Blackfeet Tribe Plan of (2024)

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Blackfeet Tribe Plan of

Operations Chapter 6 Finance

and Procurement Policies and

Procedures

Issue Date: January 31, 2024

2018 Version, as amended

Page 1 of 1

Finance Policies and Procedures

Plan of Operations Chapter 6

Table of Contents

Table of Contents .......................................................................................................................... 1

1

INTRODUCTION.............................................................................................................. 8

1.1

Overview .......................................................................................................................... 8

1.2

Purpose ............................................................................................................................. 8

1.3

Definition of Terms .......................................................................................................... 8

1.4

Amendment of Financial/Procurement Policies ............................................................... 8

2

GENERAL POLICIES ...................................................................................................... 9

2.1

Fiscal Management Roles ................................................................................................ 9

2.2

Code of Ethics ................................................................................................................ 12

2.3

Conflicts of Interest ........................................................................................................ 14

2.4

Prohibited Conflicts of Interest ...................................................................................... 14

2.4.1 Employee Obligations/Restrictions ............................................................................... 15

2.4.2 Resolution of Conflicts of Interest ................................................................................. 16

2.5

Financial Misconduct ..................................................................................................... 16

2.6

Political Activity ............................................................................................................ 17

2.7

Prohibition on Committee Chair and Administrative Assistant Use of Tribal Funds .... 18

3

FINANCIAL MANAGEMENT...................................................................................... 19

3.1

Purpose and Scope ......................................................................................................... 19

3.2

Basis of Accounting ....................................................................................................... 19

3.3

Financial Management ................................................................................................... 19

3.4

Cash Management .......................................................................................................... 20

3.5

Budgets ........................................................................................................................... 20

3.5.1 Budget Modifications..................................................................................................... 22

3.6

Fund Establishment ........................................................................................................ 22

3.7

Records Retention and Disposal .................................................................................... 23

3.8

Account Reconciliation and Journal Vouchers .............................................................. 24

3.8.1 Bank and Investment Account Reconciliation ............................................................... 24

3.8.2 Journal Vouchers ........................................................................................................... 24

3.9

Financial Reporting ........................................................................................................ 24

3.9.1 Audited Financial Statements ........................................................................................ 25

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3.10

Grant Monitoring ........................................................................................................ 25

3.11

Grants Close-Out ........................................................................................................ 25

3.12

Audits.......................................................................................................................... 26

3.12.1 Annual Audits ................................................................................................................ 26

3.12.2 Scope of Audit Reports .................................................................................................. 26

3.12.3 Procuring Audit Services ............................................................................................... 27

3.12.4 Due Date for Audit Report Submissions ....................................................................... 27

3.12.5 Audit Quality Assurance Reviews ................................................................................. 27

3.12.6 Audit Resolution ............................................................................................................ 28

4

INTERNAL CONTROL POLICIES ............................................................................. 29

4.1

Purpose and Scope ......................................................................................................... 29

4.2

Record Keeping .............................................................................................................. 29

4.3

Signature Authorities...................................................................................................... 29

4.4

Endorsement Requirements............................................................................................ 30

4.4.1 Checks ............................................................................................................................ 30

4.4.2 Transfers ........................................................................................................................ 31

4.5

Write-Off Authorization ................................................................................................. 31

4.6

Control of Cost Transfers/JV between Programs/Funds ................................................ 32

4.7

Internal Control Safeguards over Cash Receipts............................................................ 32

4.8

Access to Financial Data ................................................................................................ 33

4.9

Review Process of Data Entered .................................................................................... 34

4.10

Use of Pre-Numbered Forms ...................................................................................... 34

4.11

Support for all Journal Vouchers ................................................................................ 34

4.12

Chart of Accounts ....................................................................................................... 34

5

COST ACCOUNTING POLICIES ................................................................................ 35

5.1

Purpose and Scope ......................................................................................................... 35

5.2

Cost Accounting Period ................................................................................................. 35

5.3

Unallowable Costs.......................................................................................................... 35

5.4

Administration (Indirect) Costs ...................................................................................... 35

5.5

Direct and Indirect Costs ................................................................................................ 36

5.6

Allocation of Outside Service Fees ................................................................................ 36

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5.7

Contributed Services and Materials ............................................................................... 36

5.8

In-Kind Costs ................................................................................................................. 36

5.8.1 Accounting for In-kind Costs......................................................................................... 38

5.9

6

Accounting for Leases .................................................................................................... 38

RECEIPTS, BANKING, AND DISBURSING .............................................................. 40

6.1

Purpose and Scope ......................................................................................................... 40

6.2

Bank Accounts ............................................................................................................... 40

6.3

Online Banking Access .................................................................................................. 40

6.4

Returned Checks ............................................................................................................ 41

6.5

Revenue Recognition ..................................................................................................... 41

6.6

Program Income ............................................................................................................. 41

6.7

Interest Earned on Advances .......................................................................................... 42

6.8

Segregation of Revenues ................................................................................................ 42

6.9

Accounts Receivable ...................................................................................................... 42

6.10

Accounts Payable ....................................................................................................... 42

6.11

Advance Payments and Deferred Revenue ................................................................ 43

6.11.1 Advance Payments ......................................................................................................... 43

6.12

Fund Balance .............................................................................................................. 43

6.13

Financing Agreements and Debt Covenants .............................................................. 43

6.13.1 Debt Covenants .............................................................................................................. 43

6.13.2 Financing Agreements ................................................................................................... 43

6.14

Travel Costs ................................................................................................................ 44

6.14.1 Per Diem ........................................................................................................................ 44

6.14.2 Lodging .......................................................................................................................... 44

6.14.3 Mileage .......................................................................................................................... 44

6.14.4 Airfare ............................................................................................................................ 45

7

PROCUREMENT ............................................................................................................ 46

7.1

Purpose and Scope ......................................................................................................... 46

7.1.1 Non-compliance Statement ............................................................................................ 47

7.1.2 Amending the Procurement Policy ................................................................................ 47

7.2

Procurement Ethics ........................................................................................................ 47

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7.3

Designated Buyer ........................................................................................................... 48

7.4

Requisition ..................................................................................................................... 48

7.4.1 Simplified Purchases ...................................................................................................... 49

7.5

Requesting Bids and Quotations .................................................................................... 49

7.6

Competition .................................................................................................................... 51

7.6.1 General Competitive Sourcing ....................................................................................... 52

7.6.2 Non-competitive Procurement ....................................................................................... 52

7.7

Vendor Selection ............................................................................................................ 54

7.7.1 Tribal Preference ............................................................................................................ 55

7.8

Vendor Information ........................................................................................................ 56

7.8.1 New Vendors ................................................................................................................. 56

7.8.2 Vendor List .................................................................................................................... 57

7.9

Purchase Orders.............................................................................................................. 57

7.9.1 Purchase Order Preparation ........................................................................................... 57

7.9.2 Purchase Terms and Conditions..................................................................................... 58

7.10

Outstanding Purchase Orders ..................................................................................... 58

7.11

Procurement Records .................................................................................................. 58

7.12

Payment ...................................................................................................................... 58

7.13

Receipt of Goods ........................................................................................................ 59

7.14

Contractual Agreements ............................................................................................. 59

7.14.1 Approval Requirements ................................................................................................. 60

7.14.2 Routing Procedures for Related Parties ......................................................................... 61

7.15

Suspension and Debarment ........................................................................................ 61

7.16

Additional Prohibitions............................................................................................... 61

7.16.1 Personal Tools and Equipment ...................................................................................... 61

7.16.2 Contracts with Employees Prohibited ............................................................................ 61

7.17

Use of Tribal Assets ................................................................................................... 61

7.18

Use of Tribal Credit and Fuel Cards ........................................................................... 62

8

PROPERTY MANAGEMENT ...................................................................................... 63

8.1

Purpose and Scope ......................................................................................................... 63

8.2

Acquisition of Property .................................................................................................. 63

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8.2.1 Grantee-Acquired Property Equipment ......................................................................... 63

8.3

Title of Lien-Interest to Acquired Property with Federal Funds .................................... 63

8.4

Donated Property or Equipment..................................................................................... 64

8.5

Property Identification, Records, and Inventory ............................................................ 64

8.5.1 Sensitive Items ............................................................................................................... 64

8.6

Leases ............................................................................................................................. 65

8.7

Separate Fixed Asset Account Group ............................................................................ 66

8.8

Capitalization of Equipment........................................................................................... 66

8.9

Capital Asset Disposals .................................................................................................. 67

8.10

Use of Tribal Property ................................................................................................ 68

8.10.1 Custodian of Property .................................................................................................... 69

8.10.2 Tribal Vehicle Use Requirements .................................................................................. 69

8.10.3 Wireless Phone Use Policy ............................................................................................ 70

8.11

Disposal of Property ................................................................................................... 71

8.11.1 Selling Property ............................................................................................................. 72

8.12

9

Lost or Stolen Property ............................................................................................... 72

INSURANCE AND RISK MANAGEMENT ................................................................ 73

9.1

Purpose and Scope ......................................................................................................... 73

9.2

Insurance Policies and Risk Management ...................................................................... 73

9.3

Insured Assets ................................................................................................................ 73

9.3.1 Vehicles.......................................................................................................................... 73

9.3.2 Adding or Transferring Property ................................................................................... 74

9.4

Insurance Policy Renewal .............................................................................................. 74

9.5

Insurance Claims ............................................................................................................ 74

9.5.1 Vehicle Claims ............................................................................................................... 74

9.5.2 Property Claims ............................................................................................................. 75

9.5.3 EPLI claims .................................................................................................................... 75

10

PAYROLL ........................................................................................................................ 76

10.1

Purpose and Scope ...................................................................................................... 76

10.2

Administration ............................................................................................................ 76

10.3

Activity Reporting ...................................................................................................... 76

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10.4

Liability for Compensated Absences .......................................................................... 77

10.5

Audit of Payroll Data .................................................................................................. 78

11

11.1

GRANT COMPLIANCE ................................................................................................ 79

General........................................................................................................................ 79

11.1.1 Purpose........................................................................................................................... 79

11.1.2 Subsequent Chapters ...................................................................................................... 79

11.1.3 Training .......................................................................................................................... 79

11.1.4 Changes to Federal Regulations..................................................................................... 80

11.2

Cost Principles and Allowability ................................................................................ 80

11.2.1 General Guidelines......................................................................................................... 80

11.2.2 OMB Uniform Guidance ............................................................................................... 80

11.2.3 Allowable Expenditures with Reference to Unallowable Costs .................................... 80

11.3

Contract/Grant Management ...................................................................................... 82

11.3.1 General Guidelines......................................................................................................... 82

11.3.2 Grant Proposals and Submissions Process..................................................................... 82

11.3.3 Grant Management and Oversight ................................................................................. 84

11.3.4 Monitoring of Match Requirements............................................................................... 84

11.3.5 Reporting Requirements ................................................................................................ 85

11.3.6 Program Performance .................................................................................................... 85

11.3.7 Performance Measures ................................................................................................... 86

11.3.8 Fiscal Year-End/Grant Period End Closing ................................................................... 86

11.3.9 Maintenance of Grant Files and Grant Voucher Files ................................................... 87

11.4

Budgeting.................................................................................................................... 88

11.4.1 General Guidelines......................................................................................................... 88

11.4.2 Budget Preparation......................................................................................................... 88

11.4.3 Budget Management ...................................................................................................... 88

11.5

Time and Effort Reporting ......................................................................................... 89

11.5.1 General Guidelines......................................................................................................... 89

11.5.2 Employee Time and Effort Reporting............................................................................ 89

11.6

Asset Management ..................................................................................................... 89

11.6.1 General Guidelines......................................................................................................... 89

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11.6.2 Fixed Asset Inventory Management .............................................................................. 90

11.6.3 Fixed Asset Disposal...................................................................................................... 91

11.6.4 Review for Potential New Fixed Asset Acquisitions ..................................................... 91

11.7

Indirect Costs .............................................................................................................. 91

11.7.1 General Guidelines......................................................................................................... 91

11.7.2 Indirect Cost Proposals .................................................................................................. 91

11.7.3 Indirect Cost Reporting and Monitoring ........................................................................ 91

11.8

Cash Management and Drawdowns ........................................................................... 92

11.8.1 General Guidelines......................................................................................................... 92

11.8.2 Drawdowns .................................................................................................................... 93

11.9

Travel Advances and After-the-Fact Travel Policy .................................................... 93

11.9.1 General Guidelines......................................................................................................... 93

11.9.2 After-the-Fact Travel Policy .......................................................................................... 94

12

Footnotes of Amendments ............................................................................................... 95

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1

INTRODUCTION

1.1 Overview

The Financial Policies Manual of the Blackfeet Indian Tribe is the official document of the

Tribe, authorized by the Tribal Council, for the conduct of Tribal business and the accounting

and administration for grants and contracts with federal and state governments and other

funding sources.

1.2 Purpose

This manual constitutes all current fiscal policies and standards that have been developed by

the Blackfeet Indian Tribe, unless otherwise noted, through the time of issuance. This manual

guides employees of the Tribe in the application of various federal and state laws and

regulations with financial assistance awarded by other governments and entities.

Ownership of the manual rests with the Finance Director/Accountant, who is responsible for

maintaining policies, coordinating their timely review and update, ensuring the dissemination

of policy revisions to the Tribe and its employees, and reporting compliance with Tribal

requirements. The Finance Director/Accountant is responsible for informing the Treasurer of

all changes, and the Finance Director/Accountant and Treasurer will bring all changes to the

Tribal Council annually for review. Nothing in this policy shall be interpreted to prevent the

lawful enforcement of other Tribal laws.

1.3 Definition of Terms

Unless otherwise defined within policies, when reference is made to terms herein, the terms are

defined in the federal guidance. This guidance includes Uniform Administrative Requirements,

Cost Principles, and Audit Requirement for Federal Awards (2 CFR Chapter I, Chapter II, Part

200, et al.) as well as OMB Circulars A-21, A-87, A-89, A-102, A-110, A-122, and A-133.

Where conflicts exist, definitions within the Uniform Administrative Requirements prevail.

1.4 Amendment of Financial/Procurement Policies

This manual contains the essential fiscal and financial management policies of the Blackfeet

Indian Tribe. It is imperative that these policies are reviewed annually and updated as needed.

As additional matters require promulgation or changes to this manual are appropriate,

amendments will be proposed and made with the approval of the Blackfeet Tribal Council.

