POLICIES & PROCEDURES
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FINANCE MANUAL
TRIBAL GOVERNMENT
POLICIES & PROCEDURES
NP 25-457 approved 7/22/2025
Effective 8/1/2025
CONTENTS
INTRODUCTION ...................................................................................................................................................... 1
CONFLICT OF INTEREST ....................................................................................................................................... 2
SIGNATURE AUTHORITY DELEGATION ........................................................................................................... 3
ORGANIZATION CHART...................................................................................................................................... 4
SECTION I PROCUREMENT & CONTRACT SERVICES ................................................................................... 5
SECTION II ACCOUNTS PAYABLE .................................................................................................................... 10
SECTION III - CREDIT CARD PURCHASING POLICY................................................................................. 13
SECTION IV - GIFT CARDS AND DOOR PRIZES POLICY............................................................................... 15
SECTION V TRAVEL ............................................................................................................................................. 17
SECTION VI - PETTY CASH REIMBURSEMENTS ......................................................................................... 22
SECTION VII PAYROLL ........................................................................................................................................ 23
SECTION VIII - GRANTS & CONTRACTS MANAGEMENT ........................................................................... 26
SECTION IX - PROPERTY, PLANT & EQUIPMENT (Fixed Assets) .................................................................. 31
SECTION X - ACCOUNTS RECEIVABLE & CASH RECEIPTS ........................................................................ 34
SECTION XI DONATIONS .................................................................................................................................... 35
SECTION XII - GASB 87 LEASES ......................................................................................................................... 36
SECTION XIII - GASB 96 Subscription-Based Information Technology Arrangements (SBITA) Policy ............. 38
SECTION XIV REPORTS & BUDGETS ................................................................................................................ 40
SECTION XV ........................................................................................................................................................... 42
INDIRECT COSTS ................................................................................................................................................... 42
DEFINITIONS & CHART OF ACCOUNTS ........................................................................................................... 44
CHART OF ACCOUNTS......................................................................................................................................... 49
FORMS ..................................................................................................................................................................... 50
INTRODUCTION
The Nez Perce Tribe’s Finance Manual (the “Manual”) has been developed to provide uniform guidelines
for the Tribe’s financial management activities. A key mission of the Finance Department is to provide
efficient, accurate and timely processing of financial transactions to allow for reporting of accurate and
timely financials, which will then help management to strategically manage the Tribe’s resources and
objectives and comply with all governing regulations.
This Manual provides the accounting policies and procedures of the Tribe applicable to its government
entity. It carries the full weight of the Nez Perce Tribal Executive Committee’s (“NPTEC”) authority
and is to be fully complied with by all NPTEC members, Boards & Commissioners, Department
Executives, Program/Division Managers & Directors, and all other government employees.
This Manual serves as the foundation for management of the tribal government’s day-to-day financial
affairs. However, limitations imposed by grantor agencies or other federal regulations may supersede
certain provisions contained in these policies and procedures. In addition, NPTEC reserves the right to
modify or suspend one or more of the policies contained herein, should budget or other conditions
warrant. Nothing within the Manual shall be construed as a reduction or change of the NPTEC
Treasurer’s responsibilities under Article I, Section 4 of the Bylaws of the Nez Perce Tribe.
This revision incorporates recent changes to federal regulations, most notably the adoption of new
Uniform Guidance 2 CFR 200.317-327 Procurement Standards dated October 1, 2024. The Finance
Department will monitor compliance with these policies, interpret their day-to-day application, and will
consider and implement any administrative revisions that may become necessary due to subsequently
changing conditions. Updates to reflect the latest guidance from the Finance Department, tribal
management, and changes in law, etc. will also be incorporated into the official forms being utilized.
The Finance Department shall be responsible for circulating subsequent revisions to Department
Executives, who shall then be responsible to notify their employees of relevant changes that may affect
their operations. Where appropriate, revisions will be accompanied by instructions for implementing
changes. The current Manual is available to any employee upon request to the Finance Department. The
Manual can also be accessed in the Finance Department section of the main tribal website
(www.nezperce.org), where the most current official forms will also be available in fillable PDF format.
Every question or concern may not be answered in this publication, so employees are encouraged to
raise any questions regarding this Manual with his or her supervisor or other appropriate management
personnel. Failure to comply with the policies contained in this Manual may result in disciplinary action,
pursuant to the Human Resource Manual.
Page 1 of 50
CONFLICT OF INTEREST
Employees of the Nez Perce Tribe shall not profit, directly or indirectly, from funds under their control
nor shall they have a beneficial interest in any contract made or administered by them in their official
capacity. No employee, tribal official or agent may participate in the selection, award or administration
of any contract supported by federal, state, local, private, or tribal funds when he or she has any actual or
apparent conflict of interest. Such a conflict of interest would arise when the employee, tribal official,
agent, or any member of his or her immediate family (as defined in the Tribe’s Human Resource Manual),
his or her business associates/partners, or an organization which employs or is about to employ any of the
parties indicated herein, has a personal, financial or other interest in, or a tangible personal benefit from,
a firm considered for a contract with the Tribe.
Employees are obliged to disclose to their Department Executive, who will then also advise the NPTEC
Chairman, any actual, potential, or apparent conflict of interest as soon as the employee is aware the
conflict exists. An apparent conflict of interest is one that a reasonable person would believe that the
employee’s judgment is likely compromised because of such relationship(s).
Conflicts of interest can also arise in other contexts. Employees, in their official capacities, are prohibited
from:
a. Personally accepting substantial gifts, favors or anything of monetary value from vendors,
contractors, or others who have or desire to have business dealings with the Tribe;
b. Establishing or engaging in business in competition with tribal enterprises or businesses; and
c. Representing the Nez Perce Tribe on business matters after they are no longer an employee.
As always, employees should also refer to the current Human Resource Manual that may offer further
guidance in this regard, including disciplinary actions and the Tribe’s Whistle Blower Policy.
Should there be any discrepancy between the policies and procedures contained anywhere in this Manual as
it relates to NPTEC members and in the Administrative Procedures and Rules of the NPTEC (NP 14- 132),
the latter shall govern.
Page 2 of 50
SIGNATURE AUTHORITY DELEGATION
Within each Department or Project, the assigned Director or Manager is responsible for the overall
operations of the Program and may assign signature authority to certain employees in compliance with
this policy. To assign signature authority, a Signature Authority Delegation form (on which up to three
names may be assigned) must be completed and submitted to the Finance Department and will remain in
effect until changed. In no event shall delegation of signature authority be given to a subordinate more
than one level below the Delegator. Otherwise, such delegation must be at a lateral or higher level from
the Delegator and, in any event, any required signature on finance-related documents must be an original
unless otherwise excepted herein. If at a subordinate level, employees who are given signature authority
are also responsible for assuring the following:
•
•
•
•
•
•
An understanding of what is being approved;
The information and supporting documentation are accurate and complete;
The transaction is allowable, reasonable and justified;
The transaction is charged to the correct project(s);
There are adequate funds to cover the expense; and
The funding source is appropriate for the expenditure.
Internal Controls:
It is the responsibility of the Delegator to maintain proper control and management of his/her budget(s)
- the Delegator remains accountable for all actions taken by the Delegate. The Delegator shall take into
account and maintain appropriate internal controls, including separation of duties. The fundamental
premise of segregated duties is that an individual should not be in a position to initiate, approve, and
review the same action. Segregation of duties is critical because it ensures separation of different functions
and defines authority and responsibility over transactions. Segregation of duties is critical to effective
internal control; it reduces the risk of both erroneous and inappropriate actions.
Neither the Delegator nor Delegates may approve transactions for themselves, their immediate relatives
nor approve transactions that directly benefit themselves or their immediate relatives or, in any way, create
a conflict of interest with their responsibilities to the Tribe. Such transactions must be countersigned by
another authorized person, namely the person of next higher authority. Subordinates cannot approve
transactions for their superiors, regardless of the authority level. Such actions tend to place the subordinate
in an untenable position with undue pressure applied to them, even if not stated specifically.
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ORGANIZATION CHART
Finance Department
Page 4 of 50
SECTION I
PROCUREMENT &
CONTRACT SERVICES
Purpose:
To control expenditures by obtaining the lowest cost possible, with satisfactory terms and quality, and by
not allowing expenditures to exceed budgeted amounts.
To include control elements necessary to properly account for purchasing transactions and safeguard tribal
assets.
Department Executives and Program Managers and Directors have the ultimate responsibility to ensure
that all purchases are in compliance with this Manual, along with any applicable federal, state and grantor
agency requirements. The Purchasing and Procurement function is currently managed as part of the
Accounts Payable group.
Indian Preference in Procurement:
All departments and programs of the Tribe shall adhere to the Indian Preference provisions established
by the Tribal Employment & Rights Ordinance, unless expressly prohibited by federal law. Specially,
any contract, subcontract, grant or sub-grant authorizing the use of Federal contract or grant procurements
for the benefit of the Tribe, shall require preference in the award or purchase to Indian-owned businesses
and enterprises, unless federal law specifically says that tribal laws are preempted.
Policy & Procedures:
1. All Requisitions for goods and services shall be submitted to the Finance Department with the
following approval signatures already obtained, depending on the amount of the total expenditure:
a)
$0.01
to
$10,000
b)
c)
d)
$10,001 to
$50,001
to
$100,001+
$50,000
$100,000
Employee & immediate Supervisor/Project
Leader
Above plus Program/Division Manager or Director
Above plus responsible Department Executive
Above plus copy of NPTEC Resolution
In addition to dollar amount considerations above, bids are required based on the dollar limits shown
below from at least three (3) independent vendors or contractors, meeting the specifications provided
by the Department or Program/Division, as follows:
a)
b)
c)
d)
$0.01
$10,001
$50,001
$100,001+
to $10,000 No formal bids required (use best judgment)
to $50,000 Telephone bids required
to $100,000 Written bids required
Advertising for written bids also required
Page 5 of 50
2. The following conditions must be met for bids:
a. A complete, adequate, and realistic specification or description of the item to be purchased.
b. Bids shall be awarded to the lowest responsive and responsible bidder, unless otherwise justified.
Justification shall be in writing and shall include preferences to Nez Perce Tribe Certified Indian
Business, Minority-Owned, Women-Owned or Disadvantaged Small Business and shall be
attached to the purchase documents for record.
c. If after solicitation from a number of sources, competition is determined inadequate.
d. All awards shall be in writing.
3. Factors such as Nez Perce Tribe Certified Indian Business, Minority-Owned, Women-Owned or
Disadvantaged Small Business may receive preference, as well as price discounts, transportation
costs, and life cycle costs are valid determining factors.
4. The Nez Perce Tribe use preferred vendors whenever possible. Preferred vendors are selected through
a formal sourcing processing resulting in a contract and/or price agreement with negotiated pricing,
terms and conditions favorable to the tribe.
5. A cost analysis will be performed on all bids, quotes or proposals based on evaluation of competitive
bids and the responsiveness to requests for quotes or proposals. A cost analysis will be necessary
when adequate price competition is lacking, and for sole source justification. Any or all bids may be
rejected for sound, documented reasons.
