://www.ihs.gov/odsct/contract-support-costs/

IHS CSC Policy The new policy is Part 6, Chapter 3 of Indian Health Manual. https://www.ihs.gov/IHM/index.cfm?module=dsp_ihm_pc_p6c3# 6-3.2E A new CSC template was agreed to as part of the policy discussions with the WG and is included as Exhibit 6-3-F.

Roselyn Tso, Director, ODSCT. Roselyn. Tso@IHS. gov. 971-506-1928 Questions?