Frequently Asked Questions
Was CARES Act funding to Tribes based on each Tribe's total enrollment?
Tribes did not receive funding based on the enrollment of the Tribe. The United States Treasury utilized the Tribal population data used by the Department of Housing and Urban Development (HUD) in connection with their Indian Housing Block Grant (IHBG) program (Coronavirus Relief Fund Tribal Allocation Methodology). This population data is based on Census Bureau data (Census 2020).
The IHBG program allocation formula uses the American Indian and Alaska Native (AIAN) population count as determined by the Census of each Tribe’s ‘formula area’ (FY2020 IHBG Final Allocation Formula Areas). So what does this mean when comparing numbers?
Take the Qagan Tayagungin Tribe of Sand Point (QTT) for instance. The IHBG Tribal Population used to calculate CARES Act funding, is 302 American Indian or Alaska Native persons. In other words, IHBG recognizes there are 302 native people residing in the Tribe’s formula area, Sand Point. This data was gathered, evaluated, and presented to all IHBG participating Tribes to submit challenges last year (IHBG Formula).
QTT has 778 enrolled tribal citizens. The 302 persons served within the QTT formula area, used to calculate CARES Act funding for QTT, is only 38.8% of the total Tribal enrollment. The vast majority of the Qagan Tayagungin Tribal Citizens (61.2%) likely reside within another Tribe’s formula area, depending on where they were when they completed their last census.
It may seem confusing, why would the Treasury allocate funding based on Tribal Population using the Decennial Census total American Indian Alaska Native data used by the Department of Housing and Urban Development in its Indian Housing Block Grant. However, the Treasury determined the IHBG data is the most consistent and reliable metric on which to base the allocation of payments to Tribal Governments (Coronavirus Relief Fund FAQ). Tribal enrollment does not provide a consistent measure of tribal population across tribes as Tribal enrollment criteria are set forth in tribal constitutions, articles of incorporation, or ordinances vary from tribe to tribe (Dept of the Interior Tribal Enrollment).
Since the IHBG program allocation formula uses AIAN population count for each formula area as determined by the Census, it cannot be stressed enough how critical it is for everyone to complete their 2020 Census questionnaire. This can be found online at https://2020Census.gov.
I heard other Tribes are sending everyone a stimulus check, where's mine?
The Qagan Tayagungin Tribe is NOT issuing a stimulus check to Tribal Citizens.
CARES Act funds must be used for actions taken to respond to the public health emergency. This may include expenditures to respond directly to the emergency, such as by addressing medical or public health needs, as well as expenditures incurred to respond to second-order effects of the emergency (Coronavirus Relief Fund Guidance for Tribal Governments). The approach each Tribe takes with their public health response is likely to vary greatly from to Tribe to Tribe.
Some Tribes are using their CARES funds for medical supplies like masks, suits, and hand sanitizer. Some are purchasing portable quarantine facilities and outfitting them with beds. Others are hiring extra Village Protection Safety Officers and COVID-19 task force members to make sure quarantine and travel restrictions are being enforced. Some Tribes are doing Special Needs COVID-19 assistance payments; some are providing direct vendor payments because legal and/or auditor guidance has recommended not issuing checks to individual tribal citizens (Are Stimulus Checks Allowed?).
The tactics Tribes are utilizing to respond to this public health emergency are as varied as the number of Tribes receiving funds to do so. There is no required method to expend CARES Act funds, but there are many stipulations as to what acceptable expenses are, and what is necessary to comply with required audit paper trails.
If I don't get a stimulus check from my Tribe, should I be contacting the Bureau of Indian Affairs to report them?
Tribes have received modifications to their Aid to Tribal Government 638 contracts with the Bureau of Indian Affairs. Under the current statutory authorities, economic relief per capita payments from Aid to Tribal Government funding are not allowable (Dept of Interior FAQ). Likewise, the Treasury has said a per capita payment to residents of a particular jurisdiction without an assessment of of individual need would not be an appropriate use of payments from the Fund (Corona Relief Fund FAQ). During the weekly teleconferences co-hosted by the Bureau of Indian Affairs and the Alaska Area Native Health Service for Tribes and Federal Partners to share and receive relevant information regarding COVID-19, the BIA was requested to issue a letter on this specific topic which could be shared with Tribal Citizens to alleviate the confusion. This request is being routed to the central office in Washington DC. In the meantime, the BIA has been providing tribal citizens who call with clarification over the phone.
For Tribes who do operate Welfare Assistance (WA) programs (not all do), the Bureau of Indian Affairs has specified the service area for WA for each federally recognized tribe. Tribal Citizens enrolled in a federally recognized Tribe, but residing within the service area of another federally recognized Tribe are eligible to receive services from a WA program operated by the Tribe whose service area they are residing in, as long as there is no duplication of services.