6. The nature and extent of bidding shall be dependent on the type and magnitude of the project being
contemplated, which may in certain situations require more regional or national exposure. In many
cases, advertising in the local newspaper(s) will suffice. Departments and Programs/Divisions shall
use their best judgment in determining the appropriate advertising methods to obtain sufficient vendor
bids to meet their minimum requirements for the project.
7. For repeat purchases of the same or similar items, the determination of the lowest cost supplier may
remain in effect for up to one year, without the need for continually obtaining three bids for each
subsequent purchase.
8. An Informal Bid Summary Sheet for telephone and written bids and the bid or quote from the selected
vendor shall be attached to the requisition. All other bids and documentation related to the purchase
must be retained by the department for possible examination by the Tribe’s independent auditors each
fiscal year.
9. Noncompetitive (sole source) proposals may be used only when one or more of the following
circumstances apply:
a. Supplies or services to be acquired are unique or proprietary to a vendor;
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b. Emergency purchase is necessary and only one known source can meet the Tribe’s needs (lack of
planning does not qualify);
c. The federal awarding agency expressly authorizes noncompetitive proposals in response to a
written request from the Tribe.
10. Sole source procurements will require approval of the Department Executive and, when over
$100,000, concurrence by subcommittee and final approval by NPTEC. Approvals sought from
subcommittee should be accompanied by a written justification stating specifically how the best
interests of the Tribe would be served by purchasing from this particular vendor without the benefit of
competitive bid pricing, and submitted with the Requisition to Accounts Payable.
In no case shall the sole source justification be used to avoid or circumvent the approved Accounts
Payable & Purchasing policies and procedures.
11. No employee, officer, elected official, or agent of the Tribe shall participate in the selection, award,
or administration of a procurement if a conflict of interest, real or apparent, would be involved.
Likewise, employees, officers, elected officials, or agents of the Tribe shall not solicit or accept
gratuities, favors, or anything of monetary value (not exceeding $200) from contractors, potential
contractors, or parties to sub-agreements in compliance with the Copeland “Anti-Kickback Act”,
From time to time, vendors will give promotional material or host refreshment/meal.
12. Contractors that develop or draft specifications, requirements, statement of works, or invitations for
bids and requests for proposals must be excluded from competing for such procurements.
13. Purchase Orders will be prepared and distributed by the Finance Department within one (1) business
day after the receipt of a fully approved Requisition. Employees submitting the Requisition are
responsible for transmitting the approved Purchase Order to their vendor to formally place the order,
along with the Requisition or other supporting information that may be too lengthy for inclusion on
the Purchase Order itself. Employees are responsible for notifying the Purchasing Specialist
immediately if any issued Purchase Order will not be utilized or is to be withdrawn.
14. Preference will be extended to those vendors who accept the Tribe’s Purchase Orders. All new vendor
accounts will be established through the Accounts Payable Supervisor. Employees are prohibited from
charging any personal items to the Tribe’s account with a vendor, regardless of whether they intend to
pay back the Tribe. Departments and Programs/Divisions should develop and maintain sources of
supply to assure that they have an adequate number of vendors from which to obtain supplies,
equipment, and services necessary to support their Program’s operations.
15. All Purchase Orders will require the following signatures prior to their issuance to vendors:
a)
b)
c)
$.01
$1,001
to $ 1,000 Purchasing Specialist (facsimile signature)
to $10,000 Above plus Accounts Payable Supervisor or Director
of General Accounting (or Finance Manager)
$10,001+
Above plus Finance Manager or NPTEC Treasurer
Page 7 of 50
Contracts
1. All contracts for consulting services, leases and similar arrangements will be contracted, only if inhouse tribal staff cannot provide the required capabilities and resources and will follow the
procurement policy. A Contract Review and Recommendation Checklist form is required for all
contracts and will be submitted to the Grants & Contracts Staff for initial review and processing, with
subsequent approval from the Office of Legal Counsel. Construction and Forestry contracts will
require review by the Tribal Right Employment & Rights Office (TERO), that shall require preference
in the award or purchase to Indian owned businesses, unless federal law specifically says that tribal
laws are preempted.
2. Any contractual services that span longer than three months will require documentation of bids
received. Contracts in the cumulative amount of $100,000 or more, or lasting more than one year, also
requires concurrence by subcommittee and final approval by NPTEC.
3. All contracts of the Tribe must be authorized and signed by the NPTEC Chairman and Secretary.
Contract will not be signed without the Contract Review Form and any other supporting procurement
documentation.
4. In addition, Departments and Programs/Divisions are responsible for reviewing the government’s
Debarred List on the System for Award Management (SAM) website and confirming that their
potential contractors are not listed. A snapshot of the results indicating they are not on the Debarred
List will be attached as supporting documentation.
5. To ensure network security and hardware/software compatibility throughout the Tribe, all purchases
of technology-related equipment (desktop computers, servers, laptops, tablets, software, and
telephones, etc.) shall be coordinated with, and ordered through, the Department of Technology
Services, who will then forward the appropriate Requisition(s) to the Finance Department when fully
approved.
6. Credit Applications required by vendors will require the following review/approval procedure: a) if
there are no contractual terms and conditions, the Accounts Payable Supervisor will process the
application; b) if there are legal terms and conditions being proposed by the vendor, then a Contract
Review form shall accompany the Credit Application and be submitted to the Grants & Contracts
Staff. In this instance, OLC review and approval shall also be required, followed by signature and
final processing by the Accounts Payable Supervisor.
7. Employees must avoid acquisition of unnecessary or duplicative items, should consider consolidating
procurements and, where, appropriate, should perform an analysis of lease versus purchase method of
acquisition.
Page 8 of 50
8. Programs must maintain records sufficient to detail the history of procurement, including the rationale
for the method of procurement, selection of contract type, contractor selection or rejection and the
basis for the contract price. Time and materials type of contracts may only be used after a
determination that no other contract is suitable and should include a ceiling price.
9. The Tribe must use one of the following methods of procurement: Micro-purchases, small purchase
procedures, sealed bids, competitive bids, or noncompetitive bids (refer to 2 CFR 200.320 for further
definitions and processes to be followed).
Page 9 of 50
SECTION II ACCOUNTS
PAYABLE
Purpose
To establish a uniform guidance for recording accounts payable and disbursements to ensure they are
recorded accurately, completely and in the appropriate accounting period.
Policy & Procedures
Requisition & Purchase Orders
A Requisition form will be used to initiate the process of procuring goods and services to process a
purcha1se order.
1. Although Departments and Programs/Divisions are allocated funds in their budgets for a given period,
this allocation is only an authority to request, not to purchase. Individuals initiating a proposed
purchase should always take steps to assure that the items are being obtained at competitive prices
and with appropriate quality.
2. Each Requisition must be fully completed and contain a clear and concise description of the material
or service being ordered from1 that vendor and may reference an accompanying page or pages
containing more specific details. When received by the Finance Department, the responsible
Accountant will review the Requisition for completeness, accuracy, whether it is an Allowable Cost
and if adequate funds are available within the budget(s) being charged. When approved, the
accountant will forward the Requisition to Accounts Payable for further processing.
3. Purchase Orders are sent to the department(s) for that department to process the order.
Blanket Purchase Orders
Blanket purchase orders are to be used primarily for services or supplies that are needed on a regular and
consistent basis from the same supplier, and when supplies are in bulk and low purchase price, or in case
of emergencies, i.e. repair & maintenance, emergency response. etc.
Specific examples include:
• Preventative maintenance items/service (monthly payments)
• Bottled water service
• Facilities & Maintenance items
• Utilities
• Food purchase for meal preparation (HeadStart, Sr. Citizens, Children’s Home)
The department is responsible for submitting the original receipts to Finance within 5 business days of
the purchase.
The blanket purchase order is only good for 3 months.
Page 10 of 50
Each individual budget entity is assigned a unique Fund number (or numbers) by the Finance Department,
and a Requisition or Payment Voucher must include the complete number of the account(s) to be charged.
The basic format of an Account Number is xxxx-xx-xxxx, where the first four digits are the Fund Number
where the budget resides, the middle two digits are any sub-fund number (in many cases just 00), and the
last four digits are the Object Code identifying the type of expenditure (salaries, travel, supplies,
equipment, etc.).
Processing Payments
1. All vendor invoices for purchases using a purchase order will be sent directly to the Finance
Department, preferably by the vendor.
2. Invoices and statements from vendors must be received by the Finance Department by one of two
acceptable methods:
Mailed to:
Nez Perce Tribe
Attn: Finance Department
PO Boxes 365
Lapwai, ID 83540
Email to:
AccountsPayable@nezperce.org
3. Departments and Programs/Divisions shall generally not request that vendor invoices be sent to their
office. The Tribe’s standard payment terms are “Net 30” days, unless specified/requested otherwise.
Payments to vendors will generally be processed only from original invoices in order to avoid the
possibility of duplicate payments.
4. Invoices are not processed without adequate proof of receipt or performance. In cases of goods
delivered directly to a department or Program/Division employee, they should be counted, examined,
and inventoried. Departments and Programs/Divisions shall be responsible to immediately notify
Accounts Payable and the vendor of any unsatisfactory goods or services received so that payment
will not be processed until all issues have been resolved.
5. All checks are processed through the Tribe’s financial software system and include signatures of the
current NPTEC Chairman and Treasurer. Wire transfers to 3rd parties will follow the same guidelines,
except they shall include original signatures or e- mail authorization of the Treasurer (or Chairman)
on supporting documentation. Transfers between existing tribal bank accounts may, however, be
processed via properly authorized banking software by the Director of General Accounting and
Finance Manager.
6. Accounts Payable checks for the tribal government are processed every Monday, Wednesday, and
Friday, and are available no later than 2:00 p.m. on those days. Checks are delivered to the inter-office
mailboxes.
Page 11 of 50
7. Emergencies or items requiring immediate payment must be submitted to the Finance Department by
10:00 a.m. the day prior to the check run date The same deadline should be followed if payment is
being requested by the Tribe’s credit card.
8. Travel advances will be paid prior to the travel date.
Check Security
Check stock and unissued checks must be restricted to authorized personnel. All unissued checks will
be locked in the fireproof safe located within the Finance department at the end of the day.
The beginning check number for the next check run is sequential to the ending check number of the
prior check run, or the discrepancy must be reconciled.
Page 12 of 50
SECTION III - CREDIT CARD
PURCHASING
Purpose
The purpose of the Credit Card Policy is for Nez Perce Tribe employees to be able to make necessary
purchases while complying with the Nez Perce Tribe Procurement Policy.
Type of Cards:
1. Individual travel credit cards are for travel related expense only.
2. Home Depot Credit card is a requirement under the Patriot Act, Section 326, that requires the use of
the card be made only by designated buyers whose name appears on the card.
3. Other credit cards of the Nez Perce Tribe are controlled by the Finance Department and can be checked
out for use, that include a Walmart card.
Policy & Procedures
1. Supervisors are responsible for oversight of tribal credit cards in their departments employee’s name
or credit cards that an employee in their department checks out.
