GAO-23-105473, COVID-19 RELIEF FUNDS: Lessons Learned Could Improve Future Distribution of Federal Emergency Relief to Tribal Recipients
- Issuer
- Government Accountability Office
- Document type
- Report
- Date
- 2022-12-15
Summary
GAO-23-105473, a Government Accountability Office report to congressional committees dated December 15, 2022, titled COVID-19 Relief Funds: Lessons Learned Could Improve Future Distribution of Federal Emergency Relief to Tribal Recipients. It states that since March 2020 Congress has appropriated at least $43.6 billion for federal programs serving tribes, tribal members and tribal organizations. The report examines approaches used by a nongeneralizable sample of five federal agencies administering 12 programs, the steps tribal recipients took to access funds, and lessons learned. GAO found that using existing mechanisms such as self-determination contracts and self-governance compacts can speed distribution and reduce administrative burden. It asks Congress to consider enabling agencies to use those mechanisms to distribute emergency relief to tribal recipients.
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United States Government Accountability Office
Report to Congressional Committees
COVID-19 RELIEF
December 2022
FUNDS
Lessons Learned
Could Improve Future
Distribution of Federal
Emergency Relief to
Tribal Recipients
GAO-23-105473
December 2022
COVID-19 RELIEF FUNDS
Lessons Learned Could Improve Future Distribution
of Federal Emergency Relief to Tribal Recipients
Highlights of GAO-23-105473, a report to
congressional committees.
Why GAO Did This Study What GAO Found
COVID-19 has disproportionately Agencies used various approaches to provide COVID-19 pandemic relief to tribal
harmed the public health and entities, tribal members, and American Indian or Alaska Native individuals (tribal
economies of federally recognized recipients). Disbursement and eligibility requirements, distribution and reporting
tribes and their members. Congress deadlines, and the number and type of steps that tribal recipients had to take to
has appropriated at least $43.6 billion access and use funds varied across federal relief programs (see fig. for
since March 2020 for federal programs examples). For programs that distributed funds through existing mechanisms,
serving tribes, their members, and such as self-determination contracts and self-governance compacts, tribal
tribal organizations. These programs recipients generally did not need to take action. These contracts and compacts
include preexisting and new programs.
authorize federally recognized tribes to take over the administration of certain
The CARES Act includes a provision federal programs previously administered by agencies. For other programs, tribal
for GAO to conduct monitoring and recipients had to take additional steps, such as applying for and receiving
oversight related to the COVID-19 approval to access and use certain COVID-19 funds.
pandemic. GAO was also asked to
review efforts to provide COVID-19 Examples of How Federal COVID-19 Relief Programs Distributed Funds for Tribal Recipients
relief to tribal governments. This report
examines (1) approaches selected
federal agencies used to administer
programs that provided COVID-19
funds to tribal recipients and (2)
lessons learned that could improve
future federal relief to these recipients.
GAO reviewed federal agency
documents and interviewed agency
officials, tribal recipients, and
representatives of tribal organizations.
GAO selected a nongeneralizable
sample of five federal agencies that
administer 12 programs. GAO selected
programs involving a range of funding
amounts, eligibility requirements, and
methods for providing assistance.
What GAO Recommends
GAO identified lessons learned from selected agencies’ administration of COVID-
Congress should consider enabling 19 relief funding that could improve future federal relief for tribal recipients. For
agencies to use existing mechanisms example, using existing mechanisms, such as contracts and compacts, can
and structures, such as self-
enable agencies to more quickly distribute funds to recipients and mitigate
determination contracts and self-
administrative burden for agencies and tribes. By enabling agencies to use
governance compacts, as appropriate,
existing mechanisms to distribute funds, Congress would better ensure that they
to distribute emergency relief to tribal
recipients. distribute these funds more quickly and with minimal additional administrative
burden on tribal recipients and agencies. This also allows agencies to maintain
accountability in the use of the funds through existing reporting mechanisms.
Additionally, GAO found that increasing federal capacity and expertise for
working with tribal recipients could improve federal administration of future
funding for tribal recipients. In accordance with a 2021 presidential memo, each
View GAO-23-105473. For more information, selected agency is implementing an action plan that includes building capacity
contact Anna Maria Ortiz at (202) 512-3841 or and expertise to better meet the unique needs of tribes and tribal communities.
ortiza@gao.gov.
