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Topics Include:

Contract Support Costs

  • IHS CSC Policy
  • BIA CSC Policy
  • How tribes are adjusting to the new CSC policies:
    • Implementation issues
    • Current disputes and summaries of litigation in play
  • Agency's budgeting to meet the full funding of CSC
    • 2018/2019 Appropriations
  • Annual Contract Support Costs Calculations (ACC) form:
    • Agency use of Indirect Cost Proposals to determine CSC need
    • Purchased/Referred Care Costs vs. on-site contract providers - member assistance or contract?

New and Updated Topics/Issues

  • Legal update:
    • Cook Inlet Tribal Council, Inc. v. Mandregan et al
    • IHS drops appeal of Sage Memorial ruling
    • New round of payments in Ramah class action
    • Seminole Tribe of Florida v. Azar, et al
    • Norton Sound Health Corporation v. Azar, et al
    • Swinomish Indian Tribal Community v. Azar, et al
  • IHS revokes 97/3 method for determining duplication under CSC policy
  • Section 105(l) Leasing: Recovering Facilities Costs:
    • Maniilaq Association v. Burwell
    • The leasing process
  • Contract Disputes Act:
    • How to assert and preserve claims for underpayment
      of CSC or other funds

OMB Revisions

  • Avoiding the refund and retroactive rate adjustment provisions
  • Managing the new Modified Total Direct Cost (MTDC) Base definitions
  • Requirements for establishing an indirect rate for pass through funds
  • How to obtain approval of time reporting internal control framework
  • Allowability of council costs
  • How to submit an indirect cost rate proposal every four years with sequential four-year indirect cost rate extensions
  • Choosing the rate needed for extensions
  • Determining "consistent costs"

Negotiations/Interior Business Center

  • Minimizing the impact when adding tribal funds to programs
  • Latest position on IBC regarding certain pool costs
  • Costs of tribal government

Rate and Exclusions Scenarios

  • Analyzing the impact of different scenarios:
    • When your main funder is IHS
    • When your main funder is BIA
    • The interaction of different rates/exclusions
  • Presenting to tribal council

NEW TOPIC! Your Rights as an ISDEAA Contractor during a Government Shutdown

  • Previously approved contract support costs
  • Current year’s support costs
  • Reimbursement for expenses incurred during government shutdown
  • Documenting expenses and unfunded overhead during a shutdown
  • Indian Programs Advanced Appropriations Act

One-on-One Consultations Available

Topics and presenters subject to change.






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