2. Cardholders must be regular full-time employees.
3. Credit cards that are checked out, must be by an employee of the Nez Perce Tribe.
4. A requisition and purchase order are required for the purchase.
5. Employee card holders:
a. Keep all original receipts/invoices for reconciliation at the end of each month.
b. Credit card expenditures must be reconciled and submitted with original receipts and copy of the
purchase order to the Accounting/Finance Department within 10 business days of the statement
date.
c. Cardholders who are late and have not reconciled and submitted their monthly expenditure within
this period will need to do so immediately. Continued or repeated non-conformance to this policy
will result in cancellation of the card and such other actions as appropriate.
d. If the card expenditures are not reconciled within a month of the statement and the supporting
documentation has not been submitted to the Finance Department, the employee's tribal credit
card may be cancelled.
e. Other credit cards must be returned that same business day.
Page 13 of 50
Unauthorized Use
Misuse of the card will result in cancellation of the card, payroll deduction if needed, and withdrawal of
company credit card privileges. If the card is used for an employee’s personal expenses, or is used in any
other unlawful manner, the Nez Perce Tribe reserves the right to recover these monies from the employee
by signing the form below authorizing the Tribe to recover from their payroll, any amount incorrectly
claimed. Disciplinary action will be taken as appropriate.
Department supervisors will confirm valid expenditures. Individuals will be held accountable for all
invalid expenditures with reimbursement procedures following Section Il of the Finance Manual.
Prohibited Purchases:
•
•
•
•
•
•
•
•
•
•
Alcoholic Beverages
Cash Advances
Controlled Substances
Donations
Payments to Individuals
Personal Purchases
Prepaid Card Purchases
Vehicles and Vessels with Titles
Weapons and Ammunition
Contract payments including, leases and rentals, except for short-term small equipment rentals.
Responsibilities
•
•
•
•
•
•
•
•
•
Keep the card in a safe and secure place.
Bear the ultimate responsibility of the card.
If the card is stolen or lost, report it as soon as possible to the Finance Manager. A police report
may need to be filed.
If any transactions are fraudulent and made by someone else (i.e., hacked), notify Finance
immediately.
Will not use the credit card for personal expenses and will use it only for official business on
behalf of the Nez Perce Tribe.
Misuse of the card (i.e., use it otherwise than in accordance with the instructions in this policy or
related policies).
If the employee cardholder moves to another tribal department or resigns from the tribe, they will
return the card with a final reconciliation of all expenditures prior to the last day of employment
with that department.
The employee card holder authorizes the Nez Perce Tribe to recover the funds through payroll
deduction for any amounts incorrectly claimed or for reconciliations that are one month in arrears
of the statement date if the employee fails to reconcile expenditures within the prescribed
procedures and timeframe.
Employee card holders and their supervisor are required to sign acknowledgement of the card
issued. (Attachment XX).
Page 14 of 50
SECTION IV - GIFT CARDS
AND DOOR PRIZES
Purpose
The purpose of this policy is to set forth the guidelines for the purchase and distribution of gift
cards/certificates purchased to ensure compliance with the Nez Perce Tribe policies and
procedures, uniform administrative requirements, costs principles and audit requirements. These
procedures apply to any purchase and/or distribution of gift cards and door prizes using both tribal
and non-tribal funds.
This policy does not apply to gift cards or gift certificates issued pursuant to a general welfare
program established by the Tribe.
Gift cards and certificate means a card, code, paper form or other device that is:
a. Issued on a prepaid basis primarily for personal, family, or household purposes to a consumer in
a specified amount; and
b. Redeemable upon presentation at a single merchant or an affiliated group of merchants for goods
or services. Example: Retail Store Certificate, Restaurant Card, Store Credit, Retail Store Cash,
Gas Card, Visa Card
Door Prize
• A prize awarded and distributed at an event.
Policy & Procedures:
A requisition must be completed PRIOR to purchasing gift cards/certificates and door prizes. If
departments utilizing grant funds, written approval from their respective funding agency with supporting
documents is required prior to purchasing gift cards/certificates and/or door prizes. The requisition must
clearly define each item being purchased, with quantity and amount. It is recommended to limit the
number of gift cards/certificates purchased at one time so that the disbursement documentation is
manageable. If multiple gift cards/certificates and/or items are purchased, appropriate measures must be
taken to safeguard the gift cards/certificate and/or items that are not distributed immediately. It is
recommended that gift cards/certificates be purchased in modest denominations, i.e., not more than
$50.00 per gift card/certificate.
The requisition must include the following information:
a. Vendor Name (entity from which gift cards/certificates are to be purchased);
b. Amount of each gift cards/certificates;
c. Description of what is to be Purchased (number/face amount of gift cards/certificates to be
Page 15 of 50
purchased);
d. Description of Intended Use of gift Cards/Certificates (e.g., drawing, student recognition);
e. Month/Year cards are to be distributed;
f. A flyer of the event.
A "Gift Card/Certificate Disbursement Log" (attached as Exhibit XX) is required to record the dispensing
of all gift cards/certificates purchased by the department. The original proof of purchase and Acceptance
Agreement must be kept on file by the department, together with the log. The log should contain the
following information:
a. The log should be updated each time a gift card/certificate is disbursed to an individual. The
following information must be entered for each gift card/certificate distributed: (a) the date of
distribution; (b) the recipient's name; (c) the recipient's status (i.e., employee or non-employee).
b. The vendor from whom the gift card/certificate was purchased, as well as the gift card/certificate
number must be identified and entered in the "Vendor Name and Gift Card/Certificate Number"
column of the Log. The amount of the gift card/certificate must be entered in the "Amount"
column.
For Door Prizes, an Acceptance Agreement will need to be prepared that will contain the following
information:
a. The recipient's name and address;
b. Description of the gift card/certificate;
c. The value of the gift card/certificate;
d. The recipient's signature and date.
Internal Control
Adequate internal accounting control (i.e., segregation of duties, physical control over assets, and written
authorization for expenditures, etc.) must be established and maintained. Sound internal control will
safeguard assets and ensure financial record accuracy.
The department must submit a copy of the log, together with a copy of related Acceptance Agreements,
to the Finance Department within 10 business days of the event.
Page 16 of 50
SECTION V
TRAVEL
Purpose
The purpose of this policy is to convey basic procedural and statutory guidelines for individuals when
traveling on official tribal business - outside the local duty station where their basic job duties are to be
carried out that day. Official travel occurs as a normal course of tribal operations and, as such, travelers
and their supervisors must apply care in planning, conducting and documenting travel. Travel may involve
inherent risks for the traveler, as well as for the Tribe’s mission and organization. Inadequate planning
and questionable decisions by employees while on travel potentially make this a high visibility issue for
our federal agency partners, auditors, and the general public.
Objectives:
To control expenditures by ensuring that the travel is consistent with federal regulations and tribal
objectives and does not exceed reasonable and budgeted amounts.
To make accounting and reimbursement for travel more efficient for employees and their Department
Executives and Program/Division Managers and Directors who have the ultimate responsibility to
monitor compliance with travel policies by their employees.
To establish control elements necessary to properly authorize, account for and document travel expenses.
To ensure that individuals neither gain nor lose personal funds as a result of reasonable and necessary
expenses incurred when traveling on pre-approved, official tribal business.
Typical Travel Cycle:
•
Employee and Supervisor determine that travel is necessary and pre-plan details of trip;
•
A Travel Authorization form is required for all travel to ensure the correct budget is used and that
there are sufficient funds in that budget; the Travel Authorization will include the airfare, hotel and/or
rental car charges, outlining all arrangements and costs;
•
Following receipt of a fully approved Travel Authorization, the traveler will contact the authorized
travel agency or use their department travel credit card to make reservations for airlines, hotels, rental
cars, etc. (unless the employee, with Supervisor approval, chooses to instead make personal travel
arrangements using a personal credit card, and subsequently seek reimbursement at the conclusion of
his or her travel);
•
Employees will submit a check voucher for conference registration fees (if applicable).
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•
When necessary, a Travel Advance Request form is submitted to Accounts Payable 3-5 days prior to
the trip to provide funding for per diem costs for hotel room costs, meals and incidentals, personal car
mileage, etc.;
•
Within 3 business days of returning to work date, the traveler completes a Travel Settlement form
itemizing all travel expenses including all original receipts;
•
At the time of settlement, the employee either 1) returns excess Travel Advance amounts to the Tribe,
or 2) payment is set up on the next scheduled check run to reimburse the employee for any additional
expenditure(s) incurred.
Pre-Travel Policy & Procedures:
1. Program/Division Managers or Directors must authorize all travel for staff directly related to the
Departments and Programs/Divisions whose budgets they oversee. Department Executives must
provide final approval on travel settlements when the total cost is $5,000 or more. The NPTEC
Chairperson will authorize and approve all travel for NPTEC, Department Executives, the NPTEC
Support Staff and all Boards & Commissions.
2. A Travel Authorization form for travel must be completed and fully approved prior to making any
firm travel commitments, either personally or through the Tribe’s travel agencies. When the Travel
Authorization form is received by the Finance Department and determined to be in compliance, a copy
will be returned to the employee who may then proceed with making travel arrangements.
3. Local Travel - Note: this level of authorization does not apply to travel in an employee’s normal course
of work involving local travel, field crew assignments, etc. where only supervisory approval is
required. Local travel is defined as being less than 150 miles (one-way) and not requiring an overnight
stay.
4. For local travel, per diem allowance for lunch only. Travel for more than 12 hours, but less than 24
hours, will be eligible for 75% of the allowable daily rate for M&IE.
5. All travel will comply with General Services Administration (“GSA”) Travel Regulations. The GSA
Travel Regulations currently in force are published online in the Federal Register
(https://www.gsa.gov/travel/plan-book/per-diem-rates ). Conference rates for lodging may, on
occasion, exceed the published GSA rates. However, employees should always strive to utilize the
lowest rate possible, which may be the hotel’s block rate, government rate, tribal rate, etc.
6. The most economical, as well as practical, mode of transportation is to be used for all travel. First
class air travel, extravagant hotel rooms or luxury rental cars are not reimbursable.
7. Transportation expenses may be reimbursed for taxi, Uber, etc., for the travel between the airport and
hotel, and the meeting location to/from the hotel, and when traveling between hotel and places where
meals can be obtained, only if meals cannot be obtained at the place of lodging.
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8. Travelers may be authorized the use of a rental vehicle when such use is determined to be
advantageous for cost savings. The use of a rental car should be justified as an economical, business
necessity and not as a matter of personal convenience. All rentals should be at the
corporate/government rate or the lowest possible rate per day. When traveling in groups, sharing of
cars should be practiced to minimize costs.
9. Travel should be planned as far in advance as possible to obtain the best rate for airfare and hotel
rooms (at least 14 days). Following receipt of a fully approved Travel Authorization form, travel
arrangements can be booked using the Tribe’s authorized travel agency, or travel credit card.
Employees are responsible for providing this form to the travel agency authorizing them to begin
incurring charges on behalf of the Tribe.
10. It is the responsibility of the Department and Program Managers to ensure that their employees follow
the proper reimbursement regulations and that adequate budget balances exist to accommodate all
costs of travel. No funds will be disbursed to any tribal employee for travel that does not comply with
the tribal travel policies.
11. The travel agency or department card holder will book and may prepay the airfare costs, hotels, and
car rentals, and any such amounts will be treated as a Travel Advance to the employee until all travel
expenses are settled and accounted for. It is imperative that employees are aware of cancellation dates
to avoid unnecessary “no show” charges that, unless documented and approved with a legitimate
business reason, will result in payroll deductions to return the funds to the Tribe.
