Resource

Direct financial assistance program development and administration for tribes under the ARP

April 1, 2021 · Authored by Joel M. Laubenstein

Experience and efficiency with compliance in mind

Under the CARES Act, a number of tribes were quick to implement a financial assistance program in order to get much needed direct financial relief from their allocation of Coronavirus Relief Funds (CRF) into the hands of their members. Unfortunately, there was minimal guidance early on that would directly address these types of payments and the related compliance requirements. In a later version of FAQ’s, Treasury pointed out that a program of this sort must be administered under a set of eligibility criteria, specifically prohibiting the use of a “per cap” payment by a government. As what seemed to be the overall theme with CRF compliance rules, guidance continued to evolve and change over time at Treasury’s discretion.

With the signing of the American Rescue Plan (ARP) into law, it appears that tribal governments will once again have the opportunity to provide direct relief to tribal members who show a demonstrated need or financial hardship as a direct result of the COVID-19 pandemic. 

How Baker Tilly can help

Baker Tilly oversaw and administered various financial assistance and grant programs implemented by our clients under the CARES Act, including the largest direct financial assistance program in the nation.  Our approach brings industry best practices, tailored to results that matter to your tribe. Through collaboration with our clients, we can assist with:

Overall program design

• Developing applicant eligibility criteria
• Definition of roles/responsibilities – leveraging of available tribal permanent employees or determining and engaging with tribal temporary employees
• Development of program timelines
• Developing program communications
• Ensuring that all elements of the program design, implementation and administration conform to applicable federal, state or local compliance requirements

Application development and administration

• Development of customized online portal application system
• Development and distribution of paper applications
• Training of any program partners that are available to support the program, including tribal divisions, tribal enterprises or outside entities assisting with application administration