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2

GENERAL POLICIES

2.1 Fiscal Management Roles

The Council has the following authorities:

1. Approval of overall fiscal management policy in the form of the Plan of Operations,

ordinances, and resolutions.

2. Adoption of financial plans, strategies, and priorities for use of available financial

resources.

3. Adoption of Tribal budgets and appropriation of funds for investment, expenditure, and

other uses of the Tribe.

4. Appointment of the Tribal Treasurer and establishment of the qualifications for the

office.

5. Adoption of official Tribal positions with respect to federal funds and programs available

to serve the Tribe.

6. Approval of contracts with attorneys, independent auditors, other professionals having

ongoing relationships with the Council, and other procurement agreements exceeding the

amount of $100,000.

7. Approval of grants and other government-to-government agreements between the Tribe

and federal, state, and local governments,

8. Approval of borrowing and financing agreements as defined in this policy.

9. Certification of the official budget of the Tribe and amendments.

The Tribal Council Chair has following authorities:

1. Represents the Tribe by name, title, and signature.

2. Executes all agreements with federal, state, and other governments and entities as

authorized by the Tribal Council.

3. Speaks for the Tribe on issues related to financial resources and programs available to

serve the Tribe from federal and other governments.

4. Consults with and advises management officials on financial matters.

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The Tribal Vice-Chair has the following authorities:

1. Represents the Tribe by name, title, and signature when the Chair is away. Also supports

the Chairman in the completion of various assigned projects.

The following authorities are reserved to the Tribal Secretary:

1. Certifies all actions of the Council.

2. Advises the Tribal Organization regarding budget actions.

3. Oversees the Program Directors.

The Treasurer is the primary custodian of Tribal funds. In addition to the qualifications

specified in the Tribe’s Corporate Charter, the Treasurer is expected to have general

knowledge, background, and experience in financial management, business, and investment.

The Treasurer is expected to avail themselves of training and education in subject matters of

importance to the office, and to establish the Finance Director’s/Accountant’s position and

other positions required to efficiently and effectively carry out the duties of the office. The

Treasurer has the following responsibilities and authorities:

1. Participates in the development of recommended policies, financial plans, strategies, and

budgets.

2. Establishes accounts with banks, trust companies, institutional brokerages and the Bureau

of Indian Affairs, as authorized by the Council.

3. Prepares and collates the official budget of the Tribe and amendments.

4. Signs all checks, and other forms of disbursement and fund transfers authorized pursuant

to Tribal policies and budget, and recommends other officers/employees that may sign on

behalf of the Tribe to the Council for approval.

5. Oversees the official receipt of all funds available to the Tribe and ensures timely deposit

to appropriate accounts.

6. Oversees the investment of funds in accordance with Tribal policies and in cooperation

with the Investment Committee.

7. Selects and supervises the Finance Director/Accountant.

8. With the assistance of the Finance Director/Accountant, recommends the selection of

independent auditors to audit Tribal Financial systems and records.

9. Conducts special audits or reviews as considered necessary to ensure protection of Tribal

financial resources.

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10. Makes reports to the Council, Tribe, and others regarding Tribal finances as necessary.

11. Authorizes the release of financial information to outside entities as necessary for Tribal

business.

12. Establishes fiscal management standards and provides advice and technical assistance to

the Tribe in their development of fiscal management capacity and finance-related issues.

13. Establishes fiscal management standards and provides oversight of Tribal departments’

fiscal management operations. Outside components such as the Grocery Store and the

Casino have individual management agreements.

14. Maintains the official budget of the Tribe and a record of all actions and prepares, for

certification by the Treasurer, such budget actions as are authorized by the Council and

budget policy.

15. Oversees the preparation and release of payments for all Tribal obligations, pursuant to

budget and Tribal policies.

16. Participates as signature authority for executive council in the event that executive

council is not present and available.

The Finance Director/Accountant is primarily responsible for the operation of Tribal

accounting, budgeting, and other fiscal management systems. The Finance

Director/Accountant is expected to be fully qualified in all aspects of financial management.

The Finance Director/Accountant is hired in accordance with Tribal Personnel Policies by the

Treasurer, in consultation with the Tribal Council and other management officials. The Finance

Director/Accountant has the following responsibilities and authorities:

1. Provides for the implementation and maintenance of accounting systems and processes to

account for all Blackfeet Tribal financial matters.

2. Establishes and maintains support systems for budgeting and financial planning.

3. Participates in the development and recommendations of financial policy, plans,

strategies, and budgets.

4. Establishes written procedures for all assigned functions.

5. Publishes written instructions as needed for use by the Tribal organization in the

implementation of budgets and the conduct of Tribal business.

6. Provides technical assistance to the Tribe in the development and maintenance of fiscal

management capacity and certifies the adequacy of fiscal management policies and

systems implemented by the Tribe for the administration of Tribal funds.

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The Procurement Director is responsible for procurement and property management, and has

the following responsibilities and authorities:

1. Participates in the development and recommendations of procurement policy, plans,

strategies, and budgets.

2. Provides for the implementation of procurement and property management systems and

processes.

3. Establishes written procedures for all assigned functions.

4. Provides technical assistance to the Tribe throughout the procurement and contract

management lifecycle.

Considerations for Subordinate Organizations:

1. In general, the Council remains accountable to the Blackfeet people for the actions of

subordinate organizations, which are established by the Council. Accordingly, the

provisions of the ordinance shall apply to subordinate organizations of the Tribe. To the

extent that the organizing documents provide specific direction regarding fiscal

management, the provision of those documents shall apply.

2. The fiscal management policies and systems of subordinate organizations shall comply

with standards established by the Treasurer in consultation with such organizations.

3. The review responsibility of the Council over the fiscal management of subordinate

organizations shall be carried out by the Treasurer and through an annual independent

audit as prescribed in this ordinance.

4. The financial records of subordinate organizations shall be available to the Treasurer and

Finance Director/Accountant of the Tribe at all times.

2.2 Code of Ethics

The purpose of this Code of Ethics is to establish ethical standards for the Blackfeet Indian

Tribe, its Tribal Council, its Committees, its employees, and its government (hereafter,

“officials and employees”). All those acting on behalf of the Blackfeet Indian Tribe are imbued

with a trust to act in the highest ethical manner, carrying out their duties in such a manner that

upholds the best interest of the Tribe and its members. All elected, appointed, or employed

individuals shall not place their personal interest above that of the Tribe. Each Director,

Manager, and Supervisor is responsible for ensuring the ethical behavior of his or her

subordinates.

The following represents standards of conduct important to the maintenance of trust and ethical

behavior:

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1. Tribal officials and employees shall treat service to the Tribe as a sacred public trust with

fiduciary responsibility requiring that they place loyalty to the Tribe and its constitution,

laws, and ordinances above personal and private gain.

2. Tribal officials and employees shall not hold financial interests that conflict with the

conscientious performance of their obligations to the Tribe.

3. Tribal officials and employees shall protect and conserve Tribal property and only use it

for authorized purposes.

4. Tribal officials and employees shall disclose instances when they believe there is fraud,

waste, abuse, and corruption to the appropriate authorities.

5. Tribal officials and employees shall make every effort to adhere to the laws, customs, and

traditions of the Tribe.

6. No Tribal official or employee may use his or her position or office to obtain personal

gain of substantial value for the personal benefit of him/herself or for his/her immediate

family. For the purpose of this section, substantial value is defined as items exceeding

$25 in value. Immediate family is defined as father, mother, son, daughter, husband, wife,

partner, brother, sister, granddaughter, grandson, legal dependent, or any other person in

a similar relationship living in the home of an official or employee.

7. Tribal officials and employees shall not threaten, intimidate, or discipline any employee

in reprisal for the employee acting within the scope of the employee’s official duties.

8. Tribal officials and employees shall not solicit or accept, directly or indirectly, anything

of value if the gift could reasonably be expected to influence his/her vote, official actions,

or judgment, or if it could reasonably be considered a reward for any official action or

inaction.

9. Tribal officials and employees shall not make public policy statements on behalf of the

Tribe without obtaining approval from the appropriate Tribal authority.

10. Tribal officials and employees shall not disclose information/materials pertaining to those

items discussed in executive or closed meetings except by a consensus of the Tribal

Council.

11. No individual Tribal official or employee shall take any official action or participate in a

decision with respect to a matter if it will have a direct and predictable effect on the

financial interest of the official or employee or his or her immediate family members.

Any official or employee in such situation shall disqualify himself or herself from

participating in a discussion and/or vote on the matter.

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The Blackfeet Indian Tribe will not tolerate any activity, including by willful violation,

disregard, or circumvention that violates any applicable laws, rules, regulations, or policies

during the course of employment or office. The Tribe will not tolerate any activity, including

disregard or circumvention, by an employee that violates Blackfeet Indian Tribe policies.

Violations, including disregard or circumvention, will be subject to penalties and actions stated

in the Blackfeet Tribe Personnel Policy Manual.

2.3 Conflicts of Interest

The Blackfeet Indian Tribe has adopted a conflict of interest policy to ensure that its Tribal

Council, Committees, employees, and government (hereafter, “officials and employees”) avoid

transactions that create actual or perceived conflicts of interest. This policy will be reviewed

annually and revised as necessary. Because it is not possible to define all the various

circumstances and relationships that may result in a conflict of interest, the Tribe reserves the

right to determine when a conflict of interest exists and the right to take, in the Tribe’s sole

discretion, appropriate corrective action.

The Tribe recognizes that in some cases, conflicts of interest are unavoidable. If a conflict

arises during the year, the employee will immediately notify the Treasurer and Human

Resources, who together will determine the appropriate resolution.

2.4 Prohibited Conflicts of Interest

The following is not an exhaustive list of conflicts prohibited by this policy:

1. Employees may not have or enter into an immediate familial, dating, or similar personal

relationship with their immediate supervisor or subordinate. In the event such a

relationship arises, they must immediately report the situation and one or both of the

employees must move to another available position within 90 days, or their employment

may be terminated. It is the employee’s responsibility to find and successfully compete

for another position. The Tribe does not guarantee that another suitable position will be

available, nor does the Tribe guarantee that the salary level of an available position will

be comparable to the employee’s previous position. The Tribe reserves the right to

terminate the employment of either employee.

2. Employees may not make any decisions on behalf of the Tribe in which they or their

immediate family members or affiliated parties have a direct personal or financial

interest.

3. Employees may not conduct, enter into, or participate in any business ventures, contracts,

or other arrangements on behalf of the Tribe, with any company, contractor, or other

business in which the employee owns a significant financial interest (more than 5%),

holds a position of influence, or otherwise benefits directly or indirectly from the

company’s relationship with the Tribe, without full disclosure to, and written approval

from the Treasurer and Finance Director/Accountant.

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4. The giving and receipt of gifts are an important part of Blackfeet culture. Generally,

employees may not accept or solicit personal favors, gifts, or other forms of

compensation from individuals or organizations doing business or seeking to do business

with the Tribe. However, an employee may accept such items if there is no likelihood of

improper influence or the perception of improper influence and/or the item is one of the

following:

a. Civic, charitable, educational, cultural, or religious organization awards for

recognition of service or accomplishment, or invitations to events.

b. Trips, meals, guest accommodations, or other travel expenses that involve formal

representation of the Tribe or conduct of Tribal business.

2.4.1 Employee Obligations/Restrictions

The Tribal Council, managers, and employees shall inform the Tribe’s Human Resources

Department of all reportable employment or vendor conflicts on an annual basis. A list of all

vendors with whom the Tribe has transacted business at any time during the preceding year is

available through the Finance Department upon request.

Should any employee accept employment from, or perform services for, a customer, a

potential customer, vendor, or a competitor of the Tribe while employed by the Tribe the

employee must seek an advisory consultation with the Human Resources manager or his/her

designee and immediate supervisor/manager to determine if such outside employment might

conflict with their employment with the Tribe in any way. Employees are not permitted to

engage in any outside employment or services for a customer, a potential customer, vendor,

or a competitor of the Tribe that may interfere with or disrupt the performance of his/her

duties to their immediate supervisor/manager.

The Tribe encourages outside involvement in community, industry, and charitable activities

as long as they do not cause conflicts of interest or create demands that interfere with the

employee’s job.

Employees are prohibited from soliciting or accepting anything of value from anyone in

return for any business, service, or confidential Tribal information. Employees are also

prohibited from using their position with the Tribe to obtain any items or benefits for others

for whom the item or benefits are not available. Examples include, but are not limited to,

receiving personal discounts or free products from a supplier of the Tribe.

Any gift, service, or favor received beyond what is authorized is to be reported to the

Personnel Department, who will provide instructions to the recipient as to the appropriate

action to resolve the matter.

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2.4.2 Resolution of Conflicts of Interest

All real or apparent conflicts of interests shall be resolved as follows:

1. The Treasurer and Human Resource Director shall be responsible for making all

decisions concerning resolutions of conflicts involving employees and non-senior

managers, subject to the approval of the Council.

2. The Council shall be responsible for making all decisions concerning resolutions of

conflicts involving the Directors and Officers.

2.5 Financial Misconduct

The Blackfeet Indian Tribe prohibits financial misconduct by its Tribal Council, Committees,

government, employees, volunteers, and others responsible for carrying out the Tribe’s

activities. Financial misconduct includes, but is not limited to, the following:

1. Actions that violate the Tribe’s Code of Ethics, and any underlying policies, or any of the

accounting and financial policies included in this manual.

2. Abuse of power, such as using one’s position to coerce, threaten, intimidate, or

improperly influence a Tribal member or Tribal employee to provide personal, financial,

or political benefit to oneself, immediate family, or someone they have business or

financial ties to, or for any other purpose, including conducting personal business.

3. Unauthorized participation or involvement in administration and operations, including,

but not limited to, business, program, law enforcement, employment, and personnel

decisions.

4. Unauthorized participation or involvement in any Tribe-owned or operated enterprise

operations, including, but not limited to, business, employment, and personnel decisions.

5. Misappropriation or misuse of Tribal funds or property.

6. Impropriety in the handling or reporting of money in financial transactions.

7. Unauthorized disclosure, concealing, removing, mutilating, or destroying Tribal records,

or copying Tribal records for improper purposes.

8. Committing perjury, fraud, or forgery.

9. Violating the Tribe’s laws, ordinances, resolutions, rules, regulations, or policies.

10. Any other acts prohibited by Tribal, federal, or state law.

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11. Failure to report known instance of misconduct in accordance with the reporting

responsibilities described herein (including tolerance by supervisory employees of

misconduct of subordinates).

