Calculating, Understanding & Demystifying Contract Support Costs

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Presentation transcript:

Calculating, Understanding & Demystifying Contract Support Costs Kasie Nichols Office of Self-Governance Citizen Potawatomi Nation

Outline DOI CSC Workgroup CSC Policy in Action History Update Annual CSC Process Considerations

DOI CSC Workgroup - History 2003 –established as part of initial Ramah settlement, which called for a CSC Policy to address DCSC 2006 National Policy Memorandum Shortfall funding environment 3 pools of funding for CSC (ISD, Prior Year, Increases/Shortfall) 2012-Ramah Class Action upheld by Supreme Court - tribes provided with compensation for past CSC shortfalls FY2014 Consolidated Appropriations Act …IHS/BIA…formulate long- term accounting and budget strategies to produce solutions on determining CSC amounts going forward. Full funding environment! 2014-2016 DOI WG policy revisions with tribal consultation

DOI CSC Workgroup - Update New CSC Policy 2017: Intra-Agency Manual Part 13 Chapter 7 Relatively simple “Meet 100% of Tribe’s CSC need” Explains how BIA calculates and pays CSC 4 CSC Types: Pre-Award, Start-up, Direct & Indirect Increased DCSC Rate (15-18%) Indirect CSC Options for Tribes without current IDC rates 4 years or less, Negotiated Lump Sum or Simplified Methods CSC Adjustments Over- & Under- and Other adjustments to payments CSC Annual Report to Congress

DOI CSC Workgroup - Update CSC Workgroup Meeting Spring 2019 Topics New policy implementation issues Finalize Handbook Definitions Instructions/processes Examples Forms Flowcharts

CSC Policy in Action Annual CSC Process Tribal Example Tribe Citizen Potawatomi Nation CSC Type Direct, Indirect IDC Rate Negotiation DOI-Interior Business Center IDC Rate Type Fixed Carryforward Direct Cost Base Total Direct Costs (less capital /pass-through) CPN Contact Self-Governance / Accounting (IDC) BIA Contact OSG Awarding Official, Northwest Field Office Goal: Meet 100% of Tribe’s CSC need!

CSC Policy in Action Annual CSC Process May DTTL CSC Data Request August Submit CSC Data-address full need! Sept/Oct Reconcile final CSC payment Oct Submit IDC proposal January Negotiate IDC Rate BIA AFA (OIP, CSC) payments ongoing throughout year

CSC Policy in Action Considerations Knowledge Review Policy CSC Types (pre-award, start-up, direct, indirect) IDC Rate Negotiation (e.g., Interior Bus. Center or lump-sum) Annual CSC Payment Process (fund 100% CSC!) OIP direct cost base Exclusions/Pass-through? DCSC Base (Budgeted Salaries) IDC Rate Update CSC Workgroup technical assistance Communication Internal / External Timelines- IDC Rate & CSC Reconciliation

Director, Self-Governance Citizen Potawatomi Nation Kasie Nichols Director, Self-Governance Citizen Potawatomi Nation Tribal Representative- Southern Plains Region, CSC Workgroup kasie.nichols@potawatomi.org / 405.275.3121