12. Important: If an employee does not have a personal credit card to present upon arrival, they must be
sure to notify the travel agency so that appropriate authorization arrangements can be made in booking
hotel rooms. The Tribe’s reservation will only guarantee arrival in most cases, not pay for the entire
stay. Employees are solely responsible to provide timely cancellation notices whenever necessary to
avoid charges to the Tribe for travel that does not take place.
13. A Travel Advance Request form will be submitted consistent with the Accounts Payable check run
day (Section II, Accounts Payable, Processing Payments #6) in order for the traveler to receive a
timely Travel Advance. Accompanying documentation must include the meeting notice, meeting
location and an agenda that documents meals provided, if any, and preferably should be submitted to
Accounts Payable 3-5 days prior to the travel.
14. Use of privately owned vehicles (POV) when GSA or tribal vehicles are available within a department
or Program/Division should be carefully considered. When a decision is made to drive a POV rather
than fly to a travel destination, the employee must include documentation of a comparable 14-day
advance airfare (unless the requirement to travel affords less time) versus the personal car mileage,
and the lower amount will be advanced. If a tribally owned or leased vehicle is available to the
employee, and the employee instead chooses to use their own vehicle, reimbursement is limited to the
modified (limited) GSA rates in effect for that situation. In addition, all employees should refer to the
Tribe’s Vehicle Use Manual for additional policies and procedures related to driving and renting cars
while on tribal business.
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15. Calculation of miles to be reimbursed for the use of POV’s on regular workdays will generally use
the employee’s regular workstation as the starting point, depicted by the following: H–W–D where H
stands for the employee’s home, W is their regular workstation and D is the destination of the travel.
In this instance W to D is usually the reimbursable distance. An employee living in Moscow but
normally working in Lapwai who must travel to Kamiah would only be reimbursed for the mileage
from Lapwai to and from Kamiah (W to D). Note: on weekends or holidays, the H to D mileage will
be reimbursable since the employee would not be expected to first report to their regular workstation
on those days. If the geographic arrangement is W–H–D, then only the shorter distance from the
employee’s home to the destination is reimbursable. If the same employee must travel to Coeur
d’Alene for a conference, he or she would only be reimbursed only for the mileage from Moscow to
and from Coeur d’Alene (H to D). Unless included with a Travel Settlement, reimbursement for
personal car mileage should be requested on a Mileage & Miscellaneous Business Expense
Reimbursement form.
Post-Travel Policy & Procedures:
1. A Travel Settlement form must be submitted within 3 business days of returning to work following
the travel. Failure to settle in this timeframe, and simultaneously remit any reimbursement due to the
Tribe, may result in refusal of further travel, payroll deduction(s) and/or disciplinary action (HRM
5.5.19). All expenditures of $5.00 or more require original receipts, with the exception of per diem
meal allocations and personal car mileage. Receipts include hotel, taxi/uber, and baggage fees. All
reimbursement requests for miscellaneous expenses must be itemized with receipt and be a direct
business expense with the official travel. The responsible Accountant shall review the Travel
Settlement form for accuracy and completeness. If reimbursement is due the employee, a check will
be processed on the next check run date. Any reimbursement due back to the Tribe must be remitted
on the settlement date.
2. If the Tribe is paying for any travel expenses, employees must clearly indicate if any outside
organizations will be providing or reimbursing any costs for the travel or providing the employee with
any form of compensation (speaking fee, honorarium, etc.). If so, employees are required to request
that any such reimbursements should be made payable to the Tribe and not to the individual (unless,
related to compensation only, the employee is on Unpaid or Annual Leave status).
3. Employees are not eligible to receive reimbursement for the dollar value of discounts or
complimentary offers on hotel rooms, car rentals, or airline tickets should they choose to utilize
personal frequent flyer miles or award program points to cover all or part of such costs while on
business travel.
4. Travel advances or reimbursement for emergency travel expenses may be authorized when it becomes
necessary to interrupt scheduled travel and return home under the following circumstances:
a. The traveler becomes incapacitated by illness or injury not due to the traveler’s own misconduct;
b. The death or serious illness of the traveler’s family; or
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c. A catastrophic occurrence or impending disaster, such as fire or flood, which directly affects the
employee’s home, requiring that the employee return home immediately.
5. Travel advances or reimbursements for emergency travel expenses include:
a. Per diem at the location where the employee incurred or was treated for incapacitating illness or
injury for a reasonable period of time (generally not to exceed 14 days);
b. Transportation and per diem expenses for travel to an alternate location to receive treatment; or
c. Transportation and per diem expenses for the traveler’s return trip home.
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SECTION VI - PETTY CASH
REIMBURSEMENTS
Purpose
To provide a mechanism for the efficient purchase of relatively low-cost goods and services that do not
fall into the normal policies and procedures as outlined elsewhere in this Manual.
To include control elements necessary to properly control purchasing transactions and to safeguard cash.
Policy & Procedures:
1. Petty Cash reimbursements will normally be made for unanticipated purchases of $50.00 or less,
disbursed only to tribal employees, and should not be used for routine purchases that attempt to
circumvent purchasing procedures outlined in this Manual. Employees seeking a Petty Cash
reimbursement will be required to complete and sign a Petty Cash Reimbursement form. The
employee’s immediate Supervisor (or higher) is also required to approve all Petty Cash
reimbursements. Note: Supervisors should require their staff to plan ahead such that purchasing
procedures in Section I of the Manual are utilized whenever possible, and that use of Petty Cash is
minimized.
2. If a situation occurs where a Petty Cash expenditure needs to be made for more than $50.00, the
responsible Department Executive and Accountant, and either the Director of General Accounting or
Finance Manager must authorize the higher amount. The custodian of the Petty Cash fund is not
authorized to reimburse the employee for amounts over $50.00 without this approval. Employees shall
provide written justification for the need to exceed the policy limit when seeking reimbursement.
3. The Finance Manager has the authority to establish a Petty Cash fund for any of the Departments and
Programs/Divisions, especially at remote office locations, upon their request and when provided
documentation of need. All remote Petty Cash funds will be secured at all times and kept in a secure
area, remain reconciled and shall otherwise follow these same policies.
4. The employee making a purchase must obtain and attach an original receipt for the goods and services
being acquired. Petty Cash reimbursements will only be made for receipts that are dated within 10
business days of the time the Petty Cash Reimbursement form is submitted to the Petty Cash
Custodian.
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SECTION VII
PAYROLL
Purpose
To include all elements necessary to accumulate and maintain relevant personnel information, accumulate
employee hours worked, calculate pay amounts and withholdings, produce accurate pay checks for Tribe’s
employees, accurately prepare reports that are necessary for external and internal reporting purposes and
ensure compliance with tribal, federal, state, and local requirements.
To timely and properly distribute payroll expenses to the appropriate grant, contract and tribally- funded
cost centers and, when applicable, to provide information necessary to obtain timely reimbursement of all
allowable payroll expenditures from the Tribe’s respective funding agencies and to remain in compliance
with tribally approved budgets.
To include control elements necessary to properly account for payroll transactions and safeguard tribal
cash and other assets.
Policy & Procedures:
1. Departments and Programs/Divisions shall not hire employees on either a temporary or permanent
basis until the availability of funds has been established in an approved budget or grant/contract.
2. A fully completed and approved Employee Action Notice form, available from the Human Resources
Department, will be used as the source document for all new hires, salary adjustments, position
changes, promotions, terminations, etc.
3. For all new employees, the Payroll Department must receive the following fully completed and
signed forms (provided by Human Resources at orientation) by 10:00 a.m. on the Friday prior to the
employee’s first payroll date:
a)
b)
c)
d)
e)
f)
Employee Action Notice;
An IRS Form W-4 (employee’s withholding allowance certificate);
Employees’ Retirement Plan Enrollment and Investment Selection form;
Tribal Affiliation Form (if applicable);
Fisheries Tax Exemption Form (if applicable);
A Department of Homeland Security Form I-9 (employment eligibility verification) with
attached copy of social security card;
Note: Failure to furnish all the above forms may result in a paycheck not being processed until
such time as the proper paperwork is completed, which could mean the following pay period.
Page 23 of 50
4. A Payroll Voucher will be completed by the employees and approved by their immediate Supervisor
verifying that all time and labor charges for the pay period are accurate. It is the Supervisor’s
responsibility to ensure that all Payroll Vouchers are submitted to Payroll by 10:00 a.m. on the Friday
prior to payroll. Note: due dates may be moved earlier when holidays shorten the payroll processing
period. Please be aware of changing dates when this occurs.
5. If an employee does not have Sick Leave available at the time a Payroll Voucher is submitted,
available Annual Leave will automatically be used to cover any shortfall. Should Annual Leave
balances be insufficient, those hours will then be converted to Leave Without Pay. Employees should
carefully review and monitor leave balances appearing on each paystub.
6. Overtime pay is not allowed unless specifically authorized in the Program's budget and approved by
the Department Executives. Please refer to the Tribe’s Human Resources Manual and Emergency
Operation Plan for more specific information related to overtime pay, compensatory time off,
discretionary leave, annual and sick leave policies, etc.
7. All payroll disbursements will be made by check or direct deposit. Employees are encouraged to
utilize the direct deposit method to receive their compensation.
8. Payroll checks will be issued bi-weekly on the Thursday and on alternating Thursdays, NPTEC’s
weekly payroll and other miscellaneous payroll corrections, leave cash-ins, etc. will be processed.
Payroll will have the checks ready for distribution between 8:30 a.m. and 11:30 a.m.
9. It is the Department and Program/Division Managers’ and Directors’ responsibility to make
arrangement with Payroll for who will pick up and sign for their respective payrolls. Payroll checks
will not be issued directly to the employee.
10. Salary advances may be made to employees based on the following criteria:
a) Advances shall not exceed 75% of the employee’s net pay;
b) Employees who will be on travel status during their normally scheduled payday may
request an advance;
c) An employee may request one advance per quarter. However, an additional advance
will be allowed if a death or serious illness occurs in the employee’s immediate family;
d) Payroll advances must be approved by the employee's immediate Supervisor; and
e) All payroll advances will be deducted from the employee’s next available paycheck.
11. A new W-4 form should be submitted by an employee to Payroll whenever there is a change in their
status (marriage, new child, etc.) that will affect their payroll tax withholdings.
12. Requests on behalf of an employee to receive a donation of accrued Annual Leave will be submitted
to the Department Executive for approval on an Annual Leave Donation form, for the intended
purpose of the donation request and for up to a maximum of 90 days. Accrued Annual Leave may be
donated from one employee to another employee only in the situations where the recipient would be
Page 24 of 50
entitled to utilize sick leave but has insufficient sick and annual leave available.
13. Donors of Annual Leave are limited to a maximum donation of 40 hours per calendar year. Recipients
may receive a maximum of 160 hours from all donors per calendar year. Donated Annual Leave shall
be used on a first-donated, first- used basis. Any donated Annual Leave remaining when the recipient's
need has ended will be returned to the last donor(s).
14. An employee may request to cash-in up to a cumulative total of 120 hours of earned Annual Leave
per calendar year, with a maximum of four (4) cash-ins per year. Each request must leave a balance
of at least 40 hours. Requests must be made utilizing the approved Annual Leave Cash-in form,
approved by their Department Executive or Program/Division Manager or Director, and forwarded to
Payroll by 10:00 a.m. on Fridays.