12. Failure to comply and intentional violations of Finance and Procurement policies will

result in disciplinary action to be determined by the Personnel Department, up to and

including termination and criminal prosecution.

2.6 Political Activity

The Hatch Act and the Intergovernmental Personnel Act of 1970 precludes federal funds from

being used for partisan political purposes by any person involved in the administration of

federally assisted programs.

Employees of the Tribe and employees of any entity, corporation, or enterprise that is financed

in whole or in part by federal funds, including funds granted or loaned to the Tribe, shall not

participate in any of the following activities during working hours, for any political campaign

for Tribal, local, state, or federal political office.

1. Serve for or on any political campaign committee.

2. Organize a political party or political club.

3. Directly or indirectly solicit, receive, collect, handle, disburse, or account for

contributions on behalf of candidates.

4. Take an active part in managing the political campaign of a candidate.

5. Endorse or oppose a candidate for elective office in a political advertisement, broadcast,

campaign literature, or similar material or media.

6. Address or attend a political rally, political meeting, or similar gathering in support of or

in opposition to a candidate.

7. Write for publication or publish any letter signed or unsigned in favor of or against any

candidates or faction.

8. Use any Tribal materials, facilities, electronic equipment, vehicles, etc., for political

activities, except as endorsed by Blackfeet Tribal Council directive or resolution.

9. Circulate or sign a nominating petition on behalf of one or more candidates to any Tribal,

local, state, or federal election during working hours.

10. Use his or her position to interfere with a Tribal election or to interfere with its results.

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2.7 Prohibition on Committee Chair and Administrative Assistant Use of Tribal

Funds1

The Blackfeet Tribal Business Council prohibits any Committee Chairperson or his/her duly

authorized representative including Council administrative assistants, from administering tribal

funds and grants, including the: signing off on any financial accounts, including but not limited

to, payment vouchers, checking accounts, and credit/debit cards, without Council action by

resolution.

Violations of these provisions shall subject the employee to disciplinary action.

1 Resolution No. 166-2019, “Establishing Internal Controls over the Administration of Tribal Finances”, April

17, 2019

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3

FINANCIAL MANAGEMENT

3.1 Purpose and Scope

This section establishes uniform standards and policies for financial accounting and reporting

for the Tribe based on generally accepted accounting principles (GAAP) and industry

standards. These policies are intended to provide guidance to ensure that the Tribal government

maintains financial management practices in keeping with the highest fiduciary standards.

3.2 Basis of Accounting

Governmental funds are reported using the current financial resources measurement focus and

the modified accrual basis of accounting. Revenues are recognized as soon as they are both

measurable and available. The Tribe considers all revenue to be available if the revenue is

collected within sixty days after year-end. Expenditures are recorded when the related fund

liability is incurred. However, debt service expenditures, as well as expenditures related to

compensated absences, are recorded only when payment is due. General capital asset

acquisitions are reported as expenditures in governmental funds. Proceeds from long-term debt

and acquisitions under capital leases are reported as other financing sources.

Proprietary funds, non-expendable trust funds, expendable trust funds, and pension trust funds

are reported using the economic resources measurement focus and the accrual basis of

accounting. Under this method, revenue is recorded when earned and expenses are recorded

when liabilities are incurred, regardless of when the related cash flow takes place.

Intergovernmental revenues from federal, state, and county grants and contracts are considered

measurable when all eligibility requirements are met. Accordingly, revenues are recognized

based upon expenses recorded.

3.3 Financial Management

The Blackfeet Indian Tribe will maintain records and make reports in such form and containing

such information as may be required by its funding sources. The Tribe will maintain such

accounts and documents that will serve to permit expeditious determination of the status of

funds and the levels of services, including the disposition of all monies received from its

funding sources and the nature and amount of all charges claimed against such funds.

The Blackfeet Indian Tribe will maintain accurate accounting records and provide current and

complete disclosure in financial reporting in accordance with the reporting requirements of

each award. Title 45 Code of Federal Regulations Subpart 74.21(b) and the administrative rules

of other federal agencies require that grantees or sub-grantees have records that adequately

identify the source and application of funds for grant or sub-grant supported activities. At a

minimum, these records will contain information pertaining to grant or sub-grant awards,

authorizations, obligations, unobligated balances, assets, expenditures, income, and liabilities.

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In accordance with administrative rules, including Uniform Administrative Requirements, Cost

Principles, and Audit Requirement for Federal Awards (2 CFR Chapter I, Chapter II, Part 200,

et al.) as well as OMB Circulars A-21, A-87, A-89, A-102, A-110, A-122, and A-133, the

Blackfeet Indian Tribe Finance Department systems will, at a minimum, carry out the

following standards:

1. Effective control over and accountability for all funds, property, and other assets. The

Blackfeet Indian Tribe shall adequately safeguard all such assets and ensure they are used

solely for authorized purposes. (The Blackfeet Indian Tribe Procurement Department

works in tandem with The Blackfeet Indian Tribe Finance Department regarding the

accountability and safeguard of fixed assets and inventory.)

2. Comparison of outlays with budget amounts for each award. Whenever possible, financial

information shall be related to performance and unit cost data.

3. Written procedures to minimize the time elapsing between the transfer of funds to the

Blackfeet Indian Tribe from the U.S. Treasury/other funding sources and the issuance or

redemption of checks, warrants, or payments by other means for program purposes by the

recipient.

4. Written procedures for determining the reasonableness, allocability, and allowability of

costs in accordance with the provisions of the applicable federal cost principles and the

terms and conditions of the award.

5. Accounting records, including cost accounting records that are supported by source

documentation.

3.4 Cash Management

According to Treasury Circular 1075 (31 CFR 205.11), the time elapsed between the transfer

of funds from the U.S. Treasury and disbursement by the Blackfeet Indian Tribe should be

minimized and should be limited to the actual, immediate cash requirements of the Blackfeet

Indian Tribe.

For federal and state funded programs, cash will be requested as needed. When possible, funds

will be transferred electronically or by the appropriate funding requirement form.

3.5 Budgets

A budget is used to provide detailed financial information to the Tribal Council and its

committees so that sound decisions can be made as to the proper allocation of Blackfeet Tribal

financial and human resources. Except as limited policy decisions of the relevant Director, the

overall responsibility of the program budgets and operations rests upon the Program Managers.

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At the time of submission of an annual plan, each program will provide completed Budget

Allocation Forms, which are available from the Finance Department. All budgets will provide

detailed justification for each line item in the budget.

The Program Manager shall ensure that no budget recommendation shall exceed estimated

revenues.

Grant and Program Managers should ensure that the projected activities of the program are

within the scope of work of the contract/grant document. Newly proposed grants and contract

applications shall be reviewed by Finance and the relevant Director. No new proposals shall be

presented before the Tribal Council prior to this review. The submitted budget should use the

appropriate fringe and indirect cost rates to determine final budget amounts. In no case will the

submitted budget be in excess of the awarded grant/contract amount.

Tribal Program Directors shall submit the budget for the subsequent fiscal year to the Treasurer

no later than August 1 with revisions submitted no later than August 15. Recommended

budgets shall be submitted to the Council no later than September 1.

The Tribe’s Finance Department shall prepare and submit the Indirect Cost Proposal to the

National Business Center by March 31 for the rate proposed for the following fiscal year. The

Tribe will maintain a budget of its indirect costs and its bases of allocation. The approved

indirect cost rate is used when determining the overhead applied to each federal award.

It is anticipated that any indirect cost shortfall experienced by the various departments will be

taken directly from other Tribal dollars. The Tribe is responsible for any shortfall not covered

by other program dollars. Due to the fact that several federal and state programs do not fully

fund their share of the indirect cost pool, other funding sources should always be sought first

prior to seeking general funds.

Once the fiscal year budget is adopted, the authority of the Tribal Council will be budget

oversight. This will not prevent the Tribal Council from taking corrective action, when

necessary, to ensure compliance with the mandates set during the annual budget review.

Each grant and contract will also have a budget recorded in the accounting system.

Compliance Monitors will be responsible for reviewing and reconciling monthly financial

statements for their respective programs and projects. All Directors are required to identify and

report to the Compliance Monitors, in writing, any matter that may prevent compliance with the

program’s adopted budget as well as provide written explanations for budget variances of 5% or

more or $1,000 or more.

The Treasurer is responsible for ensuring that the budget is properly implemented and that any

unauthorized expenditure is prohibited. The Treasurer will report any deviations from the budget

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to the relevant Director if it cannot be resolved on the program basis. The Treasurer will be

responsible for reviewing monthly reports to ensure budget compliance.

3.5.1 Budget Modifications

In-house budget modifications shall be forwarded through the Compliance Monitor for

review and brought to the attention of the Treasurer for any non-routine modifications up to

25% of the total budget.

The Tribal Treasurer will approve any Tribal program budget modifications that are in excess

of 25% of total budget. Each grant is subject to the provisions required in the grant document

and select grants may require additional budget modification approval from the granting

agency. Grant budget modifications will follow the requirements of 2 CFR 200.308.

3.5.1.1 Uniform Budget Systems for Governmental Operations

There shall be an automated uniform budget planning system used for all governmental

operations. The system shall include uniform budget categories and account codes to ensure

that informative reporting and analysis can occur at various reporting levels with efficiency

and reliability. Directors shall account for items at least in the following detail:

1. Personnel costs: Each personnel position shall be budgeted individually within budget

information for internal use but shall not be for published information. Costs shall include

payroll taxes, workers’ compensation, insurance, and employee fringe benefits, in

aggregate for the cost center.

2. Operating and other expenditures at the level described within Section 4 of this policy

manual.

3. Revenue by source and purpose.

3.6 Fund Establishment

Funds are established as necessary for tracking grants and other Tribal activity. The Tribal

Council Chair signs the grant agreement and it is forwarded to the Finance Department. To

establish a fund, the grant agreement or Tribal activity support must, at a minimum, include:

1. The name and purpose of the fund

2. Tribal Council Chair’s signature (or authorized signature)

3. Award amount

4. CFDA number

5. Other information as applicable, which may include:

a. Description of the fund, including background/history.

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b. A description of the source of contributions or revenues to the fund, including a

statement regarding the disposition of earnings on the fund.

c. Custody of the fund: a statement regarding the authorized depositories for the purpose

of holding the funds on behalf of the Tribe.

d. Authorized uses of the fund, including the types of expenditures that may be made from

the fund and any restrictions on spending.

e. Any match requirements (must be approved by resolution).

f. Target and minimum fund balance.

3.7 Records Retention and Disposal

All financial records, supporting documents, statistical records, and other required or pertinent

records will be retained for seven years, or as specified by the agency from the day it submits

its final expenditure report, or as specified by grant terms if applicable. For grants involving

continued support or that are renewed annually, the retention period starts on the day the Tribe

submits its expenditure report for that period.

If any litigation, claim, negotiation, audit, or other action involving the records has been started

before the expiration of the seven-year period, the records must be retained until completion of

the action and resolution of all issues that arise from it, or until the end of the regular sevenyear period, whichever is later.

In accordance with the "Guide to Record Retention Requirements," National Archives and

Records Administration, U.S. Department of Commerce, for the Internal Revenue Service, the

following records will be retained for the indicated minimum periods:

1. For six years after the close of the year: accounts payable and accounts receivable ledger,

payroll register, inventory ledger, bad debt write-off supporting details, cash book, petty

cash book, check register and checks, invoices (funding sources and vendors), and

insurance safety reports.

2. Permanently: Audit reports, chart of accounts, financial statements, general ledger, fixed

asset records, journal vouchers, profit and loss statements, tax returns, annual Tribal

reports, charters, by-laws, and minutes, grants and agreements, tax and legal

correspondence, incorporation records, labor grants, insurance claims and policies, accident

reports, and retirement and pension records.

The disposal date determined under this policy will be the end of the fiscal year of the

anniversary date of the required number of years from the act specified or, where not specified,

from completion of a grant, date of final payment of a grant or year in which an entry is made

charging or allocating a cost to a government grant, as the case may be.

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All records not supporting government grants or otherwise covered by rules of the Internal

Revenue Service will be retained for seven years from the end of the fiscal year in which the

records were originally prepared.

3.8 Account Reconciliation and Journal Vouchers

3.8.1 Bank and Investment Account Reconciliation

The majority of the Tribe’s investment accounts are held by the Department of Interior

Office of the Special Trustee for American Indians.

On a monthly basis, the Finance Director/Accountant shall prepare and/or review the account

reconciliations, check registers, and resulting journal vouchers and have oversight to ensure

that reconciliations are completed in an accurate, timely, and thorough manner. Preparers

and reviewer shall initial and date reconciliations.

3.8.2 Journal Vouchers

All journal voucher requests must be accompanied by the JV Review Form and have

sufficient documentation attached to them. The forms should be comprehensive enough so

that any accounting office employee and/or auditor can determine what each number

represents.

Accountants are designated approvers of journal entries. Approvers must review all

supporting documentation before approving. The approvers must initial and date the

supporting documentation cover page to indicate their approval. Approved journal entries are

submitted to Key Punch for posting.

Journal vouchers are reviewed at year-end close.

3.9 Financial Reporting

Financial reporting is the summarizing of activities that have taken place in the financial

accounts during a given period of time. The Tribe is required to develop other statements that

are submitted as reports to the federal and state organizations from which funding is received.

Normally, these reports are adaptations of information contained in the balance sheet and/or

the statement of revenues and expenditures. The organization is able to use the information on

these statements in preparing the various federal and state reports.

The requirements for federal reporting are standardized in the Office of Management and

Budget Circular, Code of Federal Regulations, Public Law, and the funding agency

regulations. The Program Director and Compliance Specialist are responsible for maintaining a

report listing each program, fiscal year, forms to be used, number of copies, date due by month,

quarter, or year, and date submitted. Reports need to be prepared and submitted in a timely

manner. Copies of retained reports will have support attached such that the amounts reported

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on each financial report reconciles to the general ledger for that time period, and initialed by

the preparer and the authorized person who reviews prior to submission.

The Finance Department will maintain supporting records in sufficient detail to prepare the

Tribe’s financial reports, including:

1. Annually: Completed within 180 days following the fiscal year end, or by March 31

a. Financial statements and schedules for audit.

b. Annual budget(s).

c. Indirect cost submission to the National Business Center.