United States Government Accountability Office
Contents
Letter 1
Background 6
Selected Agencies Used Various Approaches to Provide COVID-
19 Funds to Tribal Recipients, Who Had to Take a Range of
Steps to Access and Use Them 13
Lessons Learned from Various Challenges That Agencies and
Recipients Faced Could Improve Future Federal Emergency
Relief to Tribal Recipients 21
Conclusions 35
Matter for Congressional Consideration 36
Agency Comments 36
Appendix I Additional Information about Selected Federal COVID-19 Relief to
Tribal Recipients 39
Appendix II GAO Contact and Staff Acknowledgments 42
Tables
Table 1: Availability of Key State and Local Tax Revenue Streams
for Tribal Governments 7
Table 2: Selected COVID-19 Relief and Amounts for Tribal
Recipients 12
Table 3: Characteristics of Selected Federal COVID-19 Relief to
Tribal Recipients 39
Figure
Figure 1: Steps Taken to Distribute Certain National Oceanic and
Atmospheric Administration (NOAA) COVID-19 Relief for
Tribal Recipients 18
Page i GAO-23-105473 COVID-19 Relief Funds
Abbreviations
ACF Administration for Children and Families
AI/AN American Indian or Alaska Native
ARPA American Rescue Plan Act of 2021
BIA Bureau of Indian Affairs
CRF Coronavirus Relief Fund
CDC Centers for Disease Control and Prevention
CSFRF Coronavirus State Fiscal Recovery Fund
CSLFRF Coronavirus State and Local Fiscal Recovery Funds
FSA Farm Service Agency
HHS Health and Human Services
HRSA Health Resources and Services Administration
IHS Indian Health Service
LIHWAP Low Income Household Water Assistance Program
NOAA National Oceanic and Atmospheric Administration
OIG Office of the Inspector General
OMB Office of Management and Budget
PPP Paycheck Protection Program
PRF Provider Relief Fund
SBA Small Business Administration
SSBCI State Small Business Credit Initiative
USDA U.S. Department of Agriculture
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Page ii GAO-23-105473 COVID-19 Relief Funds
Letter
441 G St. N.W.
Washington, DC 20548
December 15, 2022
Congressional Committees
In the United States, the COVID-19 pandemic disproportionately harmed
the public health and economies of tribes and their members. 1 In the early
months of the pandemic, American Indian and Alaska Native populations
had higher rates of COVID-19 cases and associated deaths compared
with the non-Hispanic White population, according to a December 2020
report from the Centers for Disease Control and Prevention (CDC). 2 In
addition, many tribes faced severe revenue shortfalls after the pandemic
adversely affected tribal enterprises in the hospitality and energy sectors.
Tribes often depend heavily on these revenues to provide or support
health care, public safety, and other essential services for their
communities.
In response to the pandemic, since March 2020 Congress has
appropriated at least $43.6 billion in COVID-19 relief laws for federal
programs serving tribes, tribal members, and tribal organizations,
including in the American Rescue Plan Act of 2021 (ARPA). 3 These
programs provide pandemic relief (COVID-19 funds) to tribes, tribal
members, and tribal organizations and include preexisting programs,
1For the purposes of this report, the term “tribes” refers to Indian tribes that have been
federally recognized. As of November 2022, there were 574 such tribes. Federally
recognized tribes and individuals who meet the applicable statutory and regulatory
definitions of “Indian” have a unique political status and are eligible for certain federal
programs, benefits, and services because of that status. For the purposes of this report,
we refer to individuals eligible to receive benefits and services based on their political
status as “tribal members.”
2J. Arrazola et al., “COVID-19 Mortality among American Indian and Alaska Native
Persons – 14 States, January-June 2020,” Morbidity and Mortality Weekly Report, vol. 69,
no. 49 (Dec. 11, 2020).
3The $43.6 billion includes appropriations for programs for which Native Hawaiians are
eligible, although Native Hawaiians are not tribal members. In addition to the American
Rescue Plan Act of 2021, five other COVID-19 relief laws provide comprehensive relief
across federal agencies and programs that Treasury uses to report COVID-19 spending.
These are the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. M and N,
134 Stat. 1182 (2020); Paycheck Protection Program and Health Care Enhancement Act,
Pub. L. No. 116-139, 134 Stat. 620 (2020); CARES Act, Pub. L. No. 116-136, 134 Stat.
281 (2020); Families First Coronavirus Response Act, Pub. L. No. 116-127, 134 Stat. 178
(2020); and the Coronavirus Preparedness and Response Supplement Appropriations
Act, 2020, Pub. L. No. 116-123, 134 Stat. 146.
Page 1 GAO-23-105473 COVID-19 Relief Funds
such as the Department of the Interior’s Aid to Tribal Governments, and
new programs, such as the Department of the Treasury’s Coronavirus
State Fiscal Recovery Funds (CSFRF) Tribal Government Set-Aside. 4
We have previously examined Interior’s and Treasury’s disbursement of
CARES Act funds to tribes. 5 For example, in June 2020 we reported that
Treasury completed Coronavirus Relief Fund (CRF) payments to tribes 7
weeks after the statutory deadline to do so. 6 We also reported that
challenges that we had identified in our past work on other issues that
affect tribes, such as challenges related to tribal consultation and
infrastructure in tribal communities, could impede the federal
government’s ability to effectively support tribes’ response to the
pandemic. 7 In October 2021, we found that lessons learned from
Treasury’s and Interior’s administration of CARES Act funding could
improve future relief for tribes. We recommended that Treasury update its
tribal consultation policy to include consultation on data used for policy
decisions and to communicate with tribes about how tribal input from
4For the purpose of this report, we refer to the tribal entities, tribal members, and
American Indian or Alaska Native (AI/AN) individuals who received relief payments in
response to the pandemic as “tribal recipients.” ARPA appropriated $219.8 billion for the
Coronavirus State Fiscal Recovery Fund to make payments to states, territories, the
District of Columbia, and tribal governments, and $50 million for Treasury’s costs of
administering the fund and certain other coronavirus relief funds. ARPA also created the
Coronavirus Local Fiscal Recovery Fund. The act and Treasury refer to both funds
together as the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF). Pub. L.