15. Employees who terminate their employment in one Department and are hired by another Department
will be allowed to transfer their Annual and Sick Leave, with the written approval of both Department
Managers/Directors responsible for the budgets.
16. Payment for the accrued Annual Leave balance will be made to all employees and NPTEC members
upon their termination of employment and upon receipt of an approved Termination Checklist (an HR
form). Unused sick leave will not be paid to employees or NPTEC members upon termination of their
employment, as this is not a vested employee benefit.
17. The Tribe has a variety of options available to employees for deductions from their payroll either for
charitable or other purposes. A Payroll Deduction form is used to process these types of deductions:
United Way, loan payments, utility payments (water & sewer and home internet), housing payments,
401 (k) Retirement Plan contributions, etc.
18. Regular, full-time employees who work less than 40 hours per week shall receive Annual & Sick
Leave accruals based on a pro-rata basis, consistent with their work schedule.
Other Taxable Income
•
Gift Cards
Page 25 of 50
SECTION VIII - GRANTS &
CONTRACTS MANAGEMENT
Purpose
Grants and contracts are an extremely important element of funding for the Tribe, with almost 3/4 of its
programs funded in this manner. All such awards are subject to terms and conditions that must be followed
by the recipient program. These rules and regulations may be included in the final Award Notice received
from the funding agency and, in the case of federal funding, published in the Federal Register. These
grants also subject the Tribe to audit requirements that will review not only the financial aspects of
administering the grant, but also program management responsibilities. It is therefore imperative that the
Departments and Programs/Divisions that receive grants have qualified staff managing them who have
experience, receive proper training and are familiar with the requirements that will keep the Tribe in good
standing with the funding agencies and authorities.
Objectives:
To provide the financial information and controls necessary to maintain compliance with federal, state,
local or private reporting requirements and expedite receipt of awarded funds.
To make the process more efficient for Department and Program/Division Managers and Directors who
have the ultimate responsibility to ensure that their programs are in compliance with federal, state, local
and private regulations.
To keep expenditures within the limitations set forth by the program objectives, scopes of work and
budgets.
To include control elements necessary to prevent misuse of grant and contract resources.
All awarded grant funds must be expended prior to utilizing the tribe’s hard dollar revenue sources.
When outside funding is potentially available to a department or Program/Division funded by one of the
Tribe’s non-federal, “hard dollar” revenue sources, the Budget & Finance Subcommittee requires that two
grant applications be submitted annually, with the objective of reducing ongoing operating expenses as
being most desirable (NP 02-187 Amended).
Pre-Award Policy & Procedures:
Departments and Programs/Divisions will utilize the Grant Notice of Intent form to inform the Grants &
Contracts Staff of their intention to apply for a competitive grant. Failure to comply with this process
may result in not being allowed to apply when another program has already received approval to
commence work on an application. This form includes a summary/abstract of the project, the grant
announcement or RFP, a draft or preliminary budget and a clear designation of the employee who will
Page 26 of 50
be responsible to manage the grant and assume the role of Project Coordinator.
1. Once a grant application is near completion, and if no Resolution is required, Departments and
Program/Divisions shall submit a draft application and a fully completed Grant Review form to the
Grants & Contracts Staff, 2 weeks before the grant submission deadline. If a tribal Resolution is
required per the funding agency’s grant announcement, the Grant Review form should be completed
in adequate time for the sponsoring program to also present a synopsis of the proposal to their
respective subcommittee for approval, in accordance with its regular meeting schedule. Allow
adequate time for sub-committee review and approval which can take 2-3 weeks.
2. Assuming receipt of a grant application in the time manner specified above, the Grants & Contract
staff will review all grant and contract applications as follows:
Notice of Intent:
a.
Verify the Tribe’s eligibility to apply;
b.
Verify the Tribe meets all the grant criteria and guidelines;
c.
Verify whether the grant requires a tribal Resolution for submission.
Grant Review Form:
a.
Ensure proper budget formatting per funding agency specifications;
b.
Ensure the correct indirect cost rate is applied;
c.
Identify if there is a non-federal matching requirement and, if so, that it is capable of being
met. Note: Submitting programs must provide specifics about the proposed source of the
match and whether it is in-kind, cash (or both), the percentage required under the
announcement, or if the match is being offered solely to score higher in review. Note:
Match funds cannot be from other federal funds, unless specified in grant regulations or
otherwise approved by Congress;
d.
Review compliance with the OMB Uniform Administrative Guidance.
3. All fully approved/final grant applications must be resubmitted to the Grants & Contracts Staff at least
3 days in advance of the funding agency’s published grant submission deadline date to provide
adequate time for electronic input, processing, and final review. This will allow any technical issues
that may arise during submission to be resolved and, if needed, provide adequate time to amend or
resubmit the grant. Confirmation e-mails will be sent to the Project Coordinator following submission
for their final review and to verify that all necessary attachments were included. In most cases, no
further changes can be made after the grant submission deadline passes. As such, it is critical that
submissions allow sufficient time for an adequate final review.
4. Nez Perce Tribal Executive Committee authorizes the Grants & Contracts Staff or delegate to submit
grants on behalf of the Tribe if required through on-line grant portals (Resolution NP 13-150), if
approved by Resolution, Administrative Action, or Grant Review Form, not including final acceptance
or approval. Should there be a need for a department or Program/Division to submit an application
by other means, a copy must be submitted via e-mail (PDF format) to the Grants & Contracts Staff at
the time of submission.
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5. All applications submitted to the funding agencies will include the Tribe's indirect cost rate for that
fiscal year, or the most recently approved rate. Any omission or reduction of indirect expense from
such approved rate in a proposal must be accurately calculated and will require a waiver and specific
approval by NPTEC through Administrative Action (. Programs should be prepared to explain and
justify to their subcommittee the merits and reasons to proceed with the submission without full
reimbursement being made to the Tribe. Documentation should be provided to subcommittee showing
the cap or limit on indirect.
Note: if a funding agency does not pay the full costs, the Tribe’s General Fund has to pay and, as such,
it is imperative that informed decisions be made by tribal management.
6. Upon receipt of a grant award notice, Departments and Programs/Divisions shall notify the Grants &
Contracts Staff immediately and provide the original award documents. Awardees will also be notified
immediately when awards are first received in the Finance Department.
Post-Award Policy & Procedures:
Once the final award documents (Notice of Award, Assistance Agreements, etc.) are received the tribal
program receiving the award will initiate the award process utilizing the Contract Review form for final
review and formal acceptance by the Tribe. and forward the review form with documents to the Grant &
Contract Coordinator. The packet is forwarded to Office of Legal Counsel to review if there are terms
and conditions included.
Once the award documents have been reviewed, and all recommended changes made, the award document
will be sent to the Department or Program/Division to present to their respective subcommittee for final
acceptance.
1. Final award, Budget form will be forwarded to the accountant to set-up in the financial system.
2. On a newly awarded grant or contract that is not of a recurring nature with the same funding agency,
an Intake Meeting must be scheduled by Program staff with the Grants & Contracts Staff. This meeting
shall include the responsible Program Manager or Director, Project Coordinator, and their staff
responsible for managing the project, and the assigned Accountant, to review the terms and conditions
of the award and to make sure that all parties will be operating with a common understanding.
3. All original financial records related to grants and contracts will be maintained in the Finance
Department, with programs responsible for maintaining copies as well. Grant and contract regulations
and other compliance requirements must be strictly adhered to.
4. The Grant & Contract Accountants' major responsibilities are as follows:
a. Maintain all financial records for grants and contracts that are assigned to them, keeping them
completely reconciled to the Tribe's financial records, and initiating any required adjusting
entries to maintain the various accounts under their area of responsibility;
Page 28 of 50
b. Review and control expenditures, and question or disallow any purchase that would exceed
approved budgets or is unallowable under the award;
c. Monitor and maintain budgets and cash balances;
d. Invoice funding agencies for reimbursement or draw down funds electronically, as required;
and
e. Prepare internal and external financial reports as required.
5. All invoices to funding agencies related to grants and contracts are to be initiated by the Finance
Department and submitted directly to the funding agencies for reimbursement/payment. On occasion,
a program may assist in invoice preparation if circumstances warrant.
6. Department and Program/Division Managers and Directors have the ultimate responsibility to ensure
that appropriate ongoing records and documentation are kept by each program operating any grant or
contract that includes non-federal share matching requirements. The program staff should interact
with their assigned Accountant and provide the correct matching amounts and supporting
documentation to the Finance Department in a timely manner for the accountant to record and report
such match in the appropriate fiscal period.
7. Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the
work performed. These records must be supported by a system of internal controls that provide
reasonable assurance that the charges are accurate, allowable, and properly allocated. They must
reflect the total activity for which the employee is compensated by the Tribe, not exceeding 100% of
the compensated activities, and support the distribution of the employee’s salary among specific
activities or cost objectives if the employee works on more than one Federal Award, a Federal award
and non-Federal award, an indirect cost activity and a direct cost activity, or two or more indirect
activities which are allocated using different allocation bases.
8. Budget estimates (i.e. estimates determined before the services are performed) alone do not qualify as
support for charges to Federal awards, but may be used for interim accounting purposes provide that
they produce a reasonable approximation of the activity actually performed, significant changes in the
corresponding work activity are identified and entered into the records in a timely manner, and the
Program includes an after-the-fact review of the interim charges such that all necessary adjustments
are made such that the final amount charged to the Federal award is accurate, allowable and properly
allocated.
9. Narrative program progress reports shall be submitted by the Departments and Programs/ Divisions
to the funding agencies at intervals specified in the grant award or contract requirements. Financial
reports shall be submitted by the assigned Accountant to the funding agencies at intervals specified.
Note: Late submissions by either party may result in audit findings that are extremely negative to the
Tribe. Copies of all records related to a grant must be retained by each party for possible examination
by the Tribe’s independent auditors each fiscal year, including documentation that the SAM website
was utilized before outside contractors were hired.
Page 29 of 50
10. Accounting records and source documents shall be maintained by the Finance Department in a manner
sufficient to comply with the audit requirements of OMB Circular A-133 and agency regulations.
Records shall be kept a minimum of seven (7) years following final closeout of the applicable grant,
or longer if there is litigation, claim, negotiation, audit, or other action involving the records.
Superfund agreements require a 10-year retention period, plus written approval from the EPA award
official before destroying any records. As always, Accountants and individual Departments and
Programs/Divisions should determine if they have unique needs requiring longer retention periods,
keeping in mind that there could also be legal ramifications to the Tribe by keeping records longer
than necessary. Contact the Office of Legal Counsel if there are any questions in this regard.
11. The Departments and Program/Divisions shall work with funding agencies to obtain advance approval
for any line-item budget modifications, when required. After receiving agency approval, the approved
Budget Modification form will be utilized and forwarded to the assigned Accountant for processing,
including documentation of agency approval.
12. Requests for an extension of the performance/budget period, and budget modifications for either an
increase or decrease in funding or scope of work, must be approved in advance by the funding agency,
and approval notice from the awarding agency sent to the assigned Accountant immediately upon
receipt. If required, an amended Resolution may be necessary. The program is responsible for
submitting the Grant Review form for the extension, continuation, or modification of the grant.