2. Monthly: Completed by the first Thursday of each month, or as requested by Council

a. Comparisons of actual year-to-date revenues and expenses with year-to-date budgeted

amounts by program.

3.9.1 Audited Financial Statements

Annual audits shall be conducted and Audited Financial Statements shall be published in

accordance with Section 3.12 of this policy. Upon completion of work by Independent

Auditors, the Finance Director shall concur or make any necessary adjustments to the final

financial statements. Any unresolved audit issues that may impact the auditor’s opinion or

the timely release of audited financial statements shall be handled in accordance with Section

3.12 of this policy.

After audited financial statements are completed, the Treasurer shall provide copies of the

audit to Tribal members upon request.

3.10 Grant Monitoring

The Compliance Monitor will reconcile grant activity monthly, or more frequently as

necessary, to the general ledger. Tribal and in-kind contributions will be identified separately.

Draw-downs will be approved by the Treasurer or designee in accordance with the grantor’s

practice, according to the approved budget. Reimbursable grant drawdowns will have support

that agrees with the detail general ledger for that program for the indicated time period.

3.11 Grants Close-Out

Upon completion of project or term expiration of the grant, the Program Director and

Compliance Specialist shall ensure that the following occurs:

1. All funds must be disbursed or returned to the grantor or carried forward in accordance

with the grant.

2. The purchase order is closed, and the file documented.

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3. Program Managers or Directors have provided the Finance Department with a summary of

the program outcome and necessary supporting documentation, including the close-out

report.

Files shall be retained in accordance with section 3.7 above. Auditing of project files

receiving federal funds must be made readily available.

If the Blackfeet Indian Tribe is acting as a grantor, fiscal agent, or administrator of a grant to a

sub-recipient and there was an issue of malfeasance or non-feasance during the contract, the

Compliance Specialist shall work in conjunction with relevant Program Managers or Directors

in determining whether or not debarment proceedings against the grant recipient should be

initiated.

3.12 Audits

3.12.1 Annual Audits

The Tribe will have a single audit and organization-wide financial statement audit conducted

annually by a qualified independent public accountant.

The audit will be conducted in accordance with the Uniform Administrative Requirements,

Cost Principles, and Audit Requirement for Federal Awards (2 CFR Chapter I, Chapter II,

Part 200, et al.), which supersedes OMB Circular A-133. Moreover, independent public

accountants conducting such audits will abide by Generally Accepted Governmental

Auditing Standards (GAGAS).

3.12.2 Scope of Audit Reports

During a Single Audit, the auditor determines whether:

1. The financial statements and the accompanying schedules of the Tribe fairly present its

financial position and the results of its financial operations in accordance with GAAP.

2. The Tribe has internal accounting and other control systems to provide reasonable

assurance that it is managing federal financial assistance programs in compliance with

applicable laws and regulations.

3. The Tribe has complied with laws and regulations that may have a material effect on its

financial statements and on each major federal assistance program.

The organization-wide financial statement audit enables the Tribe to:

1. Assess the finances of the Tribe in its entirety, including the year's operating results.

2. Determine whether the Tribe’s overall financial position improved or deteriorated.

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3. Evaluate whether the Tribe’s current-year revenues were sufficient to pay for currentyear services.

4. See the cost of providing services to members.

5. See how the Tribe finances its programs.

6. Understand the extent to which the Tribe has invested in capital assets, including roads,

bridges, and other infrastructure assets.

3.12.3 Procuring Audit Services

In soliciting and retaining auditors to conduct the annual audit, the Treasurer must make

specific reference in its request for proposal and any resulting contract that the auditor will be

required to conform its audit to the contract requirements in current federal requirements.

This relates to the scope of the audit, standardized audit report, reportable events, monitoring

by the granting agency, quality assurance reviews, access to audit work papers, plan for

corrective action, and resolution of audit findings.

The audit solicitation and any resulting contract for audit services will make specific

reference that "if it is determined that the contractor's audit work was unacceptable as

determined by the granting agency or a federal supervisory agency, either before or after a

reasonable time after a draft or final report was issued because it did not meet the granting

agency's standards, the AICPA Standards or those promulgated by the Comptroller General

of the United States, the contractor may, at the written request of the Blackfeet Indian Tribe,

be required to re-audit at its own expense and resubmit a revised audit report that is

acceptable."

The Blackfeet Indian Tribe may award multi-year audit contracts of no longer than a fiveyear duration. At the end of such a multi-year period, the Finance Director/Accountant,

Treasurer, and Tribal Council will observe competitive procedures in procuring audit

services. The audit firm selection must be completed a minimum of 90 days in advance of

end of the year.

3.12.4 Due Date for Audit Report Submissions

The final audit report will be submitted to the Tribe within 120 to 150 days, or by the last

business day in June.

3.12.5 Audit Quality Assurance Reviews

Qualified Tribal personnel should:

1. Review the complete audit report and note any deviations in the report format from that

prescribed in the audit grant scope of work.

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2. Prove the clerical accuracy of all footings, extensions, etc., of all statistical data in the

report.

3. Verify that all exhibits, schedules, and supporting statements in the report are in

agreement and reconcilable, where appropriate.

4. Review and evaluate the propriety of all questioned costs presented in the report and/or

other management and internal control weaknesses.

3.12.6 Audit Resolution

The Treasurer will systematically ensure the timely and appropriate resolution of audit

findings and recommendations.

The Treasurer will ensure that appropriate corrective action, including settlement and

payment of any unacceptable costs, is taken within six months after receipt of an acceptable

audit report for a sub-grantee in instances of non-compliance with federal laws and

regulations.

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4

INTERNAL CONTROL POLICIES

4.1 Purpose and Scope

This section establishes appropriate internal controls for Tribal operations. These policies are

intended to provide guidance to ensure that the Tribal government maintains internal controls

in keeping with required standards.

4.2 Record Keeping

To provide an accurate and auditable record of all financial transactions, books, records, and

accounts must be maintained in conformity with GAAP. Each employee is responsible for

safeguarding the organization’s assets under their control and for maintaining an auditable

record of financial transactions.

Further, the Tribe specifically requires that:

1. No funds or accounts may be established or maintained for purposes that are not fully and

accurately described on the books and records of the organization.

2. Receipts and disbursements must be fully and accurately described on the books and

records of the Tribe.

3. No false entries may be made on the books or records and no false or misleading reports

issued.

4. Payments may be made only to the granting party or a valid assigned designee and only for

the actual services rendered or products delivered. Each payment must have adequate

supporting documentation.

If you have reason to believe that the organization's books and records are not in accord with

the foregoing requirements, report the matter to the Treasurer, Finance Director/Accountant,

relevant Director, or Tribal Council.

4.3 Signature Authorities

The following table specifies the signatures required for authorization:

Type of Expenditure or Transaction

Expenditures and Transactions

Major Investments (capital and financial

investments)

Leases and Rental Transactions/NonGaming

Program Purchases

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Authority by Position

Tribal Council Chair, as authorized by Tribal

Council

Treasurer

Director and Compliance Monitor, over

$10,000.00 needs Council approval.

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Type of Expenditure or Transaction

Consultants

Council Committee Budgets2

Authority by Position

Director and Compliance Monitor, over

$25,000.00 needs council approval.

Council Executive Committee: Chairperson,

Vice-Chairperson, and Secretary

Business Commitments and Authorizations

Grant Proposals/Applications

Tribal Council Chair, as authorized by Tribal

Council, and Program Director

Funding Contracts/Grants*

Tribal Council Chair, as authorized by Tribal

Council

Procurements

Varies, see procurement policy

Personnel Matters

New Hires

Director, Human Resources, Compliance

Specialist

Transfers or Funding Source Changes

Director, Human Resources, Compliance

Specialist

Salary Action, Promotion, Termination

Director, Human Resources, Compliance

Specialist

Leave of Absence

Director, Human Resources, Compliance

Specialist

Overtime Approval (Pre-approved, unless Immediate Supervisor, Program Director,

emergency-based program)

Compliance Specialist, Council must preapprove

Other Actions

Time Card Approvals

Immediate Supervisor

Director Time Card Approvals

Tribal Secretary

Employee Travel Authorization

Director and Compliance Monitor, 1 Executive

and 2 Council.

Council Travel

Treasurer or Council Chair, Travel Committee

Goods Transfer, Disposal, or Lost/Stolen Director

* Legal Counsel for the Tribe should review all contracts particularly as it relates to dispute resolution and when to

waive sovereign immunity.

4.4 Endorsement Requirements

4.4.1 Checks

To process checks for all Tribal bank accounts, the Blackfeet Indian Tribe has identified the

following positions as having endorsement authority for checks issued from the Tribe:

Treasurer

2 Resolution No. 166-2019, “Establishing Internal Controls over the Administration of Tribal Finances” April 17,

2019

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Chairman; or, Acting Chairman

Vice Chairman; or, Acting Vice Chairman

Secretary; or, Acting Secretary,

when such endorsement authority is unavailable due to resignation, sickness, AWOL or death

(See Blackfeet Plan of Operations, Chapter 3, Duties and Responsibilities of Tribal

Employees and Key Employees, E.)3

All checks issued by the Blackfeet Indian Tribe will have the signature(s) required by the

check amount.

The Compliance Specialist will examine all original supporting documentation to ensure that

each item has been properly verified. The AP Keypunch will review documentation as

required for due diligence prior to signing a check.

Checks should not be signed if supporting documentation appears to be missing or there are

any questions about a disbursement.

Pre-signed blank checks are prohibited.

Accounting staff involved in the check disbursement process will not have physical control

of the equipment used to sign checks (plates, stamps, CD, etc.).

Keys to this equipment will be kept in a locked location and access shall be restricted to the

Treasurer.

Signed checks not being mailed shall be held in the Accounting Department. Security is also

authorized to hold checks when requested by Accounting.

4.4.2 Transfers

All inter-fund wire transfers will require the original signature of the Treasurer.

4.5 Write-Off Authorization

All available means of collecting accounts receivable will be exhausted before write-off

procedures are initiated. Write-offs are initiated by the department associated with the amount

to be written off, in conjunction with the Accounting Department.

If an accounts receivable related to a Tribal member is deemed uncollectible, such as a loan or

utility, the following approval is required before the write-off is processed:

3 Resolution No. 237-2022, “Amending the Blackfeet Plan of Operations and Finance Policies (2018) Providing

Executive Signatory/Endorsement Authority for all Financial Institutions and Banks holding Tribal Funds”

February 8, 2022

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Amount

Under $1,000

$1,000 and over

Authorized in writing by

Treasurer

Tribal Council

If an accounts receivable is deemed uncollectible but is not related to a Tribal member, or if a

write-off is needed for other reasons, such as an unallowable cost, Tribal Council approval is

required before the write-off is processed.

Proper support noting the customer, amount of write off and initials of authorized person shall

be retained in accordance with record retention policies noted in section 3.7.

Once a write-off has been processed, appropriate individuals in the originating department will

be advised so that further credit is not granted and to update the master list of bad accounts.

Customers listed as poor credit risks will be extended future credit only if the back debt is paid

and the customer is no longer deemed a collection problem.

If write-off procedures have been initiated, the following accounting treatment applies:

1. Current year invoices that are written off will either be charged against an appropriate

revenue or revenue adjustment account, or against the original account credited.

2. Invoices written off that are dated prior to the current year will be written off against an

appropriate revenue account.

4.6 Control of Cost Transfers/JV between Programs/Funds

For all transfers of costs from one program to another, and from a direct cost to an indirect cost

or vice versa, the Tribe will:

1. Have available in its accounting records an appropriate written justification statement from

the director of the program/fund for any cost transfers/JV.

2. If the amount exceeds $10,000, obtain the written approval of the Director of the receiving

cost center/fund.

4.7 Internal Control Safeguards over Cash Receipts

All Tribal programs that collect funds must issue a pre-numbered receipt, which is identifiable

by program, either labeled or by number, and is in triplicate. Receipts will be given to payee,

accounting, and a copy will be retained by the program. All funds must be collected by the

Finance Department unless otherwise authorized by the Council.

A copy of the receipt along with the reconciled funds collected will be brought to the Finance

Department on a weekly basis, with the exception of Tribal enterprises and special events,

which are reconciled daily.

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Records maintained by Tribal programs are subject to internal and external audits.

Any and all money raised to benefit/supplement Tribal programs is considered to be Tribal

funds and must be deposited to the Finance Department pursuant to this policy.

Finance staff will verify deposits and issue a receipt to the fund.

Upon issuance of the receipt, Finance staff will maintain the money in a secure location until a

bank deposit is prepared. (Tribal enterprises may be an exception to this policy. Refer to the

specific cash handling policy for each enterprise.)

In the event of a discrepancy, the actual amount of deposit will be determined by the staff

involved in the transaction and a receipt will be issued for the actual amount. Any discrepancy

will be investigated, and the cause determined within two days, and the discrepancy will be

reported to the Finance Director/Accountant.

Bank deposits will be prepared daily, and the batch session will be given to the Cash Receipts

Clerk or designated authority for approval. The Cash Receipts Clerk will verify the deposit and

the deposit will be placed in a sealed bank bag. Security takes the sealed bank bag to the bank

and returns the bank deposit slip in the sealed bank bag to the Cash Receipts Clerk

If any money is brought over after the weekly bank deposit is done, the money will be either

maintained in a secure location or put into night deposit.

Accommodations will be made to make daily banking deposits from the Tribe. In the event a

deposit cannot get to the bank, the deposit will be locked in a secure location.

In the event money is missing from any Tribal program, it must immediately be reported in

writing to the relevant Director and Finance Director/Accountant regardless of the amount

missing. It will be the responsibility of the relevant Director to determine a course of action.

Failure to comply and intentional violations of Finance and Procurement policies will result in

disciplinary action to be determined by the Personnel Department, up to and including

termination and criminal prosecution.

4.8 Access to Financial Data

The Blackfeet Indian Tribe utilizes passwords to restrict access to accounting software and

data. Accounting software users are assigned by the Finance Director/Accountant as needed for

their duties, and access is revoked when duties change, or employment is terminated.

The Tribe's automated accounting system requires a user I.D., as well as a password to

preclude unauthorized access to data.

Access to any computer-based financial data will be granted on a need-to-know basis and users

will only be able to access the software and data files necessary for their required duties.