No. 117-2, § 9901, 135 Stat. 4, 223-233 (codified at 42 U.S.C. §§ 802, 803).
5We first reported on these agencies’ disbursement of CARES Act funds to tribes in June
2020. See GAO, COVID-19: Opportunities to Improve Federal Response and Recovery
Efforts, GAO-20-625 (Washington, D.C.: June 25, 2021). In October 2021, we reported on
the approaches that Interior and Treasury took to distribute CARES Act funds to tribes,
steps that tribes had to take to use these funds, and challenges and lessons learned from
both agencies and tribes about the administration of COVID-19 funding. See GAO,
COVID-19: Lessons Learned from Interior and Treasury’s Administration of CARES Act
Funds Could Improve Federal Emergency Relief to Tribes, GAO-22-104349 (Washington
D.C.: Oct. 29, 2021).
6GAO-20-625.
7GAO, Tribal Consultation: Additional Federal Actions Needed for Infrastructure Projects,
GAO-19-22 (Washington, D.C.: Mar. 20, 2019); Drinking Water and Wastewater
Infrastructure: Opportunities Exist to Enhance Federal Agency Needs Assessment and
Coordination on Tribal Projects, GAO-18-309 (Washington, D.C.: May 15, 2018); Tribal
Broadband: FCC Should Undertake Efforts to Better Promote Tribal Access to Spectrum,
GAO-19-75 (Washington, D.C.: Nov. 14, 2018).
Page 2 GAO-23-105473 COVID-19 Relief Funds
consultation was considered. Treasury agreed with both
recommendations. 8
The CARES Act includes a provision for us to conduct monitoring and
oversight of the use of funds made available to prepare for, respond to,
and recover from the pandemic. 9 In addition, we were asked to review
federal efforts to provide COVID-19 relief for tribal governments. This is
our fifth report addressing federal agency administration of COVID-19
relief funds for tribal recipients that includes tribal governments, tribal
members, and tribal organizations. 10
This report examines (1) approaches selected federal agencies used to
administer programs that provided COVID-19 funds to tribal recipients
and the steps recipients needed to take to access and use these funds
and (2) lessons learned that could improve future federal relief to these
recipients. 11
To address both objectives, we reviewed our prior work, six selected
reports from research entities that have studied the federal administration
8As of July 2022, Treasury officials indicated that updating Treasury’s Tribal Consultation
Policy remains a priority and that updates will be considered under the newly appointed
Treasurer. The Treasurer was sworn in on September 12, 2022, and leads Treasury’s
newly established Office of Tribal and Native Affairs. According to Treasury officials, the
Treasurer will conduct a tribal consultation on updates to Treasury’s Tribal Consultation
Policy in early 2023, including on the integration of uniform interagency standards
pursuant to the Presidential Memorandum on Uniform Standards for Tribal Consultation.
87 Fed. Reg. 74479 (Dec. 5, 2022). See GAO-22-104349.
9Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (2020). All of GAO's reports related
to the COVID-19 pandemic are available on GAO's website at
https://www.gao.gov/coronavirus.
10We reported on Treasury’s and Interior’s disbursement of COVID-19 funds to tribes in
June 2020 and October 2021. See GAO-20-625 and GAO-22-104349. We reported on the
U.S. Department of Agriculture’s (USDA) debt relief payments to socially disadvantaged
agricultural producers, including AI/AN individuals, in October 2021. See GAO, COVID-19:
Additional Actions Needed to Improve Accountability and Program Effectiveness of
Federal Response, GAO-22-105051 (Washington, D.C.: Oct. 27, 2021). We reported on
Indian Health Service (IHS) relief funding and response to COVID-19 in March 2022. See
GAO, Indian Health Service: Relief Funding and Agency Response to COVID-19
Pandemic, GAO-22-104360 (Washington, D.C.: Mar. 31, 2022).
11This report does not examine how tribes used the COVID-19 relief funds they received.