Page 30 of 50
SECTION IX - PROPERTY,
PLANT & EQUIPMENT
(Fixed Assets)
Purpose
To include all elements necessary to purchase, maintain information about and track Fixed Assets by the
acquiring Department and Program/Divisions and to produce information that is necessary for internal
and external reporting purposes, including proper accounting for depreciation for audit purposes.
To make the Fixed Asset accounting process more efficient for Departments and Program/Division
Managers and Directors who have the ultimate responsibility to ensure that all transactions are following
federal regulations and tribal policies.
To include control elements necessary to properly account for all additions, deletions, or transfers and to
safeguard Fixed Assets.
Policy & Procedures:
1. Acquisitions will be recorded on the Tribe’s Fixed Asset records (capitalized) when the purchase price
of that item is $10,000 and above and the item has a useful life greater than one year. Generally
Accepted Accounting Principles (“GAAP”) generally require Fixed Assets to be recorded at their cost,
including all normal expenditures to bring the asset to a location and in final condition for its intended
use. In the case of equipment, such costs may include transportation, installation, assembly, external
consultants directly involved in installation/programming, etc. In the case of buildings, such costs
may include architectural fees, excavation and site preparation, utilities, wiring, etc.
2. Fixed Asset purchases should be itemized individually in all approved budgets, and expenditures in
excess of total approved budgeted amounts will not be processed without NPTEC approval.
3. Purchases must comply with the Accounts Payable and Purchasing policies in Section I of this
Manual, including the requirement for competitive bids. Requisitions shall code Fixed Asset
purchases for equipment to Account 7100, in the appropriate fund in which it is budgeted.
4. With the exception of software, intangible assets, and other cases where it is not practical, all Fixed
Asset purchases require a Tribal Asset Tag to be applied. The Finance Department maintains an
inventory of tags, and they should be requested whenever an asset is received. The acquiring
Department or Program/Divisions are responsible for physically applying the tag and remitting two
color photographs of the asset acquired to the Finance Department for storage in the Fixed Asset
database – one photo of the overall asset and the other displaying its tag number after application. It
is the responsibility of all Managers and Directors to ensure that all property requiring a property tag
is, in fact, tagged when first placed into service.
5. All transfers of Fixed Assets between Departments and Programs/Divisions must be ultimately
approved by the responsible Accountant (to ensure compliance with applicable regulations) and the
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Director of General Accounting or the Finance Manager. A Fixed Asset Transfer form shall be
submitted to the Finance Department indicating the following:
a. Description of transferred property, including tag number and serial number;
b. Department or Program/Division transferring the Fixed Asset;
c. Department or Program/Division receiving the Fixed Asset; and
d. Signatures of the Respective Department and Program/Division Managers or Directors, and
Department Executives, all of whom must approve the transfer.
Note: Many grants & contracts will not allow an Asset to be transferred during the period a grant is
active.
6. Any disposal of surplus Fixed Assets requires submission of a Fixed Asset Transfer & Disposal form
approved by the Department Executive, with a proposed disposal of any asset with a current value of
$10,000 or more also requiring NPTEC approval through the appropriate subcommittee. When
feasible, disposals will be by a public bid process and advertised by the disposing Department or
Program/Division. A listing of all assets to be sold will be included on the form and submitted to the
Finance Department, prior to the sale, describing said asset(s), including tag and serial/VIN
number(s).
7. Disposal of vehicles (cars, trucks, boats, snowmobiles, ATVs, trailers, etc.) will also require a transfer
of title. Contact the Finance Department for any assistance needed in obtaining title documentation.
8. All funds received from disposals will be treated in accordance with grant or contract provisions,
where applicable. Unless otherwise specified, proceeds shall be credited to the Department or
Program/Division disposing of the asset, preferably in the same fund in which it was acquired.
9. Leasing should be considered as an alternative to purchasing when it will help in the management of
that particular budget or the Tribe’s overall cash flow situation. This policy should be considered and
analyzed by Departments and Programs/Divisions at the time budgets are prepared.
10. NPTEC members, Department Executives and Program/Division Managers and Directors are
responsible for all tribal property under their control, with particular emphasis at the time of an
employee’s termination, to make sure all tribally issued property is returned to the Department and
Program/Division. Note: this principle also applies to tribal property not otherwise qualifying as a
Fixed Asset (see #13 below).
11. A formal physical inventory of tribal Fixed Assets will be taken every two years under the direction
of the Finance Manager, pursuant to federal regulations, and in certain circumstances upon the closeout of a grant or contract. All Departments and Programs/Divisions should be prepared to assist as
needed in this activity.
12. Tribal Law Enforcement shall be notified immediately if any tribal property is destroyed, damaged or
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stolen. A copy of such report will be forwarded to the Finance Department. Such report will include:
a. A description of the property destroyed, damaged or stolen, including its tag and serial/VIN
number(s);
b. The location and date of the incident;
c. An explanation of the circumstances of the damage or theft;
d. A photo of the damaged property; and
e. A copy of the completed police report will be returned to the responsible Department of
Program/Division and to the Finance Department, which will then initiate an insurance claim,
when applicable. Insurance proceeds, less any deductible, will be credited to the Department or
Program/Division whose property was damaged, destroyed, stolen, or lost.
13. Department Program/Division Managers will track sensitive items that are not capitalized (drones,
bicycles, trailers, laptop and desktop computers, tablets, printers, cameras, specialized equipment,
etc.) and maintain an internal inventory system. This list will be provided to the Finance Department
(see #11 above).
14. There shall be no personal use of tribally owned equipment, unless specifically authorized in writing
by a Department Executive and for a tribal-related or sanctioned purpose. In addition, sharing of
property of tribal assets between Departments and Programs/Divisions must also be approved in
writing by each Department Executive and, more importantly, be specifically allowable under any
grant terms and conditions or otherwise approved by the funding agency.
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SECTION X - ACCOUNTS
RECEIVABLE & CASH RECEIPTS
Purpose
To ensure all collections and deposits of funds due to the Tribe are processed accurately.
Working with the Accounts Receivable Specialist, the responsible Accountants share the ultimate
responsibility to ensure that all funds due to the Tribe from grants, contracts, customers, etc. are received
in a timely manner.
To include control elements necessary to segregate duties and reduce the likelihood of fraud.
Policy & Procedures:
Reasonable efforts will be made to collect past due funds owed to the Tribe. Seriously past due accounts
may be turned over to a collection agency, or have legal proceedings instituted for collection.
1. All paperwork necessary for collection and reimbursement of funds should be submitted to the
Finance Department on a timely basis. The accountants will generally prepare all invoices to funding
agencies and, where authorized, process the drawdown of funds.
2. Any funds received by Departments and Programs/Divisions are to be remitted to the Finance
Department on a daily basis preferably, and in any event no later than weekly. Collections must be
accompanied by documentation indicating the source, nature of the amount received and the fund
account number to be credited. Until submitted, funds must be properly safeguarded, and access
limited to necessary employees. Note: this may include amounts that will eventually be refunded (such
as court bonds held until a certain condition is satisfied). When refundable, the responsible
Department or Program/Division should utilize a Requisition (with backup support) to initiate the
refund payment to the appropriate individual or agency.
3. All checks and cash received by the Finance Department will be deposited to the bank no later than
on a weekly basis, with checks processed through the Digital Corp. Teller Scan as soon as practicable,
depending on daily workloads. The Office Assistant will enter the checks in the cash receipts log on
a daily basis when received, noting the date received, check number, maker, description, and the
amount. The responsible Accountant will receive and review the bank deposit slip then forward to the
Accounts Receivable Specialist for proper crediting.
4. Any funds received as a donation or otherwise intended as a “pass-through” to a 3rd party person or
entity shall have the written approval of the Treasurer on the Requisition related to that subsequent
payment.
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SECTION XI
DONATIONS
Purpose
To include all elements necessary to receive, maintain and control amounts received as donations,
fundraising events, or dedicated funds.
To make the accounting and receipt of dedicated funds and other donations efficient for those Departments
and Programs/Divisions who have the ultimate responsibility to ensure that the desires of the donor are
met.
Policy & Procedures:
1. Sponsors of a particular cause will submit a Plan of Operations to NPTEC requesting a tribal
Resolution to establish dedicated funds that will include the following:
a.
b.
c.
d.
e.
f.
g.
Summary of the submitting organization/entity/individual's mission;
Summary of the purpose of said dedicated funds or purpose of donation;
Criteria for usage of dedicated funds and/or income generated by same;
Length of time for existence of the fund;
Criteria for managing assets of the fund;
Criteria for oversight committee of the fund; and
Reporting requirements for the fund.
2. The Nez Perce Tribe is treated as States for certain purposes under the Internal Revenue Code, Section
7871, and since the Tribal Government Statue Act, P.L.97-473 of 1983 treats Tribes as states, as such
all gifts or grants for a public purpose made to the Tribe have the same deductibility status as if the
donation, gift, or grant were given to a state government. All such gifts would, therefore, be deductible
from the donor's tax return as if the gift were made to a charitable organization. In addition, the Tribe
has established a 501c (3) non-profit corporation that can be utilized to receive donations from certain private
foundations.
3. A Requisition form will be submitted by the Department or Program/Division responsible for the
donation to disburse its funds according to the terms in the Resolution or Plan of Operations.
4. Departments and Programs/Divisions shall provide receipts or thank you letters to the donating party
for all gifts or contributions.
A revenue account xxxx-xx-6xxx, will be set-up in the financial management system to track donations.
The program should use the donated funds in that current fiscal year, or request to roll-over the donated
funds to the next fiscal year.
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SECTION XII - GASB 87
LEASES
Purpose:
To establish guidelines and procedures for identifying, classifying, and accounting for leases in
accordance with GASB Statement No. 87. This policy ensures the accurate reporting of leases in the
financial statements of Nez Perce Tribe. This policy applies to all departments within the Tribe involved
in acquiring, using, or managing leased assets and lease agreements.
Lease Exclusions
Under GASB 87, certain types of leases are scoped out of the definition of leases. These exclusions
include:
1. Short-Term Leases: Contracts with a maximum possible term of 12 months or less, including any
options to extend, are excluded. Payments for these short-term leases are recognized as outflows of
resources.
2. Contracts for Intangible Assets: Software agreements or other agreements for intangible assets
without tangible component are not considered leases.
3. Contracts that Transfer Ownership: If the contract transfers ownership of the underlying asset to the
lessee by the end of the contract and does not contain a purchase option, it is excluded from the scope
of leases.
Criteria for Lease Recognition
An arrangement will be classified as a lease if it meets the following criteria:
•
•
•
The contract conveys control of the right to use a specific asset for a specified period.
There is an identifiable asset associated with the lease.
Payments are made in exchange for the right to use the asset.
Recording Lease Liabilities and Assets
The lease liability is recognized at the commencement of the lease term and is measured as the present
value of expected lease payments over the term of the arrangement. The liability is discounted using
either the implicit rate in the contract (if determinable) or the Tribe’s incremental borrowing rate (the
rate the Tribe would pay to borrow funds under similar terms).
The lease asset (right-to-use lease asset) is initially measured based on the amount of the lease liability,
adjusted for:
-
Any payments made prior to the lease term start date.
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-
Any initial direct costs associated with the arrangement (e.g., implementation fees).
