# Blackfeet Tribe Plan of (2024)

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/tribal%3Ablackfeet%3A37fba23d56918fb0

## Record

- **Collection:** Tribal code
- **Document type:** Tribal code

## Text

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

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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,

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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.

Plan of Operations Chapter 6

Finance Policies and Procedures

Page 48 of 95

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 sol

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Ablackfeet%3A37fba23d56918fb0. Public record. Not legal advice.