Dear USET/USET SPF Family,
On March 29, 2024, Treasury published an updated Frequently Asked Questions (FAQ) document for the Coronavirus State and Local Fiscal Recovery Fund (SLFRF). This updated FAQ provides greater flexibility for Tribal Nations in obligation of their $20 billion Tribal set aside under the SLFRF. In November 2023, Treasury held a Tribal consultation on the SLFRF to further clarify the Interim Final Rule (otherwise known as the 2023 “obligation” IFR), and through further engagement with Tribal Leaders and staff, Treasury learned that there was confusion on what constituted an obligation under the Uniform Guidance and whether Tribal Nations could obligate funds to Tribal entities.
In response to these concerns, as well as Treasury seeking certainty and maximum flexibility for Tribal Nations as directed by Executive Order 14112, the updated FAQ provides Tribal Nations with greater decision-making opportunities to obligate SLFRF dollars. Of particular note, the FAQ includes deference to Tribal Nations in determining their units of government, which also include Tribal enterprises and Section 17 and Section 3 entities.
Treasury will also be hosting a webinar for Tribal governments on the updated FAQ. Details regarding this upcoming webinar are as follows—
USET SPF applauds Treasury’s decision to include maximum flexibility and deference to Tribal Nations in obligation of SLFRF dollars in the updated FAQ. We have consistently advocated for the federal government to recognize the sovereign authority of Tribal Nations to manage our own affairs, especially in the use of federal funds to support our communities. In July 2021, USET SPF submitted comments
specifically calling upon Treasury to streamline reporting requirements, have maximum deference to Tribal Nations, and empower Tribal Nations use SLFRF dollars to support our own economic development initiatives.
Further clarifications on the “obligation” of SLFRF dollars can be found under the newly added Section 17 of the updated FAQ. Additional updates to the FAQ has also been summarized in a new Tribal Fact Sheet published by Treasury.
For more information, please contact Brian Howard, USET SPF Senior Policy Analyst, at bhoward@usetinc.org.
|