Graphic of a person standing in front of a large piggy bank and illustrations of economic charts

Reviewing the Grant Budget

An important first step is to review the budget in the initial grant documents to be sure you are able to implement it. This is done by converting it from the format required by the grant proposal to the system or format used by the tribal organization.
The director and the finance office can make sure the proposal budget has considered critical, unique, tribal components, like the employee fringe rate, indirect costs and other operational costs like phone costs and office space that may be charged to tribal programs. In many cases, these costs are charged to the tribal organization under Indirect.
If the amount of the grant award is less than the amount requested in the grant proposal, it is because, for whatever reason, the application was not funded at the requested amount. If this happens, the reduction in funding may also require a revision and/or reduction of program outcomes, which the director will be able to negotiate with the RSA project officer.
The HR department can ensure that the budget for salaries is comparable to similar existing positions (e.g., case managers with specialized skills) in other tribal departments and/or the region.
When converting the budget from the ED 524 form that was submitted with the grant application to the tribal accounting system, refer to the budget narrative for specifics about budget line items. Some items may not translate easily from the 524 form to the tribe’s system. Do your best to prepare the budget using the tribal budget guidelines. In most cases, costs under “Other” on the 524 will be divided across several categories or “line items” in the tribal system. If you need guidance on doing this, work with your supervisor or finance office contact.
When determining an agency's budget for a particular year, the RSA project officers are looking the budgetary needs for each grantee for that funding year, and will consider expenditures from past funding years, excessive balances, and the status of program outcomes.
For detailed information about participant services for budget planning purposes, see "Participant Services" in Module 6.

Match

The director and the finance office can also work together to determine how to document and/or verify the match, which is either a cash match or the value of "in-kind" or "non-cash" match, for the program. This amount may differ from that in the proposal if the award amount is less than the amount requested.
Guidance from 2 CFR 200.306, Cost Sharing and Matching, can be found here.
The 10% match amount is calculated from the total project cost (including the match amount), not the amount of the federal grant funds alone. A simple match amount calculator can be found here. You will need to download this tool into Excel to use it.
The director will need to learn how the match needs to be documented and how cash match, if that is the source of the program match, will be included in the agency budget.
If circumstances have changed and the tribal organization is not able to provide match in the current fiscal year, the director must contact their RSA project officer to request a waiver of match (see the next section below for more information).
To be accepted by the Federal government, matching funds, or cash match must meet the following criteria:
- Are documented and verifiable in your records;
- Are not included as match contributions for any other Federal award;
- Are necessary and reasonable for the accomplishment of agency objectives;
- Are allowable according to Subpart E—Cost Principles (2 CFR § 200.420 - 200.475);
- Are not paid by the Federal Government under another Federal award, except where Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs;
- Are provided for in your approved budget when required by the Federal awarding agency;
- Are incurred during the period of the task agreement or modification.

In-kind match contributions come from the grantee organization. In-kind match is typically in the form of the value of personnel, goods, and services, including direct and indirect costs. The agency must document the contributed resource of value and have it verified by the tribal organization.

- A sample In-Kind Match Contribution form for listing sources of match, along with instructions for completion, can be found here.
- A sample In-Kind Match Verification form can be found here.
- "Unrecovered" indirect costs, including indirect costs on in-kind match may be included as part of in-kind match only with the prior approval of the RSA project officer. Unrecovered indirect cost means the difference between the amount charged to the Federal award and the amount which could have been charged to the Federal award under the tribal organization's approved negotiated indirect cost rate.

Waiver of match

This section contains content provided directly by RSA.

If a Tribe is unable to provide the proposed program match within a grant year, the program director or other appropriate official at the Tribe must submit a request to waive the match requirement for that year. A formal written request to the RSA project officer should suffice to start the discussion.

There are two considerations for the timing of the request for waiver of match:

- If a grantee knows that the Tribe will not have the resources necessary to meet the matching requirement in the next budget period, a request that demonstrates and justifies the request should be submitted prior to non-competing continuation (NCC) awards are made (usually prior to July of any given FY).
- If a grantee determines that the Tribe will not have the resources necessary to meet the matching requirement during the budget period they are currently in, a request that demonstrates and justifies the request should be submitted as soon as possible and prior to NCC awards if possible.

Further information on the waiver of match can be found at 34 CFR 371.40(c).

Indirect Costs

Indirect, or "Facilities and Administration" costs are those related to the use of the tribe's or the tribal organization's facilities/offices and administrative support that cannot be claimed as direct costs. Facilities costs are related to office and meeting space, utilities, operations and maintenance. Administration costs are those such as the general manager’s office, finance, human resources and IT.

Most tribes or tribal organizations have negotiated an Indirect Cost Rate with a federal department or agency, such as HHS (Health and Human Services). This is the rate that is used when calculating the Indirect for the TVR grant and is listed in the proposed budget.

There are a couple of things to consider about Indirect costs:

Tribal expenses that are covered under the Indirect Cost Rate must not also be covered by Direct Costs, that is, paid for with direct grant funds. If the director has a question or concern about this, a good place to start is the Indirect Cost Agreement, which should detail what organizational expenses are covered by the Indirect. If there are further questions, the next steps would be to discuss with the director's supervisor and then the Finance department for clarification.
The expenses covered in Indirect costs should not be paid for using matching funds or in-kind costs that are listed under Match (see previous section).

Fund Accounting

The finance office likely uses a fund accounting system, which means that each department, program or agency has its own account number, and then each type of expenditure has its own code. In this context, the grant award is considered the "fund," and finance monitors and processes expenditures related to agency operations and services that are then paid from the fund.

Budget Modifications and Revisions

TVR agencies must develop and submit a revised budget to RSA annually when the grant amount is less than the amount requested, such as when level funding occurs. Written guidance on budget modifications and revisions, as well as revised program plans, is found in the Uniform Guidance at 2 CFR 200.308.

TVR agencies do have some authority to move funds within the budget without prior approval, according to 2 CFR 200.308, as long as the prior approval requirements at 2 CFR 200.308(c)(1) and (c)(2) are met, meaning that the director will need to seek approval from the RSA project officer in the following situations:

(i) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).

(ii) Change in a key person specified in the application or the Federal award.

(iii) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.

(iv) The inclusion, unless waived by the Federal awarding agency, of costs that require prior approval in accordance with Subpart E - Cost Principles.

(v) The transfer of funds budgeted for participant support costs, as defined in 2 CFR § 200.1 Definitions, under Participant support costs, to other categories of expense.

(vi) Unless described in the application and funded in the approved Federal awards, the sub-awarding, transferring or contracting out of any work under a Federal award, including fixed amount sub-awards as described in 2 CFR § 200.332 is not allowed. This provision does not apply to the acquisition of supplies, material, equipment or general support services.

(vii) Changes in the approved cost-sharing or matching provided by the non-Federal entity.

(viii) The need arises for additional Federal funds to complete the project.

To summarize the language from the regulations above, prior approval for budget revisions and program plan revisions is not needed when it comes to personnel cost of living increases, promotions, and similar situations. Prior approval is needed from the project officer for new staff positions or redesign of staff positions that may also change the personnel costs, as these kinds of changes are program plan changes. Proposed plan program changes also include changes to the participant services budget, as the major purpose of TVR agencies is to provide TVR services to tribal members with disabilities.

It is recommended that if a modification or revision of the agency budget is needed, it is better to err on the side of caution and communicate with the RSA project officer about the situation and share a draft version of the revised budget.