Page 3 GAO-23-105473 COVID-19 Relief Funds
of COVID-19 funds to tribal recipients, 12 and statements from tribal
organizations on the federal government’s efforts to provide COVID-19
relief to tribal recipients since March 2020. We selected a
nongeneralizable sample of five federal agencies that administer at least
one program that provides COVID-19 funds for tribal recipients. 13 Within
these five agencies, we selected a total of 12 programs that represented
different combinations of the following criteria: the amount of COVID-19
funds appropriated to that program for tribal recipients (see table 2 for
funding amounts); eligibility requirements (including tribal governments,
entities, organizations, and individuals); concerns about specific programs
raised during our interviews with selected tribal organizations, tribal
officials, and researchers (methodology described below); whether the
program already existed or was new; whether the program was
specifically for tribes; and how the program provides assistance, such as
grants or payments, to individuals. 14 Findings from selected agencies and
programs cannot be generalized to those we did not include in our review.
We also interviewed a variety of tribal officials and other tribal
stakeholders, which included a nongeneralizable sample of three tribal
recipients, including tribes and a tribal organization, to interview about
steps they needed to take to access and use COVID-19 funds and about
lessons learned that could improve future federal relief. 15 We selected
12Given our methodology, we may not have identified all studies on addressing challenges
that tribes faced with federal COVID-19 funding. We reviewed these studies because of
the relevance to our scope.
13The federal agencies we selected for this review are the Departments of the Treasury,
the Interior, Commerce, Health and Human Services, and Agriculture.
14The programs we selected for this review are Treasury’s Coronavirus Relief Fund Tribal
Government Set-Aside, Emergency Rental Assistance 1 Tribal Community Set-Aside,
Coronavirus State Fiscal Recovery Fund Tribal Government Set-Aside, and State Small
Business Credit Initiative (SSBCI) Tribal Set-Aside; Interior’s Bureau of Indian Affairs’
American Rescue Plan Act of 2021 appropriation and Operation of Indian Programs in the
CARES Act; Commerce’s National Oceanic and Atmospheric Administration (NOAA)
Assistance for Fishery Participants and Fisheries Disaster Assistance for Tribal Fisheries
Participants; Health and Human Service’s Low Income Household Water Assistance
Program Tribal Set-Aside, Emergency Grants for Native American Language Preservation
and Maintenance, and Provider Relief Fund (PRF); and USDA’s Agricultural Debt Relief
for socially disadvantaged farmers or ranchers (summary table below). Because we have
ongoing work examining IHS’s administration of COVID-19 funds for tribal recipients, we
did not include IHS programs in this review.
15We interviewed officials from Citizen Potawatomi Nation and Central Council of Tlingit &
Haida Indian Tribes, and representatives from Riverside San Bernardino County Indian
Health, Inc.
Page 4 GAO-23-105473 COVID-19 Relief Funds
these three tribal recipients using criteria such as tribal enrollment
(ranging from about 25,000 to over 34,000 individuals), geographic
location (representing three different Bureau of Indian Affairs (BIA)
regions), the tribal recipient accessed at least one of the COVID-19 funds
in our scope and, in the case of two recipients, whether we could follow
up to discuss the experiences they shared with us for our October 2021
report. 16 We also selected two tribal organizations that have helped tribal
recipients navigate COVID-19 funding and reporting processes. 17
In addition, we selected four researchers who contributed to five of the six
selected reports we reviewed on the federal administration of COVID-19
funds to tribal recipients. We also selected a consultant who previously
worked for a tribal organization that assisted tribal recipients of the
COVID-19 funds that we examine in this work. We interviewed these five
individuals about lessons learned that could improve future federal
relief. 18 Information from tribal recipients, tribal organizations,
researchers, and the consultant we interviewed presents a range of
informed views but cannot be generalized to those we did not interview.
To obtain information about approaches that selected federal agencies
used to administer certain programs that provided COVID-19 relief for
tribal recipients and the steps that tribal recipients had to take to access
and use these funds, we reviewed statutory requirements for COVID-19
funds distributed by the selected programs. We also reviewed agency
documents describing processes and methodologies for administering
COVID-19 funds to recipients. We interviewed officials from selected
federal agencies about their administration of COVID-19 funds to tribal
recipients. We also interviewed the selected tribal recipients about steps
that they had to take to access and use funds. We identified similarities
and differences across selected programs, including statutory
requirements, distribution mechanisms, and steps that recipients had to
take to use and access funds.
16GAO-22-104349.
17We interviewed representatives from the Native American Finance Officers Association
and the Self-Governance Communication and Education Tribal Consortium.
18We selected two researchers affiliated with the Federal Reserve’s Center for Indian
Country Development, two researchers affiliated with the Harvard Project on American
Indian Economic Development, and an independent consultant who has assisted tribal
recipients with accessing and using COVID-19 funds.
Page 5 GAO-23-105473 COVID-19 Relief Funds
To identify lessons learned that could improve future federal relief to tribal
recipients, we reviewed our prior work and relevant documents from the
selected tribal organizations and researchers. We also interviewed
agency officials and tribal recipients about challenges that the selected
agencies and tribal recipients faced with the distribution of COVID-19
funding, and lessons learned for future federal relief funding. We
conducted a content analysis of interview statements to identify any
themes or commonly cited challenges and associated lessons learned
among those we interviewed. We compared the findings from our
analysis and interviews with statutes and agency documents to identify
any similarities and differences with statutory requirements, agency
policies, and applicable federal standards for internal controls. 19
We conducted this performance audit from October 2021 to December
2022 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
Background
Federally Recognized As of November 2022, the federal government recognized 574 tribes as
Tribes distinct, independent political entities whose inherent sovereignty
predates the United States but has been limited in certain circumstances
by treaty and federal law. Tribes can vary greatly in terms of their culture,
language, population size, land base, location, and economic status.