Lease Capitalization Threshold
The Tribe will recognize lease assets and liabilities with present value of future payments that exceeds
the Tribe’s leases capitalization threshold of $25,000.
Amortization of Lease Asset
The right-to-use lease asset is amortized over the shorter of its useful life or the lease term.
Amortization should be calculated on a straight-line basis unless another method better reflects the
asset’s use.
Subsequent Reassessment
Contracts should be reviewed periodically or upon significant changes to reassess and update the lease
liability and asset amounts. Reassessments should occur when:
•
•
There is a modification or extension of the contract.
Changes to estimated amounts or discount rates arise.
Disclosure Requirements
Financial statements will include disclosures on the Tribe’s lease activities, including:
•
•
•
•
A description of lease arrangements.
Information on the total lease asset and liability balances.
Details on significant assumptions used in measurement.
Schedule of future lease principal and interest payments.
Roles and Responsibilities
•
Finance Manager: Evaluate any potential leases provided by department heads to determine
GASB 87 applicability. Review and approve lease journal entries and disclosures. Ensure all
leases are properly identified, classified, and recorded in accordance with this policy and GASB87.
•
Department Managers: Notify the Finance Department of any new, modified, or terminated
potential leases.
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SECTION XIII - GASB 96
Subscription-Based Information
Technology Arrangements (SBITA)
Policy
Purpose
To establish guidelines and procedures for identifying, classifying, and accounting for Subscription-Based
Information Technology Arrangements (SBITAs) in accordance with GASB Statement No. 96. This
policy ensures the accurate reporting of SBITAs in the financial statements of Nez Perce Tribe (the Tribe).
This policy applies to all departments within the Tribe involved in acquiring, using, or managing
subscription-based information technology services.
SBITA Exclusions
Under GASB 96, certain types of software agreements are scoped out of the definition of SubscriptionBased Information Technology Arrangements (SBITAs). These exclusions include:
1. Short-Term SBITAs: Contracts with a maximum possible term of 12 months or less, including any
options to extend, are excluded. Payments for these short-term SBITAs are recognized as outflows of
resources.
2. Contracts with Stand-Alone Tangible Capital Assets: Software agreements that involve only tangible
capital assets without any significant software component are not considered SBITAs.
3. Contracts with Insignificant Software Components: If a contract includes both a tangible capital asset
and a software component, but the software component is insignificant, it is excluded from the scope
of SBITAs.
Read more here: Summary - Statement No. 96 (gasb.org)
Criteria for SBITA Recognition
An arrangement will be classified as an SBITA if it meets the following criteria:
The contract conveys control of the right to use a specific IT asset for a specified period.
There is an identifiable asset associated with the subscription.
Payments are made in exchange for the right to use the IT asset.
Recording SBITA Liabilities and Assets
The subscription liability is recognized at the commencement of the subscription term and is measured as
the present value of expected subscription payments over the term of the arrangement. The liability is
discounted using either the implicit rate in the contract (if determinable) or the Tribe’s incremental
borrowing rate (the rate the Tribe would pay to borrow funds under similar terms).
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The subscription asset (right-to-use subscription asset) is initially measure based on the amount of the
subscription liability, adjusted for:
Any payments made prior to the subscription term start date.
Any initial direct costs associated with the arrangement (e.g., implementation fees)
SBITA Capitalization Threshold
The Tribe will recognize subscription assets and liabilities with present value of future payments that
exceeds the Tribe’s SBITAs capitalization threshold of $25,000.
Amortization of Subscription Asset
The right-to-use subscription asset is amortized over the shorter of its useful life or the subscription
term. Amortization should be calculated on a straight-line basis unless another method better reflects the
asset’s use.
Subsequent Reassessment
Contracts should be reviewed periodically or upon significant changes to reassess and update the
subscription liability and asset amounts. Reassessments should occur when:
There is a modification or extension of the contract.
Changes to estimated amounts or discount rates arise.
Disclosure Requirements
Financial statements will include disclosures on the Tribe’s SBITA activities, including:
A description of SBITA arrangements.
Information on the total subscription asset and liability balances.
Details on significant assumptions used in measurement.
Schedule of future SBITA principal and interest payments
Roles and Responsibilities
Finance Manager: Evaluate any potential SBITA provided by department heads to determine GASB 96
applicability. Review and approve lease journal entries and disclosures. Ensure all SBITAs are properly
identified, classified, and recorded in accordance with this policy and GASB-96.
Department Managers: Notify the Finance Department of any new, modified, or terminated SBITAs.
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SECTION XIV
REPORTS & BUDGETS
Purpose
Accountants shall be responsible to provide each Department and Program/Division with a financial
report package, electronically in PDF format, at the end of each month that contains the current Budget
Status Report (comparing actual expenditures vs. budget for the current month and year-to-date) and Trial
Balance Detail Report (containing individual transactions contained in the current month actuals). Due to
timing in closing out the monthly transactions, applying Indirect Costs, etc., it is expected that these
reports will be available by the 10th working day of the following month. However, at any point in the
month, Department Executives and their Managers & Directors may request they be provided such reports
current as of that date (which may not include all transactions for the month or the application of Indirect
Costs to the budget). Labor Distribution Reports are also available from the responsible Accountants,
upon request, showing the employees, hours and amounts charged to a given budget for the period.
Adjustments to Actual:
On the Program side, it is expected that actual expenditures, especially labor allocations, will be carefully
reviewed when processing the original source document (Requisitions, Payroll Vouchers, etc.), and
subsequent reports reviewed on a timely basis such that any errors can be identified and sent to the
responsible Accountant on an Expenditure Adjustment form before the last day of the following month
for correction in that month. Corrections to labor allocations need to be submitted on a Labor Adjustment
form by the close of business on the Friday preceding a bi-weekly payroll run in order to be processed
with that next payroll. Timely corrections are crucial to accurate reporting.
Budget Modifications:
Exceeding an approved total budget amount will not be allowed without approval by the Budget &
Finance Subcommittee and NPTEC. In general, a Budget Modification form should be processed only
when required by the terms and conditions of an outside agency-funded grant or contract, and before the
expenditure is incurred. When submitted to the Finance Department, such forms shall be accompanied by
written (or e-mail) approval from the funding agency.
For tribally funded and Indirect programs, the following types of budget modifications will not be
processed without approval by the respective Department Executive, subcommittee Chairperson and
NPTEC Treasurer:
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1) Transfers based on savings in Salary and Fringe Benefit line items to any other expense account;
2) Transfers between accounts that decrease Indirect Cost recovery from previously approved levels;
3) Transfers between accounts that increase the Travel line-item budget; and Transfers that simply
attempt to revise budgets, after the fact, to match actual expenditures already incurred.
Individual line items within an approved tribal budget may be over or under budget to allow for better
financial analysis of variances and improved future budgeting, provided that the total program budget is
not exceeded. Actual expenditures shall never be misclassified as to their true nature in order to fit into
approved budgetary line items. Those employees managing tribal budgets should instead be prepared to
provide reasons and justification when expenditures materially exceed a budgeted line-item amount.
A budget is a best guess estimate, sometimes made over a year in advance of what may or may not actually
occur. As such, natural variances will take place as situations change over time (employee turnover,
economic changes, etc.). The goal in budgeting is to make the best projection possible and then analyze
the line-item variances and the reasons they occur, whether positive or negative, and then incorporate that
knowledge into an improved subsequent year budget. Multiple line-item budget modifications throughout
the year tend to hide unexpected situations that were encountered and falsely indicate near- perfect
planning at year-end when that was not really the case. These budget modifications add little end value
and can cause significant administrative effort throughout the year by program staff, Finance Department
staff, and upper management asked to review and approve the changes.
Below are some excerpts from the Preface to GASB #34, the government accounting standard the Tribe
must comply with:
“Showing budgetary compliance is an important component of government’s
accountability…Requiring governments to report their original budget…adds a new
analytical dimension and increases the usefulness of the budgetary comparison.
Budgetary changes are not, by their nature, undesirable. However, we believe that the
information will be important - in the interest of accountability - to those who are aware
of, and perhaps made decisions based on, the original budget. It will also allow users to
assess the government’s ability to estimate and manage its general resources.”
In general, the Tribe begins its tribally funded budget process in late spring for the upcoming fiscal year,
with most of the activity centered over the summer months. Each year, informational packets will be
distributed along with that year’s preparation and review schedule.
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SECTION XV
INDIRECT COSTS
Purpose
From an overall standpoint, two types of funding basically support the Tribe’s operations: agency- funded
grants and contracts and “hard dollar” sources. Agency-funded grants and contracts generally reimburse
the Tribe for its expenditures on a dollar-for-dollar basis and currently fund approximately 75% of the
Tribe’s programs. The Tribe does not provide a “mark-up” or profit factor. These programs are subject to
strict federal or other regulations. Many of the Tribe’s internal programs have their direct costs funded by
hard dollar sources, which include revenues received from the Tribe’s various enterprises (casinos,
convenience stores, etc.), taxes (fuel, tobacco, sales & hotel), leasing, lottery, investments, etc. No matter
how these programs are funded, all budgets are allocated a proportionate share of the Tribe’s “Indirect”
costs in addition to the direct costs of running the program.
Indirect costs are defined in the federal regulations as “those costs incurred for a common or joint purpose
benefitting more than one cost objective, and not readily assignable to the cost objectives specifically
benefitted without effort disproportionate to the results achieved.” Within the Tribe, Departments such as
Human Resources, Finance, Plant Maintenance, Housekeeping, Communications, Emergency
Management, Technology Services, Law & Justice and Executive Direction, GIS, Grant Writers, NPTEC
Support Staff, and portions of NPTEC (50%) and OLC (25%) make up the costs eligible for inclusion in
the Tribe’s Indirect Cost Pool. Since they are included in the amounts charged to federal agencies, Indirect
Costs are also considered to be “federal funds” and, as such, are subject to the same rules other funded
programs follow and are ineligible to be used for matching purposes.
Note: Capital outlays to acquire Fixed Assets are not an allowable cost in the Indirect Cost Pool for that
fiscal year. As such, those expenditures need to be carefully analyzed, documented, and justified since
their purchase requires the Tribe’s General Fund to “front” those costs for a longer period of time. The
annual depreciation expense that is booked for those assets over their useful lives will then be allowable
in subsequent year Indirect Cost Pools, continuing annually until the original costs are fully recovered.
For the Tribe’s cash flow purposes, it may be important for Indirect Cost Programs to consider
leasing/financing versus purchasing assets to ensure cost recovery in the year of the expenditure.
In general, the Finance Department will submit the Tribe's proposed indirect cost negotiations agreement
to the Interior Business Center within one hundred and eighty (180) days following the fiscal year end.
In simplest terms, the rate is basically calculated by dividing the total “expenses” in the Indirect Cost Pool
by the adjusted total of all the direct program costs, both agency-funded and tribally funded. However,
there are many adjustments that also factor into that calculation.
Why Do Programs Have to Pay Indirect?
As mentioned above, the Tribe’s funding sources do not provide for a profit factor. Yet, all of the Tribe’s
programs generally require the support of its Indirect Cost Programs in order to operate successfully
(hiring employees, paying employees, maintaining facilities, providing technology, etc.). If the Tribe’s
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outside agencies and hard dollar programs do not fully pay for these costs, the burden falls on the Tribe’s
General Fund to pay for them.
