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Demystifying Contract Support Costs: A Comprehensive Guide

This comprehensive guide dives into understanding and calculating Contract Support Costs (CSC), providing insights into the history, policies, updates, and annual processes related to CSC. Learn about the DOI CSC Workgroup, CSC Policy implementation, and considerations for managing these costs effectively. Stay informed about the latest policies, examples, and forms to ensure your tribe meets 100% of its CSC needs, with valuable insights from Kasie Nichols, the Director of Self-Governance at Citizen Potawatomi Nation. Contact Kasie Nichols for further assistance.

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Demystifying Contract Support Costs: A Comprehensive Guide

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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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