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All users must keep their passwords secret and change their passwords regularly, no less than

every 120 days. Access will be restricted by a series of passwords to be revised, system-wide,

at least annually.

The system's accounting data will be backed up to a secure offsite location daily.

4.9 Review Process of Data Entered

Before any entries are posted, the un-posted entries will be approved as follows:

1. Journal Vouchers: Each JV Review Form is approved by the assigned Compliance Monitor

and Finance Director/Accountant.

2. Disbursement and A/P Checks: Compliance Specialist, Program Director and Council, if

over $25,000.00, approves invoices selected for payment.

3. Revenue Receipts: Cash receipts are reviewed as received by the Compliance Monitor.

Directors must provide backup for all non-grant cash receipts received by the Tribe for

their program.

4.10 Use of Pre-Numbered Forms

All checks and purchase orders will be issued in numerical order.

4.11 Support for all Journal Vouchers

All journal voucher request forms must have sufficient documentation attached to them. Each

form should be comprehensive enough so that any accounting office employee and/or auditor

can determine what each number represents.

4.12 Chart of Accounts

The Finance Director/Accountant monitors and controls the chart of accounts, including all

account maintenance. Any additions or deletions of accounts must be made by the Finance

Director, who ensures that the chart of accounts is consistent with the structure of the Blackfeet

Indian Tribe and meets the needs of each division and department.

The accounting coding structure is designed to work compatibly with the Fund Accounting

System, MIP, and is built on a table-driven segment structure. The following presents the

typical account segments:

Fund

4-digit number

Department

2-digit number

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Function

3-digit number

Finance Policies and Procedures

General Ledger Code

Up to 4-digit number

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5

COST ACCOUNTING POLICIES

5.1 Purpose and Scope

This section establishes uniform policies for the allocation of costs within the governmental

operations of the Tribe to ensure uniformity of budgeting, accumulation, accounting, and

reporting of costs in an efficient manner that will result in an accurate assessment of the costs

of programs and operations. The policy sets forth the categories and functional components

into which costs are to be allocated for all governmental operations and provides for the

appropriate allocations of the cost of services provided by governmental operations to nongovernmental organizations operated by the Tribe.

5.2 Cost Accounting Period

The fiscal year of the Blackfeet Indian Tribe will be October 1 to September 30.

5.3 Unallowable Costs

Costs expressly unallowable, or mutually agreed to be unallowable, will be identified in

separate accounts and excluded from a billing, claim, or grant. These costs may include bad

debts, contingencies, contributions, entertainment, fines and penalties, general governing

expenses, capital assets, interest, legislative expenses, under recovery of costs under grant

agreements, and any other costs stated as unallowable in grant agreements. These costs, if paid

by the Tribe, will be from the Tribal General Fund.

5.4 Administration (Indirect) Costs

All costs for the overall operation of the Blackfeet Indian Tribe that are used for administering

federal and state funded grants and contracts will be considered administrative. In general, the

following list of costs that are considered necessary for the overall administration of the Tribe

will be included in this category:

1. The personnel expenses of the relevant Director and administrative staff, and fiscal and

planning staff to the extent they are involved in activities of a general nature related to the

overall operation of the Tribe. Such activities include personnel management or

supervision by administrative staff that is not traceable to any specific service.

2. Staff time spent researching and acquiring other resources to be used for the development

and expansion of services.

3. Staff travel expenses for personnel activities charged to the indirect cost pool.

4. General Tribal personnel management and record keeping related to employee benefits, as

well as developing and implementing personnel policies and such activities as staff

orientation and training of a general nature.

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5. Financial management of Tribal program operation such as maintaining necessary journals,

ledgers, and accounts, making requisite bank deposits and withdrawals, invoicing and

payment processing, payroll administration, and preparing periodic financial reports that

encompass the overall agency financial status. The cost of project accounting for

grant/contract activities may be treated as an allocable cost.

6. Costs of office furniture, supplies, and equipment designated specifically for the

administrative staff.

7. The annual audit for federal and state funded programs (all funds).

8. The costs of general liability insurance, fidelity bonds, etc.

5.5 Direct and Indirect Costs

Costs incurred specifically for a final cost objective (e.g., a grant, contract, etc.) will be treated

as direct cost.

The Blackfeet Indian Tribe maintains one composite indirect cost pool combining all indirect

costs. The base of allocation for the indirect cost pool is determined annually and subject to

change.

Each of the individual cost elements will be treated consistently.

5.6 Allocation of Outside Service Fees

Outside service fees, such as legal fees, incurred specifically in connection with a final cost

objective will be allocated as a direct cost.

5.7 Contributed Services and Materials

Contributed services in the form of volunteer services will be recognized if all of the following

conditions exist:

1. The services performed are significant and form an integral part of the efforts of the Tribal

program. The Tribe controls the duties of the service donors.

2. The Tribe has a clearly reasonable basis for the amount to be recorded.

3. Materials received as support will be recorded based on their estimated fair market value.

When a reasonable fair market value cannot be determined, no support should be

recognized.

5.8 In-Kind Costs

The Tribal Council will approve any in-kind costs associated with a grant at the time of grant

approval. It is the policy of the Tribe to minimize in-kind costs where possible.

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To satisfy a matching or cost-sharing requirement on a grant or contract, in accordance with

GASB, the Tribe will account for the following allowable in-kind costs:

1. Charges incurred by the Tribe as project costs, including non-cash items such as

depreciation or use charges.

2. Project costs financed with cash contributed or donated to the Tribe by non-federal third

parties, or in the case of federal funds, other federal funds specifically authorized by law

for matching.

Indirect costs will not be used as the Tribe’s program match requirement without prior

approval from the grantor agency.

Several items are not normally counted as in-kind:

1. Goods and services normally available free in the community and that would be available

whether the project was operated or not, e.g., CPR training, space in a community center,

etc.

2. Contributed time of elected officials or Advisory Councils.

3. Value of space donated for meetings and other purposes in the homes of individuals,

especially staff members.

4. Outdoor space such as playgrounds, park space, and undeveloped lots.

Valuation of third-party, in-kind contributions:

1. Volunteer services: unpaid services valued at rates paid by other activities of the

organization should be consistent with those paid for similar work in the same labor

market. Rates of employees of other agencies should be priced at the base compensation

rate exclusive of fringe benefits and overhead costs.

2. Donated real or tangible personal property:

a. Tangible personal property and donated real property (land and buildings): purchase

price or fair market value at the time of transfer.

b. Donated use of property: valued as if the grantee has rented the property and has paid

the property’s fair rental value.

c. Grantees may be required to establish the value of real property through the use of an

appraiser.

3. Other charges: adequately supported and permissible. Charges must be reasonable and

properly justified.

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5.8.1 Accounting for In-kind Costs

The Finance Director/Accountant shall verify with relevant Program Managers or Human

Resources that matching or in-kind contributions are appropriate and/or allowable, how inkind valuations were determined, whether funds are available for hard matches, and from

what source.

The Blackfeet Indian Tribe will obtain the same kind of documentation, to be retained for the

same period of time, as required for incurred costs. To the extent feasible and practical, the

organization will obtain independently generated documentation for in-kind costs: time

sheets or log-in sheets for donated labor, written verification of the value of donated

equipment or space, etc., from the Program Director by the 5th of each month.

5.9 Accounting for Leases

Leases that meet the accounting criteria for capital leases in accordance with Governmental

Accounting Standards Board (GASB) No. 62 are recorded as property, plant, and equipment,

and the related capital lease obligations (the aggregate present value of minimum future lease

payments, excluding executory costs such as taxes, maintenance and insurance) are included in

long-term debt for financial reporting purposes. Depreciation and interest are charged to

expense, and rent payments are treated as payments of long-term debt, accrued interest, and

executory costs. All other leases are accounted for as operating leases, and rent payments are

charged to expense as incurred.

The Tribe will observe rules regarding an operating lease vs. a capital lease, contained in

GASB No. 62. If, according to GASB 62, it is determined that a capital lease exists, a share of

such lease payment will be capitalized and amortized over the life of the lease or the useful life

of the asset, whichever is longer.

In the case of long-term leases, the allowability of costs charged against grants will be based on

current applicable laws and regulations.

The maximum amount of cost recovery on a lease with an affiliated division or subsidiary

under common control will be the amount allowed by the Blackfeet Indian Tribe-retained title.

Thus, only the costs of depreciation, taxes, operations, and maintenance, excluding interest, are

allowable.

For leases with an escalating rental payment schedule, the Blackfeet Indian Tribe will amortize

the total lease payments over the term of the lease on a straight-line basis, to be in conformance

with Statement of Financial Accounting Standard No. 13, as amended.

The Tribe acknowledges that a new standard for the treatment of leases under GASB 87 Leases

will become effective for accounting periods beginning after December 31, 2019. This section

will be updated accordingly for implementation of GASB 87.

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6

RECEIPTS, BANKING, AND DISBURSING

6.1 Purpose and Scope

This section establishes uniform policies to ensure that the funds of the Tribe are appropriately

safeguarded and that all efforts are made to maximize the earnings on such assets. This section

sets forth direction regarding the collection and receipt of funds, accounting of revenues,

disbursements of funds, selection of depositories, and limitations on borrowing.

6.2 Bank Accounts

Bank accounts are authorized by resolution of the Tribal Council of the Blackfeet Indian Tribe

at Federal Deposit Insurance Corporation (FDIC)-insured banks and in accordance with federal

funding agency requirements.

To the maximum extent practical, funds will be maintained in interest-bearing accounts.

In addition to maintaining its accounts in FDIC-insured banks, the Treasurer has taken the

following additional precautions to ensure the security of its funds: (1) negotiating with the

bank to provide collateralization for deposits beyond $250,000 and/or (2) periodically

obtaining and reviewing the credit rating of each financial institution.

All bank accounts will be reconciled on a monthly basis by an employee independent of cash

receipts cycles, and in a timely manner. Supporting documentation must be initialed and dated

by the reviewing employee.

No accounts may be opened with any bank or financial institution in the name of the Tribe or

any of its subordinate organizations or enterprises without the approval of the Council by

resolution. Only the Treasurer can open accounts.

6.3 Online Banking Access

The Blackfeet Indian Tribe grants online banking access with transfer authorization to only a

limited number of key individuals: The Treasurer and the Finance Director/Accountant. The

Treasurer and the Finance Director/Accountant are granted online banking access with upload

and stop payment authorization.

Online bank transfers can be performed by the Treasurer or the Finance Director/Accountant

when the Treasurer is unavailable.

The individual requesting the transfer should receive written confirmation of the transaction

and file this with the Transfer Request Form.

As an additional safeguard, the written confirmation for all transfers will be forwarded to the

Finance Director/Accountant.

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6.4 Returned Checks

For any check included in a bank deposit that is returned to the Tribe because of non-sufficient

funds, there will be a $30 fee charged to the issuer of the check in addition to the fee charged

by the bank.

6.5 Revenue Recognition

All revenues of the Tribe shall be receipted by official Tribal receipt and shall be deposited in

the depository account authorized by Council. The Treasurer shall make provisions to ensure

that all funds are deposited in a timely manner.

Revenue under cost reimbursement-type grants/contracts is recorded as costs are incurred on a

biweekly/monthly basis.

Program revenue (other than grant revenue) is identified by its purpose and then coded to the

appropriate miscellaneous revenue General Ledger code that is attributable to a specific

program.

Non-exchange revenues, sales taxes, and occupancy taxes, are accrued in the period earned

rather than paid.

All grant/contract revenues are properly classified in an appropriate fund because of their

restrictive nature.

Any general fund equity that has restrictions is disclosed in the financial statements.

The Tribe follows the modified accrual method of accounting. Refer to the specific revenue

policy for Tribal enterprises.

Revenues are recorded when earned and in the correct period to follow the matching principle

in GAAP.

6.6 Program Income

Program income is gross income generated directly by a grant-supported activity or earned

only as a result of the grant agreement during the grant period.

If authorized by federal regulation or the grant agreement, costs incidental to the generation of

program income may be deducted from gross income to determine program income.

Depending on the method provided for in the grant agreement, program income will be

deducted from outlays, added to the funds committed to the grant agreement, or used to meet

the cost sharing or matching requirements of the grant agreement.

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6.7 Interest Earned on Advances

Interest earned on advances of funds will go to that specific program as interest revenue. The

Blackfeet Indian Tribe is exempt under the Indian Self-Determination Act from being required

to return interest on advances to the federal government.

6.8 Segregation of Revenues

The Blackfeet Indian Tribe will utilize unique fund codes to separately identify the source of

funds provided for federally funded activities.

6.9 Accounts Receivable

The Revenue Director shall make provisions for the timely collections of all sums owed to the

Tribe and shall maintain accurate and up-to-date records of all accounts receivable. The

Revenue Director shall recommend and shall initiate collection actions as necessary to provide

for the timely collection of all amounts due to the Tribe.

6.10 Accounts Payable

Accounts Payable will be recorded as a liability and an expense when the A/P clerk has all of

the following:

1. Matched the vendor invoice with a purchase order.

2. Receiving report for goods, i.e., packing slip (when available)

3. Verified the clerical accuracy of the invoice.

Comparison of invoice to purchase order: All non-recurring invoices must be compared to the

purchase order with regard to date of acquisition, quantity, type of goods or service, unit cost,

and total cost. If the goods were delivered on reservation, there should not be charges for sales

tax, unless ownership has been transferred prior to delivery.

Entering the expenditure into the accounting system: Once the invoice has been reconciled

with the purchase requisition, it can be entered into the accounting system. Accounts payable

must be careful to enter the proper period and date, fund function, activity code, and Tribal ID

as applicable. The invoice number and date should also be entered, as well as the due date and

any available discounts.

Check issuance: Checks are to be produced daily, or as necessary for emergencies, based on

due dates, allowing for discounts. After review for propriety, checks will be produced. The

checks will be signed only by the Treasurer. Accounting may then separate the checks, deliver

to the program files. The Compliance Specialists attach the backup data to the file copies and

file the documents.

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6.11 Advance Payments and Deferred Revenue

6.11.1 Advance Payments

The Tribe receives payment on some grants/contracts in advance. These revenues are

deferred (liability) and recognized as income in the period in which the related products or

services are delivered.

Revenue will be recognized on a monthly basis, in the amount of expenditures incurred

during the period. At this time, deferred revenue will be reduced.

