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Tribal Administration

Information for Tribal Councils and NAHASDA Administrators

Information for Tribal Councils & NAHASDA Administrators

This page provides required information for Tribal Councils and NAHASDA administrators working with Bristol Bay Housing Authority (BBHA) as subrecipients under a Memorandum of Agreement (MOA). The following requirements and guidance apply to tribes receiving NAHASDA funds through BBHA.

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HUD LIMITS
FORMS
  • The Tribe must provide documentation of Theft/Embezzlement coverage on an annual basis for employees and council members.
  • The Tribe must provide either:
    • A current audit with no exceptions or findings on an annual basis, or
    • An annual Certification of Financial Management completed by a Certified Public Accountant (CPA).
  • NAHASDA funds are no longer advanced and are provided on a reimbursement basis only, with documentation of expenditures.

    • For materials, supplies, and services, documentation must include efforts to secure at least three bids.

    • NAHASDA does not allow sole source contracting with only one vendor or contracting with a single vendor without following bidding rules.
    • Only HUD’s Alaska Office of Native American Programs (ONAP) may approve a sole source procurement.
    • This issue was identified as a weakness during village monitoring.
  • Although funds are reimbursed, the NAHASDA environmental review requirement must be completed before any expenditure of funds.
    • BBHA completes environmental reviews for Utility Voucher and Crime Prevention programs at the beginning of the year.
    • For Modernization Programs, BBHA must receive an accurate legal description of the lot on which each home is located.
    • BBHA must continue reviewing NAHASDA applications to ensure individuals receiving assistance are eligible under the Act.
  • Tribes must plan expenditures so that no more than two (2) years of NAHASDA funding remains on hand.
    • If a tribe plans a larger project, BBHA can provide technical assistance to help the tribe pursue a HUD Title VI Loan to complete the project sooner and repay it using future allocations.
  • The Tribe must provide documentation of Theft/Embezzlement coverage on an annual basis for employees and council members.
  • The Tribe must provide either:
    • A current audit with no exceptions or findings on an annual basis, or
    • An annual Certification of Financial Management completed by a Certified Public Accountant (CPA).
  • NAHASDA funds are no longer advanced and are provided on a reimbursement basis only, with documentation of expenditures.

    • For materials, supplies, and services, documentation must include efforts to secure at least three bids.

    • NAHASDA does not allow sole source contracting with only one vendor or contracting with a single vendor without following bidding rules.
    • Only HUD’s Alaska Office of Native American Programs (ONAP) may approve a sole source procurement.
    • This issue was identified as a weakness during village monitoring.
  • Although funds are reimbursed, the NAHASDA environmental review requirement must be completed before any expenditure of funds.
    • BBHA completes environmental reviews for Utility Voucher and Crime Prevention programs at the beginning of the year.
    • For Modernization Programs, BBHA must receive an accurate legal description of the lot on which each home is located.
    • BBHA must continue reviewing NAHASDA applications to ensure individuals receiving assistance are eligible under the Act.
  • Tribes must plan expenditures so that no more than two (2) years of NAHASDA funding remains on hand.
    • If a tribe plans a larger project, BBHA can provide technical assistance to help the tribe pursue a HUD Title VI Loan to complete the project sooner and repay it using future allocations.
  • The Tribal Council must have official action (such as meeting minutes or a resolution) establishing the utility voucher limit.
  • The Tribe must have a W-9 form on file for each electric or fuel vendor in order to report payments to the IRS.
  • The Tribe must obtain a billing statement from each vendor in the NAHASDA-eligible tribal member’s name that shows the amount owed.
  • If a tribal member has a credit balance with a vendor, the credit must be applied before issuing a voucher.
  • Each NAHASDA applicant remains eligible for one (1) year after BBHA issues a NAHASDA eligibility determination letter.
  • NAHASDA eligibility for participating families must be documented by BBHA and kept on file at the Tribe.
  • If families who are not NAHASDA-eligible participate in group activities, the Tribe must document that another funding source is used to cover those costs.
  • First Quarter — April 15
  • Second Quarter — July 15
  • Third Quarter — October 15
  • Fourth Quarter — January 15
Timely submission of quarterly reports is required to maintain funding eligibility.