Dear Tribal Council,
This is just a reminder that the Tribe needs to meet the same financial requirements each year that Bristol Bay Housing Authority (BBHA) does in order for BBHA to flow thru money to the tribe as a Sub-recipient under an MOA (Memorandum of Agreement):
The Tribe must provide documentation of Theft/Embezzlement coverage on an annual basis for employees and council members.
The Tribe must provide either a current audit with no exceptions or findings on an annual basis OR, annually, a Certification of Financial Management by a Certified Public Accountant (CPA).
Funds are no longer be advanced but will be on a reimbursement basis with documentation of expenditures. For materials and supplies and services, this includes documentation to secure at least 3 bids. NAHASDA does not allow Sole Source Contracting with only one vendor or contracting with a single vendor without first following bidding rules.Only HUD Alaska Office of Native American Programs (ONAP) has the ability to allow a Sole Source procurement.This was also a weakness identified in the Monitoring of the villages.
Although it is on a reimbursement basis, the NAHASDA requirement for an Environmental Review must still be done before any expenditure of funds. BBHA takes care of the environmental review for the Utility Voucher and Crime Prevention programs at the beginning of the year. However, this is a hang-up during the Pandemic for Modernization Programs. BBHA must have an accurate legal description of the lot on which a home is built for each Mod project home. BBHA must also continue to review NAHASDA applications to ensure that persons having NAHASDA funds spent on them are eligible recipients under the Act.
Tribes need to plan to expend funds so that no more than 2 years of NAHASDA Funding are on hand. If a tribe had plans for a larger project, BBHA can provide technical assistance for a tribe to secure a Title VI Loan from HUD so they can get their project done sooner and pay it off with their future allocations as Congress appropriates them.
For tribes that have their MOA in place with BBHA they need to make sure of the following in operating a Tribal Utility Voucher Program:
The tribal council has a copy of their action such as minutes or a resolution that sets the limit on a Utility Voucher amount.
The tribe has a W-9 form from the electric or fuel vendor on file so it can send to the IRS how much money was given to the vendor annually.
The tribe gets a copy of the billing statement for each vendor (electric and fuel) in the tribal member’s name that is NAHASDA eligible. The billing statement needs to show the dollar amount that is owed to the vendor.
If the tribal member has a credit on their account, the credit will need to be spent before the tribal member can receive the Voucher from the Tribe.
Each NAHASDA applicant is eligible for one year after BBHA has issued a letter of NAHASDA eligibility.
For tribes that have their MOA in place with BBHA, they need to make sure of the following in operation of their Crime Prevention and Safety Program (based on HUD on-site monitoring in 2019):
NAHASDA eligibility of the participating families is documented by BBHA and on file at the tribe (letter of NAHASDA eligibility);
When the tribe allows families, who are not NAHASDA eligible to participate in group activities, the Tribe can document that it has another source of money in the project to cover those families to participate.
An MOA Tribe needs to meet its requirements of turning in a Quarterly Report to BBHA as follows:
First Quarterly Report is due on April 15th;
Second Quarterly Report is due on July 15th;
Third Quarterly Report is due on October 15th;
Fourth Quarterly Report is due on January 15th.
Jennifer Creasey is the new Tribal Development Director working under Kevin Tennyson. Their emails are email@example.com and firstname.lastname@example.org. Amanda Trangmoe is BBHA’s Chief Financial Officer, and her email is email@example.com if you have a copy of an audit to submit or a CPA’s certification of your financial management system.