6.12 Fund Balance

In accordance with GASB No. 54, fund balances will be classified in the following manner:

non-spendable, restricted, committed, assigned, and unassigned. Adjustments to fund balances

will be made only to reflect an adjustment to a prior fiscal year. In this case, a “Prior Year

Adjustment” classification will be used.

6.13 Financing Agreements and Debt Covenants

6.13.1 Debt Covenants

The Blackfeet Indian Tribe will ensure compliance with debt covenants through regular

reporting and monitoring.

The Tribe’s Finance Director/Accountant will oversee the monitoring of all debt covenants

on a quarterly basis. In the event that the Tribe incurs long-term debt, the Finance

Department will prepare a quarterly debt forecast report.

The Treasurer will report on debt covenants to the Tribal Council and/or its Audit Committee

annually. The Treasurer will notify the Council and/or Committee immediately if any

situation arises that would jeopardize the Tribe’s ability to comply with the debt covenants.

6.13.2 Financing Agreements

The Blackfeet Tribal Council must base all financing decisions on accurate and complete

information. The financing team, including staff and professionals involved, is responsible

for ensuring that the terms of a proposed loan are adequately explained to the Tribal Council

so that the Council can make an informed business decision. Ultimately, the Tribal Council is

responsible for making sound decisions, considering business and legal issues, on behalf of

the Blackfeet Indian Tribe.

Leases and rental agreements exceeding terms of $10,000 shall require Council approval.

The Treasurer may approve leasing and rental agreements not exceeding $10,000 provided

that such approvals are reported routinely to Council. The Treasurer shall provide a

comprehensive record of all debts and finance agreements and establish provisions to ensure

the Tribe meets agreement obligations.

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Collateral for finance agreements shall be limited to the assets acquired or leased unless

specifically authorized by the Council. Grant- and contract-funded programs must provide

written permission from the funding agency to utilize property as collateral.

6.14 Travel Costs

For general welfare benefit requests that include travel costs, the Tribe will provide all costs in

advance. Travel must be accomplished in the most efficient and economical manner possible;

mileage costs must be compared with lowest cost airfare. Trip reports and receipts are due

within five business days of return.

6.14.1 Per Diem

When calculating per diem, the General Services Administration (GSA) annual rates for the

metropolitan area will apply. Rates are provided at the GSA website

(https://www.gsa.gov/perdiem).

6.14.2 Lodging

A reservation in the applicant’s name must be provided to receive advance payment for

lodging. Maximum lodging rates as established by the GSA will apply

(https://www.gsa.gov/lodging).

6.14.3 Mileage4

1. Federal Travel Regulations (FTR) as set forth in the Uniform Administrative

Requirements, Cost Principles, and Audit Requirements for Federal Awards. The

maximum mileage reimbursement when utilizing a personal vehicle for travel that can be

charged to a federal grant cannot exceed the lowest possible airfare, which in most

circumstances is a non-refundable economy class airfare. The difference between the

lowest economy class ticket and mileage costs would have to be reimbursed from nonFederal programs when such reimbursement falls within the following guidelines.

2. The allowable GSA per diem reimbursements allowed to be charged to a Federal grant are

determined by the air travel itinerary. This is typically 1 day prior to, and 1 day after the

travel event (i.e., conference, training, etc.). A person desiring to leave several days prior

to the travel event or return several days after would not be allowed to claim lodging or

meal reimbursements for the additional travel time that is deemed unnecessary to attend the

travel event based on the air travel itinerary.

3. Mileage cost reimbursement in excess of the lowest economy fare is permitted when travel

by airline would:

4 Resolution No. 130-2024, “Amending the Plan of Operations Chapter 6 Finance and Procurement Policies

(2018) Updating Travel Policies Regarding Mileage and Airline Costs” November 2, 2023

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a.

b.

c.

d.

e.

Require circuitous routing,

Require travel during unreasonable hours,

Excessively prolong travel,

Result in additional costs that would offset the transportation savings, or

Offer accommodations not adequate for the traveler’s medical needs.

4. Travelers shall document the reason for requesting an exception to the general rule (i.e.,

lowest cost airfare) based on those situations cited above in #3 AND requesting

permission from the funding agency, in advance of the Travel Request or the Trip

Report-reimbursement request.

5. Approved advanced travel for a personal vehicle shall include the mileage to the airline

and costs in parking the vehicle while on travel.

6. Travelers utilizing a tribal fleet car shall not be entitled to mileage reimbursement and

shall be provided with costs to cover gas only.

7. Reimbursement. The total amount of reimbursement pursuant to this section will be

subject to the exact amount displayed upon the receipt(s) of the allowable expenditure.

(example of non-allowable: Ball game receipts to cover fuel)

Mileage will be reimbursed at the current year IRS standard rate (https://www.irs.gov/taxprofessionals/standard-mileage-rates). Members must provide beginning and ending

odometer mileage and starting and ending addresses to the Accounting Department within 30

days of the event to receive reimbursement.

6.14.4 Airfare

Coach class airfare will be reimbursed within 30 days of purchase with a receipt in the

applicant’s name.

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7

PROCUREMENT

7.1 Purpose and Scope

Procurement involves the process of selecting vendors, establishing payment terms, strategic

vetting, selection, the negotiation of contracts and actual purchasing of goods and services.

Procurement is concerned with acquiring (procuring) all of the goods, services, and work that

is vital to the Tribe. The term procurement as used in this policy includes both contracts and

modifications, including change orders.

This section establishes uniform policies and standards for the acquisition of goods and

services by all Tribal programs. Purchasing authority is designated to the Procurement

Department for all goods and services in addition to contracts and the bid/vendor process, and

compliance is the responsibility of the Finance Department for budgets, allowable costs, and

general cost principles.

All goods and services are purchased by Program Directors within departments, with oversight

from the Blackfeet Indian Tribe’s Finance Compliance Specialists. Designated buyer must be

approved by their direct supervisor or Director.

It is the policy of the Blackfeet Indian Tribe to:

1. Ensure that all purchase or contract actions are justifiable. All purchases must support

legitimate Tribal or Tribal Program objectives. The Tribe will only buy items or services

that meet its actual, minimum requirements. Unnecessary or duplicative buying will be

avoided.

2. Ensure that purchasing and contracting actions will be based on competition whenever

feasible and practical. Obtaining adequate competition among suppliers is the best way of

ensuring that the prices the Tribe pays are reasonable.

3. Ensure that all purchasing and contracting actions are accurately documented in writing.

Documentation enables the Tribe to meet the accountability requirements of the federal

agencies from whom it obtains funds. It also provides a historical record that will help the

Tribe make efficient and economical purchases in the future.

4. Ensure that Tribal purchasing and contracting efforts reflect a preference for Indian-owned

and operated businesses whenever possible.

5. Ensure that federal government sources of supply will be considered when feasible. Such

sources may be used whenever they offer the Tribe the best available price and the ability

to meet the Tribe’s technical and delivery requirements.

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7.1.1 Non-compliance Statement

This Procurement policy must be adhered to, completely, at all times. Failure to comply and

intentional violations of Finance and Procurement policies will result in disciplinary action to

be determined by the Personnel Department, up to and including termination and criminal

prosecution.

7.1.2 Amending the Procurement Policy

This policy contains the essential procurement policies of the Blackfeet Indian Tribe. As

additional matters require promulgation or changes to this policy are appropriate,

amendments may be made with the approval of the Tribal Council.

7.2 Procurement Ethics

This policy serves to supplement existing policies relating to Code of Ethics (See Fiscal Policy

2.2), Conflict of Interest (See Fiscal Policy 2.3), and Financial Misconduct (Fiscal Policy 2.4).

This policy and the Fiscal Policy Code of Ethics, Conflict of Interest and Financial Misconduct

satisfy the requirement of 2 CFR 200.318 (c)(1).

Maintaining the integrity of the Blackfeet Indian Tribe’s procurement process is of paramount

importance; therefore, any person disseminating procurement information to persons who do

not have a bona fide need to know, within or outside of the Tribe, are in violation of this trust

and subject to dismissal or disciplinary action to be determined by the Personnel Department.

Association with supplier representatives at luncheon, dinner, or business organization

meetings is helpful in establishing better business understanding and is neither questionable

nor unethical provided the Tribe keeps free of obligation. If a Tribal representative is unsure of

the ethics of an interaction, he or she should inform their direct supervisor.

Tribal Council, Program Directors, and staff must ensure conformity to this policy by insisting

on compliance by their subordinates.

Designated buyers shall do the following:

1. Apply sound business principles and procedures to all procurement actions and ensure that

their business methods are above reproach and the hint of suspicion.

2. Avoid any action or circumstances, such as a gratuity (a payment or gift to obtain favorable

treatment or influence an award), family relationship, or financial interest, that might

conflict with the proper performance of their duties or compromise the organization’s

acquisition process, and ensure that their conduct at all times is in a manner that maintains

trust and confidence in the integrity of the procurement process.

3. Conduct business ethically and in a manner above reproach and, except as authorized by

statute or regulation, with total impartiality and preferential treatment for none. As a

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government grantee, all transactions relating to the expenditure of public funds require the

highest degree of public trust, confidence, and impeccable standards of conduct.

4. Refer questions to their direct supervisor.

5. Sign a statement to the effect that they recognize, understand, and accept the

aforementioned code.

7.3 Designated Buyer

This section establishes the Procurement requirements in regard to the designated buyer and

their authority.

1. All Program Directors are designated buyers for the Procurement Program, including but

not limited to the purchase order process as well as the warehouse purchasing.

2. All Program Directors must establish alternative designated buyers within their program.

There must be two (2) alternative designated buyers for each program providing there is

adequate staff. A designated buyer form can be completed at procurement and must have

the signatures of the program director and the designated buyers before any purchase can

be completed.

3. For all procurement processes, with the exception of warehouse, a designated buyer must

have a memo stating the program director is not available and the signature authority has

been assigned to the designated buyer during the time of absence.

7.4 Requisition

This section establishes the uniform process for all Tribal programs to use a purchase order and

a purchasing requisition for special purchases from the vendors including but not limited to:

Sam’s Club, All Nations, and Staples. When purchasing from these vendors the designated

buyer will fill out a requisition and a purchase order with the Director and Compliance Monitor

signature authorizing purchase. The purchasing requisition will be brought to the Procurement

Department with a cover sheet attached showing the designated buyer and when the purchase

will occur. The cover sheet will also be signed by the Warehouse Manager or designated

signatory authority. The credit cards for these vendors are managed by the Procurement

Department.

1. The purchase order form and the purchase requisition form are designed to contain all the

necessary information and signatures for processing purchases.

2. All purchase requisitions for special purchases will be processed on a Purchase Order by

the Warehouse Manager only after invoice/receipt are received by the Procurement

Department and as soon as possible to avoid any late charges or holds from the vendors.

Purchase Orders will be processed for payment through MIP/Abila in Finance.

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After the check is processed, the Warehouse Manager will mail the check to the vendor.

All purchase orders must be submitted at least 15 calendar days before fiscal year-end or at

least 15 calendar days before the end of the grant year of the funding source, if different than

September 30. Purchase orders submitted less than 15 days before year-end are intended for

emergencies and must be approved by Director and the Treasurer. This policy ensures that all

requisitions are processed, and goods/services are procured in the current year and expedites

the year-end closing process.

7.4.1 Simplified Purchases5

Simplified purchasing procedures are procedures not requiring formal bidding procedures or

formal proposals and may be used for procurements under $250,000 as follows:

1. Procurements of up to $10,000 may be awarded on the basis of verbal quotations without

competition. Verbal quotations must be documented by the purchaser.

2. Procurements of $10,001 to $25,000 may be awarded on the basis of competitive

quotations provided verbally to the awarding official. Verbal quotations must be

documented by the purchaser.

3. Procurements of $25,001 to $250,000 may be awarded on the basis of competitive

quotations provided in writing to the awarding official.

Lowest price is not required to be the deciding factor in selecting the awardee for simplified

procurements. Any other factors that are reasonable and prudent under the circumstances may

be considered, including but not limited to preference, ability to warranty work, and past

performance. Support for these factors should be documented.

The Tribe operates under the guidelines of 2 CFR 200. Updates by the federal government to

the amounts listed above occur at various times and may result in outdated amounts in this

policy. The guidelines in 2 CFR 200 should be consulted and questions should be directed to

the Procurement Department or Compliance Specialist. Amendments to this policy will be

made as required and approved by the Tribal Council.

7.5 Requesting Bids and Quotations

Competitive bidding is employed to ensure responsive, reasonable, and firm proposals.

Generally, three or more qualified suppliers will be solicited. Exceptions are made only in the

event such bidding process would result in no apparent benefit to the Blackfeet Indian Tribe

and when approved by the Finance Director/Accountant and relevant Director, or the Tribal

Council.

5 Resolution No. 253-2023 “Amending the Plan of Operations Chapter 6 Finance and Procurement Policies

(2018) Updating Simplified Purchases Threshold” February 2, 2023

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The designated buyer is responsible for obtaining quotations from vendors for both estimating

purposes and purchasing. A requestor may obtain quotations for estimating purposes as long as

the query does not commit the Tribe to the purchase. Cost estimates will be appropriately

safeguarded and will not be disclosed to any bidder. Only the department or program

requesting the bid should use the cost estimate to conduct a cost analysis of the responses

received for the procurement.

This procedure outlines the process of securing written quotations prior to selection of a

source.

Requests for written quotations will be communicated to qualified vendors verbally or in

writing. Complete information should be provided to vendors including but not limited to:

quantity, description, delivery requirements, special conditions, drawings, specifications,

freight costs, payment terms, etc.

For procurements in excess of $25,001, public notice of the invitation for bids is given at least

once a week for two consecutive weeks not less than 7 days before 21 days prior to bid

opening date for preparation and submission of bids and proposals: and notice of contract

award is made available.

The designated buyer must be thorough and attempt to eliminate all known variables to assist

the vendor in accurate quotations.

The designated buyer, when purchasing materials and/or services requiring written requests for

quotation, will solicit prices from three or more vendors. In the case of some proprietary/sole

source items, more than one price is occasionally not possible and should be noted on the

purchasing file documentation in the Justification section of the Purchase Requisition. Sole

source purchases must be approved by the Procurement Director, Compliance Monitor, and

relevant Director, or the Tribal Council.

Quotations will only be solicited from vendors that the designated buyer knows are qualified to

meet all the requirements.

The requester should provide answers to technical questions arising during the quotation

period. The designated buyer should coordinate the reply and ensure all potential suppliers are

provided the same information.

