Dear Tribal Leader Letter

September 25 at 1:00 pm – 5:00 pm Eastern
Register
Location: Virtual

September 26 at 9:30 am – 12:30 pm Central
Register
Location: Dallas, Texas

October 1 at 9:30 am – 12:30 pm Eastern
Register
Location: Washington, DC

October 3 at 9:30 am – 12:30 pm Pacific
Register
Location: Seattle, Washington

October 9 at 1:00 pm – 5:00 pm Eastern
Register
Location: Virtual

Please email your written comments and recommendations for this Tribal Consultation to
consultation@ihs.gov. Use the SUBJECT LINE: CSC Methodology for Program Income.
The deadline for transmitting written comments for this Tribal Consultation is
Friday, October 11, 2024.

Over the past 60 days, the Contract Support Cost Advisory Group (CSCAG), made up of Federal
and Tribal members met three times, to discuss needed changes to the existing funding
methodology to address the calculation of CSC on expenditures of program income. The
CSCAG’s charge includes providing advice and recommendations on the Indian Health Service
(IHS) CSC policy, as well as identifying priorities and issues for improvement.

The principles that have been agreed upon by CSCAG members are to take an approach with the
broadest applicability, which aligns as much as feasible with the current CSC policy. During this
timeframe, CSCAG members identified a few areas of agreement, as well as a few areas for
additional discussion. Overall, there remains a considerable amount of work to be accomplished
by the CSCAG and IHS staff to implement a modified methodology.

The IHS is requesting input from all Tribal Leaders, as the implementation of a modified
methodology to negotiate and pay CSC on expenditures of program income can have broad
budgetary implications for Tribes that receive direct services, as well as compacting and
contracting Tribal Nations.

During this Tribal Consultation, they plan to convene three in-person Consultation sessions and
two virtual Consultation sessions to allow multiple opportunities to provide feedback on the
Agency’s proposals to calculate CSC related to expenditures of program income. Details about
the Consultation sessions are provided in the Dear Tribal Leader Letter.

Throughout the CSCAG’s discussions, there were a few recurring topics of particular interest to
this Tribal Consultation. The IHS invites your recommendations and feedback broadly on the
expansion of the CSC policy, as well as the necessary changes required to implement CSC
calculations on expenditures of program income.

Due to the variability of how T/TOs collect program income expenditure data, the IHS is seeking
your recommendations on how to estimate initial amounts, as well as reconcile CSC annually.