Further complicating matters, not all federal and state programs pay the fully approved rate. Certain
legislation has imposed “caps” on indirect cost recovery in certain programs funded by grants. These may
have the effect of reducing the Tribe’s recovery to 15%, 10%, or even less, in which cases the General
Fund must make up that difference and effectively subsidize the program with internal funds.
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DEFINITIONS & CHART OF
ACCOUNTS
DEFINITIONS:
ACCOUNT NUMBER: A group of numbers used to identify the fund, department or sub-fund,
and description of an account. For example, 1011-02-7070 is broken down as follows: 1011 =
Indirect cost fund, 02 = Finance Department and 7070 = Supplies.
ALLOWABLE COSTS: OMB Uniform Administrative Guidance defines this category of
costs as having to meet the following general criteria:
• Be reasonable for the performance of the award and be allocable thereto under these
principles;
• Conform to any limitations or exclusions set forth in these principles or in the award as
to types or amount of cost items;
• Be consistent with policies and procedures that apply uniformly to both federally
financed and other activities of the organization;
• Be accorded consistent treatment;
• Be determined in accordance with generally accepted accounting principles;
• Not be included as a cost or used to meet cost sharing or matching requirements of any
other federally financed program in either the current or a prior period; and
• Be adequately documented.
ASSET: A valuable item that is owned. Examples include cash, accounts receivable, equipment,
buildings, land, etc.
APPROPRIATION: Funds set aside for a specific purpose.
BALANCE SHEET: A statement of the Assets, Liabilities, and Fund Balance (or Equity), as
of a specified date. Total Assets equal total Liabilities plus Fund Balance.
BUDGET: An itemized summary of projected/most probable income and expenditures for a
given fiscal period.
CHART OF ACCOUNTS: A list of all account numbers used by an organization to record
activity into the general ledger.
COLLUSION: Where two or more persons secretly operate together to gain an unfair
advantage over others for personal gain.
CONTRACT: A legally enforceable agreement with a party for a specified amount of valid
consideration to be paid to that party for a specific deliverable(s) outlined in a scope of work.
CREDIT: The right side of a journal entry, which can represent an increase in revenues and
liabilities (the natural balance) or decrease in expenses and assets.
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DEBIT: The left side of a journal entry, which can represent an increase in expenses and assets
(the natural balance) or a decrease in revenues and liabilities.
DEFERRED REVENUE: Revenue that is received but not yet earned or recognized.
DIRECT COST: Costs that can be specifically identified with a particular cost objective.
DISBURSEMENT: Funds paid out.
ENCUMBRANCE: Commitments related to unperformed contracts for goods or services. Used
in budgeting, encumbrances are not GAAP expenditures or liabilities but represent the estimated
amount of assets reserved for outstanding purchase orders. Some agency contracts may allow these
costs to be recovered during the closeout period.
ENTERPRISE FUNDS: Account for the operations financed and operated in a manner similar
to private business enterprises.
EXPENSE: Items that do not qualify for capitalization, either because of the amount or the fact
they are expected to be consumed in less than a year. A decrease in financial resources.
FIDUCIARY FUNDS: Funds to account for assets held in a trustee capacity.
FIXED ASSET: A single tangible item valued at $10,000 or more with a useful life longer than
one year is classified as a fixed asset. Examples of fixed or “capital” assets include land, buildings,
equipment, and vehicles.
FRINGE BENEFIT: An employee benefit given in addition to one’s wages or salary. Examples
include payroll taxes, health insurance and retirement plan contributions.
FUND: A fiscal and accounting entity with a self-balancing set of accounts which is segregated
for the purpose of tracking specific activities in accordance with special regulations or restrictions.
FUND BALANCE: The difference between the assets and liabilities of a governmental fund
which, at the end of a fiscal period, is increased or decreased by netting revenues and expenses.
GASB: Government Accounting Standards Board. An independent, private-sector organization
that develops and issues accounting and financial reporting standards for federal agencies and the
U.S. state and local government.
GENERALLY ACCEPTED ACCOUNTING PRINCIPLES: Also referred to as GAAP, these
are the rules of accounting established by experienced professional accountants and bodies such
as the Financial and Government Accounting Standards Boards.
GENERAL FUND: Accounts for all “essential government functions” and financial resources
except those required to be accounted for in another fund or paid for under an alternative funding
source.
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GENERAL LEDGER: A record of monetary transactions of an organization posted in the form
of debits and credits.
GOVERNMENTAL ACCOUNTING STANDARDS BOARD: Also referred to as GASB, this
is the board that is the authority for establishing accounting standards for governmental entities
such as the Tribe.
GRANT: Any agreement, memorandum of agreement, contract or grant agreement or award that
provides funding to the Nez Perce Tribe or its entities to perform a specific project. Grants may
be provided to the Tribe or its entities by the federal government, state, a business, an organization,
foundation, or individual.
INDIRECT COST: Costs incurred for a common or joint purpose benefiting more than one cost
objective. Assigning these costs to more than one objective requires an effort that is
disproportionate to the results achieved. Examples of indirect costs include Finance and Human
Resources Department staffs and electricity and maintenance for the administration building.
JOURNAL ENTRY: A two-sided entry consisting of a debit and a credit used to record
information into the general ledger, sometimes referred to as a journal voucher.
LEASE: A lease is a contract that conveys control of the right to use another party’s (a lessor’s)
asset, as specified in the contract, for a period of time in an exchange or exchange-like
transaction.
LIABILITY: Obligations of an entity. An example of a current liability is accounts payable
whereas a long-term liability may be a bank loan payable in more than one year.
MEMORANDUM OF AGREEMENT (MOA): A document written between two or more
parties to cooperatively work together on an agreed upon project or goal, the MOA will contain
specific language regarding the responsibilities of each party and the benefits for each party. There
is a list of binding terms, and it usually has an obligation of funds specified for the project or
objective.
MEMORANDUM OF UNDERSTANDING (MOU): A document written between two or more
parties that indicates a common line of action. It is used in cases where the parties do not wish to
have a legal commitment or in situations where the parties cannot create a legally enforceable
agreement.
OMB: The Federal Office of Management and Budget.
OMB UNIFORM ADMINISTRATIVE GUIDANCE: Published in the Federal Register under
2 CFR Chapters 1 and 2, Part 200, these final rules governing administrative requirements, cost
principles and audit requirements for federal awards.
PROPIETARY FUNDS: The funds used to account for governmental activities that are similar
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to “for profit” business operations in the private sector.
REASONABLE COSTS: OMB Uniform Administrative Guidance defines reasonable costs as
follows: A cost is reasonable when in its nature or amount, it does not exceed that which would
be incurred by a prudent person under the circumstances prevailing at the time the decision was
made to incur the costs. The question of the reasonableness of specific costs must be scrutinized
with particular care in connection with organizations or separate divisions thereof that receive the
preponderance of their support from awards made by Federal agencies. In determining the
reasonableness of a given cost, consideration shall be given to:
• Whether the cost is of a type generally recognized as ordinary and necessary for the
operation of the organization or the performance of the award;
• The restraints or requirements imposed by such factors as generally accepted sound
business practices, arm’s length bargaining, federal and state laws and regulations, and
terms and conditions of the award;
• Whether the individuals concerned acted with prudence in the circumstances, considering
their responsibilities to the organization, its members, employees, and clients, the public
at large, and the government; and
• Significant deviations from the established practices of the organization that may
unjustifiably increase the award costs.
REVENUE: Increase in financial resources. Other than reimbursement-type revenues received
from its grants and contracts, the Tribe receives revenue from various taxes (Tobacco, Fuel, Sales
& Hotel), from the casinos under the Gaming Revenue Allocation Plan, utilities and broadband
customer billings, sale of fishing permits, TERO and other licenses and fees, leases and crop share,
facility rents, lottery proceeds, interest & dividends on bank accounts and invested funds, etc.
This type of revenue is often referred to as being from a “hard dollar” source.
SBITA A SBITA is a contract that conveys control of the right to use another party’s (a SBITA
vendor’s) information technology (IT) software, alone or in combined with tangible capital assets (the
underlying IT assets), as specified in the contract for a period of time in an exchange or exchange-like
transaction.
SEFA: One of the required annual financial reports under OMB Circular A-133 that is part of the Tribe’s
audit – Schedule of Expenditures of Federal Awards. This report lists all the Tribe’s federal awards for the
fiscal year, the Catalog of Federal Domestic Assistance (CFDA) number, agency award number, period
of award, amount authorized and actual expenditures during the year.
SPECIAL REVENUE FUNDS: Funds accounting for specific revenue sources that are legally
restricted to be expended for specific purposes, such as the Tribe’s various grants and contracts.
STATEMENT OF REVENUES, EXPENDITURES, AND CHANGES IN FUND BALANCE: A financial
statement that shows revenue, expenditures, and changes in fund balance during a specified period of time.
TRIAL BALANCE: A list of the balances of the accounts in a ledger fund by double entry, with
the debit and credit balances shown in separate columns. The totals of the debits and credits must
be equal for the Trial Balance to balance.
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UNALLOWABLE COSTS: The following costs are unallowable under OMB Uniform
Administrative Guidance:
•
Alcoholic beverages
•
Bad debts
•
Contingencies
•
Contributions and donations
•
Entertainment
•
Fines and penalties
•
Fund raising
•
Interest and other financing costs except where authorized under the circular
•
Legislative expenses
•
Lobbying expenses
•
Under-recovery of costs of other grants or agreements
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CHART OF ACCOUNTS
Included below is a listing of the most frequently used Account Numbers that employees should be aware
of, and that are paired up with the appropriate fund number assigned to the Tribe’s various Departments
and Programs/Divisions when completing Requisitions or otherwise authorizing invoices for payment.
Certain budgets may use some or all of these accounts. When an employee has a specific request or need
to accumulate and track costs in a different account, contact your responsible Accountant to discuss the
matter and they should be able to establish a new account for your use.
Number
Description
7010
7015
7020
7023
7024
7025
7035
7055
7060
7064
7065
7066
7070
7080
7082
7090
7095
7100
7200
7700
7800
7801
Salary & Wages
Fringe Benefits
Consultants
Computer Services
Attorney Fees
Contractual/Sub-contracts
Training
Mileage
Travel
GSA Vehicles
Vehicle Maintenance
Service to Participants/Stipends
Supplies
Repairs & Maintenance
Vehicle Fuel
Telephone
Software Subscriptions/Agreements
Capital Outlays (equipment and other assets)
Utilities
Other Expenses
Indirect Expense
Match Expense (non-federal share)
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FORMS
•
•
Original/New Budget
Budget Modification
•
•
Grant Notice of Intent
Grant Review
•
•
•
•
•
Annual Leave Cash-In Request
Annual Leave Donation Request
Direct Deposit Authorization
Salary Advance Request
Voluntary Payroll Deduction
•
Expenditure/Labor Adjustment
•
•
•
•
•
Fixed Asset Transfers & Disposals
Inter-Department Billings & Allocation
Mileage & Miscellaneous Business Expense Reimbursement
Petty Cash Reimbursement
Requisition
•
Signature Authority Delegation
•
•
•
Travel Authorization
Travel Settlement
Travel Advance Request
Page 50 of 50
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.