After all quotations have been received and examined for completeness, copies of bids will be

attached to the purchase order. On most occasions, determination of the most qualified bidder

and award of the order will be made by the designated buyer only after all aspects, including

the preference of the requester, have been considered. The Tribe, whenever reasonable, will

select the lowest bidder. Exceptions must be documented by the Program Director and

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approved by the Compliance Monitor. The information gathered will be kept with the purchase

order as backup documentation.

The designated buyer will not reveal to a vendor at any time the specific prices quoted by

another vendor.

6

For construction or facility improvement contracts or sub contracts exceeding the Federal

Simplified Acquisition Threshold, the Federal awarding agency or pass-through entity may

accept the bonding policy and requirements of the non-Federal entity provided that the Federal

awarding agency or pass-through entity has made a determination that the Federal interest is

adequately protected. If such a determination has not been made, the minimum requirements

must be as follows:

(a) A bid guarantee from each bidder equivalent to five percent of the bid price. The “bid

guarantee” must consist of a firm commitment such as a bid bond, certified check, or other

negotiable instrument accompanying a bid as assurance that the bidder will, upon acceptance

of the bid, execute such contractual documents as may be required within the time specified.

(b) A performance bond on the part of the contractor for 100 percent of the contract price. A

“performance bond” is one executed in connection with a contract to secure fulfillment of all

the contractor's obligations under such contract.

(c) A payment bond on the part of the contractor for 100 percent of the contract price. A

“payment bond” is one executed in connection with a contract to assure payment as required by

law of all persons supplying labor and material in the execution of the work provided for in

the contract.

For purposes of this part, the Simplified Acquisition Threshold is $150,000. This amount may

also be adjusted by the Federal Government according to inflation rates from time to time.

Blackfeet Tribal Procurement shall post federal adjusted rates when such adjustment occurs.

7.6 Competition

Open competition has long been recognized as one of the best protectors of a healthy and

equitable purchasing system. It is the aim of the Blackfeet Indian Tribe to use competition

whenever possible to secure sound value and to guard against favoritism and profiteering at the

Tribe’s expense.

The Blackfeet Indian Tribe purchasing and procurement policies require, wherever practical,

the solicitation of at least three responses when the dollar value per requisition or request totals

$10,001 or more.

6 Resolution No. 95-2020, “Updating the 2018 Blackfeet Finance and Procurement Policies (2018) to Clarify

Bonding Requirements” January 16, 2020

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7.6.1 General Competitive Sourcing

The established criteria require that competition shall be used to the maximum practical

extent. This rule is soundly based on the premise that competition is the known and most

reliable method of achieving fair and reasonable prices on items with the same quality.

Therefore, the designated buyer should, at every opportunity, strive to introduce competition

in the procurement process, making a serious endeavor to compete all items whenever

feasible. The Finance Compliance Monitor should carefully review contemplated single/sole

source procurement to ensure the validity of proposed justification, and to recommend

development of alternate sources of supply whenever circumstances permit.

7.6.2 Non-competitive Procurement

It is the policy of the Blackfeet Indian Tribe that procurement shall be conducted

competitively to the maximum extent possible. Procurement by sole source may be used only

when the award of a contract is not feasible using competitive proposals, and at least one of

the following circumstances applies:

Only one source of supply is available, as certified in writing by the relevant Director or

Program Director

After solicitation of a number of sources, competition is determined inadequate, as

certified in writing by the relevant Director or Program Director

An emergency exists that seriously threatens the public health, welfare, or safety of the

Tribe, or endangers Tribal property, or would otherwise cause serious injury to the Tribe.

Emergencies could arise by reason of flood, fire, earthquake, epidemic, major equipment

failure, etc. In such cases, there must be an immediate and serious need for supplies or

services such that the need cannot be met through standard procurement methods. The

emergency procurement shall be limited to those supplies or services necessary to meet

the emergency.

The Tribal Council has approved an ongoing contractual relationship, such as with

established legal counsel. Ongoing contracts for supplies or services shall be evaluated by

the relevant Director on an annual basis for adequacy of services rendered, and

competitive solicitations shall be issued at least every three years.

When a third party’s funds are used, authorization of the third party is required for using sole

source.

Copy of sole source justification and any required outside approvals will be attached to the

approved contract.

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7.6.2.1 Sole Source Award Policy

A. Sole source awards are awards issued without competition, through solicitation of a

proposal from only one source, or after solicitation of a number of sources, competition is

determined inappropriate for the procurement action. The use of sole source awards is

authorized when:

1. The item is only available from a single source;

2. The public exigency or emergency for the required goods or services will not permit a

delay resulting from competitive solicitation;

3. The awarding agency authorizes noncompetitive proposals;

4. The Council has approved an ongoing relationship, such as with established Legal

Counsel, having important knowledge and history regarding the Tribal businesses

where use of federal funds is not a factor; or

5. After solicitation of a number of sources, competition is considered inadequate.

B. When issuing sole source, proposed costs and rates shall be specified in advance and

analysis to ensure that costs and rates are fair and reasonable is required.

C. When a third party’s funds are used, authorization of the third party is required for using

sole source.

D. The Procurement Director shall have the authority to approve sole source awards up to

$100,000 when the circumstances dictate, with concurrence of the Treasurer, and it is in

the best economic interest of the Tribe to do so, except when applicable laws or

regulations dictate a lower level. Other awarding officials may award up to $5,000 sole

source without approval of the Procurement Director, provided that such limit is within

written procurement delegation.

SOLE SOURCE RESOLUTIONS ATTACHMENTS MUST INCLUDE:

1. SCOPE OF WORK WITH THE FOLLOWING:

a. Justification that competition is determined inappropriate as per A above.

b. Eligibility of the proposed sole source meets (one of) 1-5 of A above.

c. The proposed sole source’s proposed costs and rates as fair and reasonable per B

above.

d. Signed approval from Procurement Director and Treasurer (usually the

professional services contract issued from Procurement)

2. If the funding is from a third party, approval from that third-party authority-or indication

of approval upon BTBC resolution. Example is 638 funds-the approval authority would

come from the 638 AOTR. For state or federal grant programs-the grant manager.

3. If funded by a third party-include contract.

KEEP IN MIND:

*Third party funding sources have specific requirements, please consult with Procurement or

Legal Departments if there are any questions.

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*Procurement establishes tribal preference in projects when bidding is used and not sole

source.

*Further, in the Procurement policies if a serious situation arises affecting the best interests

of the Tribe, the BTBC may waive the Procurement policies upon appropriate justification.

This is in rare events.

*Since sole source contracting is an alternative authority to personnel policies of the Tribe,

sole source contracts are monitored by the funding authority in accordance with this policy

which requires resolution by the BTBC and third-party approvals.

*Independent contractors are responsible for providing:

1. Business license with the Tribe

2. Appropriate Certifications

3. Appropriate Insurance

4. Workman’s Comp

5. In federal contracts, Davis-Bacon wages

6. Any other assurances by the contractor, that the sole source objectives will be met.

7.7 Vendor Selection

The selection of vendors is generally the responsibility of the designated buyer and requires

consideration of several factors. Whenever possible, identification of brand names, item/mfg.

numbers, and sufficient detail should be provided to ensure that the request could be correctly

completed in an efficient manner.

The designated buyer should endeavor to place orders with regard to the quality, cost, and

service record of the vendor. Preference should be given to the following types of vendors,

providing this involves no sacrifice in quality, service, or price:

1. Blackfeet Indian Tribe member-owned suppliers are given preference up to 5% above the

cost of other vendors.

2. Native-owned suppliers are given preference up to 3% above the cost of other vendors.

3. Suppliers who are developing new and improved products or equipment or designing a

special product for the Blackfeet Indian Tribe.

4. Suppliers with adequate financial strength who also have a reputation for adhering to

specifications and deliveries.

5. Locally owned and operated suppliers.

Vendors for some routinely purchased goods or services, such as office supplies or plumbing

services, may be identified through an annual pre-qualification process. The designated buyer

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shall invite vendors to participate through an RFP process and develop a pre-qualified vendor

list utilizing the Tribe’s vendor selection criteria.

The Blackfeet Indian Tribe is committed to a policy of full and open competition. In

circumstances other than non-competitive procurements, the designated buyer will obtain at

least the following number of bidders/offers:

1. Procurements of up to $10,000 may be awarded on the basis of verbal quotations without

competition.

2. Procurements of $10,001 to $25,000 may be awarded on the basis of competitive

quotations provided verbally to the awarding official.

3. Procurements of $25,001 to $250,000 may be awarded on the basis of competitive

quotations provided in writing to the awarding official.

Formal advertising for over $250,000.00, excluding single item vehicle purchases (i.e., dump

trucks, construction equipment, etc.). All formal advertisements, bid package preparations, bid

receipts, bid selection, awards, and all other associated activities for purchases over $250,000

will be handled exclusively by the Finance Department.

The amounts in this section follow the same rules as noted under Simplified Purchases above

in regard to the requirements of 2 CFR 200.

The sole exception to this policy is purchases made by the Tribal Council utilizing non-grant

funding.

7.7.1 Tribal Preference

In the acquisition of goods and services, preference shall be afforded to businesses owned by

Tribal Members who have the ability to perform services and/or deliver goods at the level of

quality and quantity required and within required timeframes.

Bidding preference shall be afforded businesses owned and operated by enrolled members of

the Tribe, or by non-enrolled Indian businesses that are resident on the Blackfeet

Reservation, when the goods and services to be acquired can be specified in sufficient detail

to make price the deciding factor in selection. In this event, all prospective bidders shall be

put on notice in the bidding process of the preference policy, and bid preference shall be

administered as follows:

1. Preference shall be given first to 100% Blackfeet owned businesses, second to 51% or

more Blackfeet owned businesses, and third to other Indian businesses resident on the

reservation.

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2. Contracts shall be awarded under preference to a qualified business when its bid is

responsive to all other conditions and does not exceed the lowest bid by the following

percentages, when the lowest bid is:

a. Between $0 and $10,000: 15%

b. Between $10,001 and $50,000: 10%

c. Between $50,001 and $100,000: 5%

d. $100,001or more: 2%

7.7.1.1 For procurements involving construction projects:

For single item vehicle purchases, i.e. dump trucks, construction equipment, in any amount,

written solicitations will be sent out to a number of pre-qualified vendors along with a scope

of work or itemization of project to be completed.

For procurements involving construction services with an overall total, including materials

and/or goods, in an amount of $250,000 or greater, solicitations will be performed in

coordination with the Finance Department.

Construction projects over $2,000 will abide by the Davis Bacon Act. Contracts with

contractors will include prevailing wage clauses. The Program Director will insure that all

certified payrolls are obtained and maintained and that any week in which no wages are paid,

a signed statement to that effect will be obtained. In addition, any subcontractors will also

abide by the requirements set out by the construction contract and will be required to submit

to management their weekly certified payrolls.

7.7.1.2 For procurements utilizing General Services Administration (GSA) providers for

goods and services:

All ordering for purchases or leases must be submitted at least 90 calendar days before yearend or at least 90 calendar days before the end of the fiscal year of the funding source, if

different than September 30.

7.8 Vendor Information

7.8.1 New Vendors

The Finance Department shall maintain vendor file information in the AP system for all new

vendors, noting any related parties.

The Procurement Director shall collect completed W-9 forms or equivalent forms from new

vendors. All new vendors and the vendor file information must be approved by the

Procurement Director prior to any purchasing commitment.

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7.8.2 Vendor List

On an ongoing basis, the Procurement Department shall maintain an Approved Vendor List

with vendors who meet all requirements. Vendors will be checked in compliance with the

Uniform Guidance regulations for suspension and debarment at least annually and

documented by the personnel doing the search and dated. The Procurement Department shall

also maintain a consolidated master vendor list to include both active and inactive vendors.

The list will be regularly updated (i.e., new vendors added and old vendors—who have gone

out of business, been debarred, changed commodities, or deemed not responsible—deleted).

7.9 Purchase Orders

This section establishes the uniform process for all Tribal programs in the use of a purchase

order.

This procedure defines the requirement for purchase orders to be approved through the

Purchase Module and/or in writing (when applicable), PRIOR to the establishment of a firm

order or contract. The designated buyer is responsible for ensuring that the appropriate

approval for each purchase has been obtained. All relevant approvals must be obtained prior to

placing orders. Any employee who commits Tribal resources without the appropriate

procurement approvals will be in violation of this policy and commitments/invoices/orders will

become the responsibility of the employee and will not be reimbursed or otherwise paid.

7.9.1 Purchase Order Preparation

A system of authorization and approval is an important element of internal control. The

Purchase Order Form must be complete prior to forwarding to the Procurement and Finance

Department.

Each purchase order form is designed to contain all necessary information and signatures

needed to process the purchase for the Blackfeet Indian Tribe. The purchase order form is

submitted by the designated buyer to the Finance Compliance Monitor to review for proper

approval, determine if funds are available, and determine compliance with regulatory

requirements before signing and readying for the next step. All purchases over $10,000

require signatures of Tribal Council Chair and Tribal Council Secretary.

Each purchase order must be reviewed by the Procurement Data Processor for completeness.

The requisition is then processed by the Procurement Data Processor, who assigns a purchase

order Number and informs the designated buyer that they may order the items. Purchase

order numbers will be assigned in numerical sequence and will be carefully controlled to

avoid misuse.

Receipt of original invoices signal the purchase order processing step. The original purchase

order form will be filed in the Procurement Department along with any pertinent supporting

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documentation, including original invoices, as noted in section 7.11. Statements or quotes are

not acceptable documents to process a purchase order.

7.9.2 Purchase Terms and Conditions

The Blackfeet Indian Tribe’s Standard Terms and Conditions provide the basic terms and

conditions for all purchases of goods and services. Additional mandatory clauses shall be

added to terms and conditions as required by purchase type.

7.10 Outstanding Purchase Orders

In order to prevent overpayment of contracts and the inability to adhere to grant limits, the

Procurement Department shall monitor outstanding purchase orders. As part of monthly

reporting, the Procurement Data Processor will prepare reports listing outstanding purchase

orders. Purchase orders found to be submitted with inadequate authorizations or supporting

documentation will be returned to the applicable Compliance Monitor or Program Director for

correction.

The Directors and Compliance Monitors must review these reports on a monthly basis to

ensure adherence to grant limits. The Program Director and Compliance Monitor will work to

close out open purchase orders by the end of the close-out period.