Tribal members are individuals who are enrolled in, or otherwise belong
to, a federally recognized tribe. 20 According to BIA, in 2021 the total
number of enrolled members of the 574 federally recognized tribes was
approximately 2.5 million.
19GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: Sept. 10, 2014).
20Criteria for enrollment in a federally recognized tribe are generally determined by each
tribe and differ from tribe to tribe. Tribes have inherent authority to determine requirements
for membership; however, some tribes’ enrollment is subject to requirements in federal
law or treaty.
Page 6 GAO-23-105473 COVID-19 Relief Funds
Tribal governments have many of the same responsibilities as state and
American Indian and Alaska Native
Population local governments but often do not have access to the same sources of
American Indian and Alaska Native is a racial revenue to support these responsibilities. In addition to serving tribal
category, and people who identify as such members who reside on lands under a tribe’s jurisdiction, the tribe may
may or may not be tribal members.
also provide services or benefits to enrolled tribal members who do not
According to 2020 Census estimates, the
population of self-identified American Indians reside on or near these lands, and others in the community, such as tribal
and Alaska Natives, including those of more members from other tribes and those who are not American Indian or
than one race, was 9.7 million (roughly 2.9
percent of the U.S. population).
Alaska Native (AI/AN). However, tribal governments typically do not have
However, this is likely an undercount. In access to the traditional taxes that state and local governments can levy
March 2022, the Census Bureau released a to meet the needs of their citizens beyond what can be addressed with
statement regarding estimates of limited federal funds, as shown in table 1. 21 Therefore, in lieu of taxes,
undercounting and overcounting—known as
“coverage error”—in the 2020 Census. These some tribes rely on a combination of federal funds and economic
results showed statistically significant development initiatives (i.e., tribally owned businesses) as their primary
undercounts for American Indians and Alaska
Natives, alone or in combination, as well as sources of revenue to support tribal government operations. 22
for other populations. Further, the estimate of
populations of American Indians or Alaska
Natives, alone or in combination, living on Table 1: Availability of Key State and Local Tax Revenue Streams for Tribal
reservations was the most undercounted of Governments
any demographic group.
Source: GAO. | GAO-23-105473 Key tax revenue streams for
state and local governments Availability to tribal governments
Income taxes Income taxes are generally not a feasible revenue
source for low-income tribes because of
disproportionately high levels of unemployment and
relatively low household incomes.
Property taxes Property taxes are generally not a viable option for
tribes with a land base because reservation lands
are held in trust by the federal government or owned
directly by the tribe.
Sales and other taxes Some tribes use sales and other taxes, but these
generally do not generate enough revenue to fully
support tribal government programs and services
and may be preempted by state and local taxes.
Sources: GAO summary of E. Henson, et al., Policy Brief 4: Emerging Stronger than Before: Guidelines for the Federal Role in
American Indian and Alaska Native Tribes’ Recovery from the COVID‐19 Pandemic, Harvard Project on American Indian Economic
Development and Native Nations Institute (July 24, 2020); Kelly S. Croman and Jonathan B. Taylor, “Why Beggar thy Indian Neighbor?
The Case for Tribal Primacy in Taxation in Indian Country,” Joint Occasional Papers on Native Affairs, Native Nations Institute, and
Harvard Project on American Indian Economic Development (May 4, 2016); and the National Congress of American Indians Policy
21Eric C. Henson et al., Policy Brief 4: Emerging Stronger than Before: Guidelines for the
Federal Role in American Indian and Alaska Native Tribes’ Recovery from the COVID‐19
Pandemic, Harvard Project on American Indian Economic Development and Native
Nations Institute (July 24, 2020).
22See GAO, Tribal Economic Development: Action Is Needed to Better Understand the
Extent of Federal Support, GAO-22-105215 (Washington, D.C.: Aug. 30, 2022); and
Indian Programs: Interior Should Address Factors Hindering Tribal Administration of
Federal Programs, GAO-19-87 (Washington, D.C.: Jan. 3, 2019).
Page 7 GAO-23-105473 COVID-19 Relief Funds
Issues/Tribal Governance/Taxation, https://www.ncai.org/policy-issues/tribal-governance/taxation (accessed Sept. 20, 2022). |
GAO-23-105473.
