There will always be tribal-specific policies and protocols that must be followed to ensure that financial internal controls are followed so that the tribe passes their audit and protects itself from possible situations when grant funds may have to be paid back to the funder. The finance office staff will be able to provide a new TVR director with information on the tribe's financial procedures and policies. In addition, directors will want to establish internal, program-specific, policies and protocols to ensure the bridge between the federal grant funding agent and the tribal financial offices is sound and operates smoothly.

Participant Expenditures

In general, to ensure participant expenditures fall within generally accepted guidelines, TVR agency staff must

make sure that the service is necessary as part of the eligibility determination process or is part of the IPE and supports the achievement of the employment goal;
explore alternate resources before allocating program funds; and
ensure the proposed service is allowable, allocable and reasonable. Further information on allowable, allocable and reasonable costs can be found here.

To ensure participant confidentiality, all procurement documentation must not contain any participant names or identifying information. Participant identifiers must also be removed from any type of report or documentation that goes outside the TVR agency—even to other tribal departments or tribal administration. A participant's case number or program ID should be substituted for their name, or the participant can be mentioned in a non-specific manner. This includes any bids or invoices prepared in the participant's name. Names should be covered, the paperwork should be copied, and the case number should be used on the copy and then submitted.

Financial Due Diligence

Financial Checks and Balances—Each TVR program must have a clear system of procurement accountability, or "checks and balances." This is to verify that billing and/or payment requests submitted to the finance office are accurate and valid budget expenses. This should not be taken lightly. If fraud takes place within the TVR program, the director can be held responsible. For example, when making procurement requests, it is prudent for the director to confirm that the actual expense is included in the participant's currently approved IPE before authorizing the payment and submitting it to the finance office. Another recommended practice is to ask participants to sign off or verify in writing that they received a service or item in order to confirm that the funds/services were not directed elsewhere by a person intending to commit fraud.

Comparable Services and Benefits—It is the responsibility of a TVR director to ensure that grant funds are allocated in a manner that provides the greatest level of service to the largest possible number of eligible participants who have an IPE. Accomplishing this requires careful consideration of alternate resources, such as other programs or TVR/VR agencies. There are many programs, both tribal and off-reservation, with resources available to support participants in their journey toward success, and TVR programs will need to become knowledgeable of the services available and eligibility requirements for them. A list of possible alternate resources can be found here. The tribe or tribal organization may have a list or publication which lists resources available in the community.

Conflicts of Interest—In tribal communities, there are often instances where people with close family relationships work in the same department, or where a program participant is a relative of a TVR staff member. Generally, it is best that a family member not supervise immediate family members, or a vocational rehabilitation counselor not provide services to an immediate family member, in order to prevent conflicts of interest. In some instances, it may may be the best option for a participant to get childcare from their father or aunt or have their brother fix their car. These situations are not uncommon in tribal communities, and not necessarily disallowed, as long as procedures are followed and the correct documentation is in place. A director may want to seek counsel from a supervisor until comfortable navigating these situations.

Case sharing—Sharing participant cases with other TVR programs and State VR is usually done under a Cooperative Agreement, Memorandum of Agreement (MOA) or Memorandum of Understanding (MOU), which outlines the protocols for sharing cases and providing shared participant services. If this type of agreement is not yet established, it may be useful to contact other TVR program directors to get copies of their agreements with their states as well as other TVR programs. More information about MOUs can be found in Module 1 under "Program Partners," and an MOU template from AIVRTTAC can be found here.