“In response to IHS’ request for input on the factors it should consider in developing a methodology for allocating the funds authorized in ARPA, the Tribal SelfGovernance Advisory Committee (TSGAC) offers recommendations like those we provided during prior coronavirus relief consultations, including:
• Funding allocations should use existing methodologies that rely upon well-known and understood factors, such as user population. Developing a new methodology could delay the transfer of funds and increase the burden on Tribal recipients to provide or verify new data points.
• Transfer funds through existing compacts, contracts, and funding agreements. Contract and Compact amendments should be streamlined and not impose any additional restrictions or requirements other than those included in the Act. The U.S. Government Accountability Office (GAO) recently reported that the ability for IHS to transfer Coronavirus Relief Funds through existing Self-Determination contracts and Self-Governance compacts allowed the agency to quickly disburse the funds. “