Relationship between the The United States has a unique trust responsibility to protect and support
Federal Government and tribes and their members through treaties, statutes, and historical
relations with tribes. 23 As several tribal leaders have previously noted,
Tribes
these trust obligations and responsibilities do not exist as a form of
welfare but as repayment on a nation-to-nation agreement. 24 Federal
recognition of a tribe establishes a government-to-government
relationship between the recognized tribe and the federal government,
and various laws require federal agencies to provide a range of services
and benefits to tribes and their members because of their unique political
status.
One way that tribes exercise their sovereignty is by choosing how to
receive federal services and benefits when federal law permits such a
choice. Some tribes may choose to receive services directly from federal
agencies (direct service). Alternatively, tribes may choose to administer
certain federal programs under a self-determination contract or self-
governance compact: 25
23Through treaties, statutes, and historical relations with Indian tribes, the United States
has undertaken a unique trust responsibility to protect and support Indian tribes and
Indians. Indian Trust Asset Reform Act, Pub. L. No. 114-178, § 101(3), 130 Stat. 432
(2016) (codified at 25 U.S.C. § 5601(3)). The fiduciary responsibilities of the United States
to Indians are also founded in part on specific commitments made through written treaties
and agreements securing peace, in exchange for which Indians have surrendered claims
to vast tracts of land, which provided legal consideration for permanent, ongoing
performance of federal trust duties. 25 U.S.C. § 5601(4).
24National Tribal Budget Formulation Workgroup, Building Health Equity with Tribal
Nations: The National Budget Formulation Workgroup’s Recommendations on the Indian
Health Service Fiscal Year 2023 Budget (May 2021), accessed Mar. 11, 2022,
https://www.nihb.org/legislative/budget_formulation.php.
25Under the Indian Self-Determination and Education Assistance Act of 1975, as
amended, federally recognized tribes can enter into self-determination contracts and self-
governance compacts with Interior to take over administration of certain federal programs
previously administered on their behalf. Pub. L. No. 93-638, 88 Stat. 2203 (codified as
amended at 25 U.S.C. §§ 5301-5423). BIA and the Office of Self-Governance are
overseen by Interior’s Office of the Assistant Secretary–Indian Affairs, which is
responsible for policy for Interior programs that serve tribes and their members. Federal
agencies with contracting and compacting authority are responsible for negotiating and
approving each contract and compact and their associated annual funding agreement and
for making disbursements to the tribes.
Page 8 GAO-23-105473 COVID-19 Relief Funds
• Self-determination contracts allow tribes to assume responsibility
for managing the program’s day-to-day operations, with federal
agencies providing technical oversight to ensure that the tribe meets
contract terms and reporting requirements.
• Self-governance compacts transfer administration of the program to
tribes and provide the tribes with some flexibility in program
administration. To be eligible for participation in self-governance
compacting, a tribe must demonstrate financial stability and
management capability, among other things. 26
Tribes with such contracts or compacts have greater flexibility to design
and adjust tribally administered programs to meet their tribe’s unique
needs. For example, generally, tribes with self-governance compacts may
reallocate funds for programs included in the compact in any manner that
the tribe determines to be in the best interest of the tribal community
being served. 27
As of March 2020, 569 of 574 tribes had a self-determination contract or
self-governance compact to take over the administration of one or more
federal programs from Interior, according to Interior officials. Of the
agencies within the scope of this report, Interior has authority to enter into
self-determination contracts and self-governance compacts with tribes. 28
These contracts and compacts can include certain programs that the
Secretary of the Interior administers but for which appropriations are
2625 U.S.C. § 5362(c). To be eligible to participate in self-governance, a tribe shall
demonstrate financial stability and financial management capability, as evidenced by the
tribe having no uncorrected significant and material audit exceptions in the required
annual audit of its self-determination or self-governance agreements with any federal
agency for the 3 fiscal years preceding the date on which the tribe requests participation.
27GAO-19-87.
28USDA has authority to enter into self-determination contracts with tribal organizations in
the Food Distribution Program on Indian Reservations demonstration project and with
tribes and tribal organizations for a Tribal Forest Management demonstration project. Pub.
L. No. 115-334, §§ 4003(b), 8703, 132 Stat. 4490, 4625, 4877 (2018). IHS also has
authority to enter into self-determination contracts and self-governance compacts, but IHS
is not in the scope of this review.
Page 9 GAO-23-105473 COVID-19 Relief Funds
made to another agency. 29 However, not all agencies have the authority
to transfer appropriations to Interior so that the funds can be disbursed to
tribes through such contracts or compacts.
