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Calculating, Understanding & Demystifying Contract Support Costs

Calculating, Understanding & Demystifying Contract Support Costs. Kasie Nichols Office of Self-Governance Citizen Potawatomi Nation. Outline. DOI CSC Workgroup History Update CSC Policy in Action Annual CSC Process Considerations. DOI CSC Workgroup - History .

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Calculating, Understanding & Demystifying Contract Support Costs

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

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

  3. 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

  4. 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

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

  6. CSC Policy in ActionAnnual CSC Process Tribal Example Goal: Meet 100% of Tribe’s CSC need!

  7. CSC Policy in ActionAnnual CSC Process BIA AFA (OIP, CSC) payments ongoing throughout year

  8. CSC Policy in ActionConsiderations • 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

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

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