7.11 Procurement Records

All purchasing records are maintained by the Procurement Department. Every procurement file

should contain, at a minimum, key documents reflecting compliance with the existing policies

and procedures. It should also contain documents showing deviations and justifications for

such deviations.

Exceptions to this file plan shall be noted and documented as necessary but should only apply

to the specific sections of this plan. In no event shall the file plan be supplemented by another

version unless so mandated by the Procurement Director or Treasurer. In cases where a file

plan requirement is not applicable to a particular procurement, it should be noted. In cases

where a requirement is valid and the document or appropriate response cannot be obtained, a

memo or other written notation should be entered in the file.

Any desired variations to the plan must be approved by the Procurement Director and

Treasurer prior to implementation.

Periodic reviews (audits) shall be conducted of procurement files and where necessary shall

provide for action to adhere to the approved file plan.

7.12 Payment

Payments for goods will only be made after all required documentation and approvals have

been obtained as well as any required quotes or price checks. All documentation will be

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provided and attached to the check presented for signature. All documentation and approvals

will be retained with the paid invoice as set out in the retention policy.

Payment for goods and services should be made only when funds are available for use. All

purchases will be in compliance with the procurement policies defined in Section 7.

All federal funds expended shall be in compliance with the following: Uniform Administrative

Requirements, Cost Principles, and Audit Requirement for Federal Awards (2 CFR Chapter I,

Chapter II, Part 200, et al.) as well as OMB Circulars A-21, A-87, A-89, A-102, A-110, A-122,

and A-133.

7.13 Receipt of Goods

Delivered goods should be immediately compared with the packing slip and purchase

requisition and/or purchase order and initialed by personnel who physically receive the goods.

If there are any discrepancies regarding the delivery, it should be noted on the packing slip.

The discrepancy should then be pointed out to the Director/Manager, and the adjusted packing

slip sent to Tribal Procurement.

Payment will be made only for goods ordered and received. The designated buyer will place

the packing slip in a pending file until the invoice is received. Upon receipt of the invoice, it

will be compared to the adjusted packing slip for propriety. Notice will be given to the

Accounting Manager and the vendor of any discrepancy between the invoice and adjusted

packing slip.

7.14 Contractual Agreements

Contracts may be used for the provision of goods, services, and professional services.

Professional services are those that require specialized intellectual, educational, or creative

expertise. Professional services for auditing, architectural design, legal services and

construction project management require a contract at any dollar amount. Construction

professional services are those that require architecture/engineering (A & E) services,

construction consulting, construction and material testing, or construction expertise. When

contracts are necessary between the Tribe and outside companies or persons, the following

procedures must be followed:

1. Procurement policies and procedures will be followed in compliance with the Tribe’s

Procurement policy and Uniform Guidance guidelines to find the most cost-effective

contractor or consultant and to comply with the regulations as set out in the Uniform

Guidance.

2. Technical requirements must be specifically identified.

3. The Legal Department will be consulted for contract review.

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All contracts and modifications are in writing and clearly specify the desired supplies, services,

or construction to be received. Care shall be taken in developing appropriate specifications for

procurements, to ensure that the Tribe receives what it pays for, and that what it receives is

consistent with what is needed.

All contracts and modifications must state the length of the contract, the Terms of payment,

and remedy for non-performance.

The contract should be recommended to the Tribal Council by the designated Director if over

$10,001.

The contract must be approved with signature by the Tribal Council if it is over $10,001; the

Tribal Chairperson or relevant Director will sign the contract if approved.

Copies of the contract should be provided to the respective department Director/Manager, and

to the Finance Department, with the original to be filed in the Procurement Department.

The designated buyer should request a certificate of insurance, if necessary, from the

contractor/consultant, which should be forwarded to the Procurement Department for filing

with the contract.

Progress payments or invoices must be approved by the designated buyer and Compliance

Monitor and then forwarded to the Finance Department, which will follow

procurement/purchasing procedures for payment of billings.

Contracts shall not be awarded to, nor purchase orders entered into, with debarred, suspended,

or ineligible vendors.

Procurement using federal funds requires that vendors be checked at the Excluded Parties List

System website (https://www.epls.gov/)

7.14.1 Approval Requirements

Once quotes are received and a Quotation Analysis Form has been completed to show the

total cost involved, the requisition will be forwarded to designated approval signatories for

their agreement to the acquisition.

The Council reserves the right to approve the following items, adhering to standard

procurement protocol:

1. Selection and engagement of Legal counsel.

2. Selection and engagement of independent auditors.

3. Selection and engagement of other professional advisors to the Council for which an

ongoing relationship is anticipated.

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7.14.2 Routing Procedures for Related Parties

The Finance Department will provide a special routing procedure for any request that must

be approved by related parties. Related parties are excluded from authorizing purchases

regardless of approval level. Any Tribal employee that fails to declare a relationship and

approves a procurement request will be subject to disciplinary action. For the purposes of this

policy, a relative is defined as:

Mother

Brother

In-Law

Father

Child

Grandparent

Sister

Spouse

Member of the same

household

7.15 Suspension and Debarment

Vendors may be suspended, debarred, or determined ineligible by the Tribe when necessary to

protect the Tribe in its business dealings. The Tribe may suspend or debar a vendor under

applicable law. To ensure potential vendors were not suspended or debarred, as required under

2 CFR 180, the Blackfeet Indian Tribe will require all vendors with accumulated contract

values over $25,000 to include a suspension and debarment certification.

7.16 Additional Prohibitions

7.16.1 Personal Tools and Equipment

It is the policy of the Blackfeet Indian Tribe to purchase or lease the equipment and materials

necessary for an employee to perform assigned job responsibilities. The use of personal or

non-Tribal property or equipment to perform any task(s) is prohibited. Such equipment uses

and any associated labor costs may not be charged to the Tribe. Supervisors shall not

authorize the use of personal equipment to perform job-related tasks under any

circumstances.

7.16.2 Contracts with Employees Prohibited

The Blackfeet Indian Tribe will not enter into any contract with an employee-owned business

or partnership for the performance of work under any circumstances. For this purpose, an

employee-owned business or partnership is defined as any venture where the employee holds

an ownership share or a financial interest that could pose a potential conflict of interest.

Any work that must be performed for the benefit of the Tribe that falls outside the normal

scope of work performed by Tribal employees shall be contracted out following the approved

contracting procedures. Any work performed in violation of this policy shall not be charged

to the Tribe and will not be reimbursed or otherwise paid.

7.17 Use of Tribal Assets

No employee may use any property, vehicles, equipment, material, or supplies for personal

use. No loans of any kind will be made to any employee, including loans of cash on hand.

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7.18 Use of Tribal Credit and Fuel Cards

Corporate credit cards may be assigned to employees with a demonstrated need. All credit

cards must be approved by the Finance Director/Accountant and Treasurer before issuance. In

general, cards shall be limited to employees in the following job classifications:

1. Director

2. Officer

Corporate fuel cards are assigned to specific programs, vehicles, and equipment.

Upon card issuance, cardholders will be required to sign a statement agreeing to acceptable use

for Tribal business purposes only. Cardholders shall report the loss or theft of a corporate

credit or fuel card immediately to the credit card company and the Finance

Director/Accountant.

Purchases for personal and unauthorized Tribal use are strictly prohibited. Violations will

result in a 50% processing fee on the items charged in addition to the cost of the items charged

and must be paid in full within 5 days of receipt of the credit card monthly invoice, or the

amount will be deducted from the employee’s next payroll check. A second violation will

result in the Tribal credit card being terminated. All travel for Tribal purposes must adhere to

the Tribe’s travel policy.

All receipts and proper support for purchases will be turned into the accounting department for

reconciliation to the credit cards statement at least monthly.

If an employee uses a Tribal vehicle for travel and the funding program allows for the use of

the Tribal fuel card, mileage will not be issued. If a fuel card is not allowable, full mileage for

the trip will be reimbursed. Fuel receipts must be provided to the Purchasing Department, and

the cost differential between the standard IRS mileage reimbursement rate and fuel purchases

will be reimbursed to the program budget.

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8

PROPERTY MANAGEMENT

8.1 Purpose and Scope

This section establishes standardized policies and procedures for the utilization, accountability,

control, and disposal of all Tribally owned, rented, and leased personal property. For the

purpose of this policy, personal property includes all capital equipment and small equipment

(i.e., cameras and electronics) considered sensitive and susceptible to misappropriation or loss.

The provisions of 2 CFR 200.311 as it pertains to property management, are hereby

incorporated within this policy by reference.

8.2 Acquisition of Property

All purchased equipment and personal property shall be acquired through a written purchase

order and shall be added to a property inventory at the time of acquisition by the Asset

Manager or his/her designee.

The Asset Manager shall oversee the acquisition of federal excess and surplus property that

may be available and of the value of its use by the Tribe. Such property shall be treated as

Tribal property and subject to this policy upon receipt. Excess and surplus property shall be

assigned to the department or program considered most appropriate by the Asset Manager in

consultation with the Procurement Director. Likewise, some property is purchased for the

specific use of donation to program clients. Such property shall be recorded and tagged

consistent with Section 8.5 prior to assignment.

The management and safeguarding of property shall be the responsibility of the relevant

Property Custodian. In general, the Property Custodian shall be the supervisor or director of the

using department or may be an individual employee with respect to assigned property, as

assigned by a Director.

8.2.1 Grantee-Acquired Property Equipment

The Tribe will maintain detailed records of all government-furnished property and granteeacquired equipment on government grants, segregate such property and equipment, ensure its

maintenance and disposal, not use it on any commercial activities, and exclude it from its

insurance coverage.

8.3 Title of Lien-Interest to Acquired Property with Federal Funds

A lien-interest in all equipment with a unit acquisition cost of $5,000 and material or property

acquired as a direct cost with funds granted by the awarding agency will vest with the

awarding agency during the duration of the grant. Upon termination of such a grant, the grantee

(Tribe) may arrange for acquisition of such equipment or property at a fair and reasonable

price, seek temporary custody of such equipment or property if service will be continued with

other funding, or make arrangements for a duly authorized representative of the granting

agency to obtain custody.

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8.4 Donated Property or Equipment

Donated assets that, at the time of receipt, meet the Tribe’s criteria for capitalization will be

capitalized at their fair or appraised value.

8.5 Property Identification, Records, and Inventory

Upon receipt, the Blackfeet Indian Tribe will tag all equipment and will record assigned

numbers on all applicable documents pertaining to the property control system. Granteeacquired property will be identified as such on the tag and recorded with the appropriate

notation in the fixed asset subledger.

Property records will be maintained that include:

1. A description of the property

2. A serial number or other identification number

3. The acquisition date

4. The cost of the property

5. Estimated value

6. Percent of federal participation in the cost of the property

7. The location

8. Use and condition of the property

9. Title holder, if leased or rented

10. Any ultimate disposition date, including the date of disposal and sale price of the

property.

8.5.1 Sensitive Items

Sensitive items include all items, regardless of value, which require special control and

accountability due to unusual rates of loss, theft or misuse, or due to national security or

export control considerations. Such property includes weapons, ammunition, explosives,

information technology equipment with memory capability, cameras, and communications

equipment.

The following provides an example list of sensitive items:

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Finance Policies and Procedures

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Category

Multi-functional

Office Equipment

Minimum Acquisition

Threshold

$200.00

Computers

No minimum acquisition cost

Personal digital assistance

with PC Connectivity

Portable hard drives

No minimum acquisition cost

Example assets

Computer and video

projectors, fax machines,

copiers, scanners, etc.

PCs, servers, laptops, and

micro-mini laptops

Palm pilot, Blackberry

No minimum acquisition cost

Does not include smart cards,

USB memory sticks, or other

devices classified as “media”

Power tools

$200.00

Portable compressors,

generators, table saws

Video recorders/players

$200.00

Video (VCR), tape, dictation

machines, CD, DVD, and

audio tape

Portable instrumentation

$200.00

Voltmeters, o-scopes, watt

meters

Hazardous materials

No minimum acquisition cost Radioactive, chemical, nuclear

materials and reagents listed in

40 CFR part 261

Cameras

$200.00

Digital, laparoscopic, x-ray,

video cameras not including

surveillance equipment

Weapons

No minimum acquisition cost Firearms, knives, etc.

Precious metals (or equipment No minimum acquisition cost Gold, silver, platinum. Does

made of same)

not include items that contain

small or trace amounts of

precious metals such as circuit

boards.

The Tribe will conduct a physical inventory of all government and Tribal-owned property

valued over $200 in its possession or control, on at least an annual basis. Personnel

performing the physical inventory will not be the same individuals who maintain the property

records or have custody of the property unless other staff are unavailable to perform the

inventory count. Each program’s Property Custodian will perform an annual physical

inventory and maintain property records. The property records will be shared with the Fixed

Asset Manager and Technician.

Any property not located shall be reported missing as provided in Section 8.11.

8.6 Leases

Leases that meet the accounting criteria for capital leases in accordance with Governmental

Accounting Standards Board (GASB) No. 62 are recorded as property and equipment, and the

related capital lease obligations (the total present value of minimum future lease payments,

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excluding executory costs such as taxes, maintenance and insurance) are included in long-term

debt for financial reporting purposes. Depreciation and interest are charged to expense, and

rent payments are treated as payments of long-term debt, accrued interest, and executory costs.

All other leases are accounted for as operating leases, and rent payments are charged to

expense as incurred.

This section will be updated for GASB 87 Leases which is effective for accounting periods

beginning after December 15, 2019.

8.7 Separate Fixed Asset Account Group

Fixed assets will be recorded in a self-balancing group of accounts separate and distinct from

the regular General Ledger accounts.

To be classified as a fixed asset, a specific piece of property must possess two attributes: (1) a

useful life of more than one year, and (2) a value of $5,000 or more.

All fixed assets acquired either by purchase from a granting agency, local funding, or donated

to the Tribe, will be immediately recorded in the Fixed Assets Account Group. Purchased fixed

assets are valued at cost. Donated fixed assets are recorded at their estimated fair value at the

time received by the Tribe. All fixed assets owned by the Tribe should be substantiated with

adequate records.

The Fixed Assets Account Group will be organized as follows:

1. Land

2. Buildings & Improvements

3. Vehicles

4. Furniture & Fixtures

5. Equipment

6. Infrastructur

This text is long and has been trimmed here. Open the source document for the complete record.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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