Regardless of how tribes choose to receive services and benefits,
consultation with tribes on policies directly affecting tribes and their
members has been recognized as an important component of the
government-to-government relationship. To strengthen the U.S.’s
government-to-government relationship with tribes, a 2000 executive
order directs federal agencies to have an accountable process to ensure
meaningful and timely input by tribal officials in the development of
regulatory policies that have tribal implications. 30 Many federal agencies
have established policies for conducting tribal consultations. Furthermore,
a 2009 presidential memorandum directed agencies to develop a detailed
plan of action to implement the policies and directives of the 2000
executive order, and a 2021 presidential memo reaffirmed this policy. 31
COVID-19 Impacts on We have previously found that COVID-19 has disproportionately
Tribes, and the Federal impacted tribes and their members, in part because of preexisting health
and welfare disparities that American Indians and Alaska Natives
Response experience. 32 For example, we found in March 2021 that American Indian
29For self-determination contracts, these are programs administered by the Secretary of
the Interior for the benefit of Indians for which appropriations are made to agencies other
than the Department of Health and Human Services or the Department of the Interior. For
self-governance compacts, these are programs, functions, and activities administered by
the Secretary of the Interior that are otherwise available to Indian tribes or Indians for
which appropriations are made to agencies other than the Department of the Interior.
30Executive Order No. 13175, Consultation and Coordination with Indian Tribal
Governments, § 5(a), 65 Fed. Reg. 67249 (Nov. 9, 2000). Policies that have tribal
implications refers to regulations, legislative comments, or proposed legislation, and other
policy statements or actions that have substantial direct effects on one or more Indian
tribes, on the relationship between the federal government and Indian tribes, or on the
distribution of power and responsibilities between the federal government and Indian
tribes. Executive Order 13175 § 1(a).
31Presidential Memorandum, Tribal Consultation, 74 Fed. Reg. 57881 (Nov. 9, 2009). The
2021 presidential memo directed agencies to submit these plans of actions to the Office of
Management and Budget (OMB) by April 26, 2021, and progress reports by October 23,
2021, and then annually thereafter. Presidential Memorandum, Tribal Consultation and
Strengthening Nation-to-Nation Relationships, 86 Fed. Reg. 7491 (Jan. 29, 2021).
32For more information on preexisting health and welfare disparities for American Indian
and Alaska Native populations, see the U.S. Commission on Civil Rights, Broken
Promises: Continuing Federal Funding Shortfall for Native Americans (Washington, D.C.:
Dec. 20, 2018).
Page 10 GAO-23-105473 COVID-19 Relief Funds
and Alaska Native individuals were hospitalized because of COVID-19 at
a rate 3.6 times that of non-Hispanic White individuals. 33 We also found
that the prevalence of preexisting health and welfare conditions, limited
access to health care, and other long-standing infrastructure challenges,
such as limited access to safe drinking water and overcrowded homes,
have contributed to the disproportionate impact of COVID-19 on AI/AN
individuals. 34
The COVID-19 pandemic has also disproportionately affected tribal
governments and their communities because of its impact on tribal
government finances. Many tribally owned businesses are in the leisure
and hospitality sector—one of the sectors hardest hit by pandemic-related
restrictions. One national tribal organization observed that the pandemic-
related revenue losses for tribal enterprises have resulted in many tribal
governments laying off personnel, further reducing tribal administrative
capacity. Further, we have reported that limited access to broadband on
tribal lands during the pandemic has negatively impacted access to
telehealth, remote education for students, economic opportunities, and
tribal government operations. 35
Since March 2020, Congress has provided about $4.6 trillion through the
six COVID-19 relief laws enacted to fund response and recovery efforts.
These laws provided relief for tribes and their members and other tribal
entities by creating several new programs, making appropriations for
those programs, and providing supplemental appropriations for existing
33GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters Its Second
Year, GAO-21-387 (Washington, D.C.: Mar. 31, 2021).
34For more information on many of these and other long-standing challenges, see GAO,
Tribal Broadband: National Strategy and Coordination Framework Needed to Increase
Access, GAO-22-104421 (Washington, D.C.: June 22, 2022); Alaska Native Issues:
Federal Agencies Could Enhance Support for Native Village Efforts to Address
Environmental Threats, GAO-22-104241 (Washington, D.C.: May 18, 2022);
GAO-22-104360; Indian Health Service: Agency Faces Ongoing Challenges Filling
Provider Vacancies, GAO-18-580 (Washington, D.C.: Aug. 15, 2018); Drinking Water and
Wastewater Infrastructure: Opportunities Exist to Enhance Federal Agency Needs
Assessment and Coordination on Tribal Projects GAO-18-309 (Washington, D.C.: May 15,
2018); and Native American Housing: Additional Actions Needed to Better Support Tribal
Efforts, GAO-14-255 (Washington, D.C.: Mar. 27, 2014). We made 34 recommendations
or Matters for Congressional Consideration in these reports. As of October 2022, agencies
had implemented 22.
35GAO, Indian Education: Schools Need More Assistance to Provide Distance Learning,
GAO-21-492T (Washington, D.C.: Apr. 28, 2021); GAO-20-625; and GAO-22-104421.
Page 11 GAO-23-105473 COVID-19 Relief Funds
programs. See table 2 for information on the 12 programs we selected
from these laws to review for this report.
Table 2: Selected COVID-19 Relief and Amounts for Tribal Recipients
Department Office Appropriation/program Amount (in dollars)
Appropriations for tribal recipients
Treasury Office of Recovery Coronavirus Relief Fund Tribal Government 8 billion
Programs Set-Aside
Emergency Rental Assistance 1 Tribal 800 million
Community Set-Asidea
State Small Business Credit Initiative Tribal Set- 500 million
Asideb
Coronavirus State Fiscal Recovery Fund Tribal 20 billion
Government Set-Aside
Interior Bureau of Indian Affairs Operation of Indian Programs 453 million
American Rescue Plan Act of 2021 (ARPA) 900 millionc
Commerce National Oceanic and Fisheries Disaster Assistance for Tribal 30 million
Atmospheric Fisheries Participants
Administration
Health and Human The Administration for Emergency Grants for Native American 20 million
Services Children and Families Language Preservation and Maintenance
Low Income Household Water Assistance Up to 34.1 milliond
Program (LIHWAP) Tribal Set-Aside
Agriculture Farm Service Agency Agricultural Debt Relief As much as necessarye
Allocations for tribal recipients
Commerce National Oceanic and Assistance for Fishery Participants 16.8 millionf
Atmospheric
Administration
Health and Human Health Resources and Provider Relief Fund 520 milliong
Services Services Administration
Source: GAO analysis of the six laws providing comprehensive relief across federal agencies and programs that the Treasury uses to report COVID-19 spending. | GAO-23-105473.
a
Indian tribes, tribally designated housing entities, and the Department of Hawaiian Homelands are
eligible for this set-aside. Pub. L. No. 116-260, tit. V, § 501(a)(2)(B), (k)(2)(C), (D), 134 Stat. 1182,
2069 (2020) (codified at 15 U.S.C. § 9058a(a)(2)(B), (k)(2)(C), (D)).
b
In addition to this tribal set-aside, tribal governments are eligible for the State Small Business Credit
Initiative technical assistance grants and additional allocations, such as those for socially and
economically disadvantaged-owned business.
c
Of the $900 million ARPA appropriation, $100 million was for tribal housing improvement; $772.5
million was for tribal government services, public safety and justice, social services, child welfare
assistance, and other related expenses; $20 million was to provide and deliver potable water; and
$7.5 million was for federal administrative costs and oversight. ARPA, Pub. L. No. 117-2, tit. XI, §
11002, 135 Stat. 4, 241-242 (2021).
d
Division H of the Consolidated Appropriations Act, 2021, created the Low-Income Household
Drinking Water and Wastewater Emergency Assistance Program and appropriated $638 million for it.
Up to 3 percent of that appropriation was reserved for Indian tribes and tribal organizations. Pub. L.
No. 116-260, div. H, tit. V, § 553, 134 Stat. 1182, 1627 (2020). ARPA appropriated $500 million for
Page 12 GAO-23-105473 COVID-19 Relief Funds
the program and also reserved up to 3 percent of that appropriation for Indian tribes and tribal
organizations. Pub. L. No. 117-2, tit. II, § 2912, 134 Stat. 4, 51 (2021). The Department of Health and
Human Services’ (HHS) Office of Community Services allocated $34.1 million to the LIHWAP Tribal
Set-Aside.
e
In August 2022, section 22008 of the Inflation Reduction Act of 2022 repealed the statutory provision
establishing this Agricultural Debt Relief program. ARPA directed the Secretary of Agriculture to
provide payments of up to 120 percent of the outstanding direct and guaranteed farm loan balances
for each socially disadvantaged farmer or rancher to pay off the balance of the producer’s loan. Pub.
L. No. 117-2, tit. I, § 1005, 135 Stat. 4, 12-13 (2021). Socially disadvantaged farmers or ranchers are
farmers or ranchers who are members of a socially disadvantaged group, which is a group whose
members have been subjected to racial or ethnic prejudice because of their identity as members of a
group, without regard to their individual qualities. 7 U.S.C. § 2279(a)(5), (6). ARPA appropriated such
sums as may be necessary for the cost of loan modifications and payments under this program.
f
Certain tribal, subsistence, commercial, and charter fishery participants, including tribes, persons,
fishing communities, and aquaculture businesses not otherwise eligible for emergency agricultural
disaster assistance, were eligible to receive assistance from this program. The CARES Act
appropriated $300 million for such assistance but did not include a set-aside for tribes. Pub. L. No.
116-136, tit. II, § 12005, 134 Stat. 281, 518 (2020).
g
This fund provides financial relief to eligible health care providers that provided COVID-19
diagnoses, testing, or health care after January 31, 2021, and received appropriations totaling $178
billion. HHS allocated $520 million of the fund for tribal distribution.
Some of the selected COVID-19 relief programs were set-asides for tribes
or tribal governments from a program for which states and other
governments are eligible recipients, while others provided relief to a
variety of eligible recipients, including tribal organizations, specified
entities, or directly to individuals. See appendix I for more details about
eligible recipients for programs in our scope.
Agencies used various approaches, some of which were required by
Selected Agencies statute, to provide COVID-19 funds to tribal recipients that determined the
Used Various number and type of steps that tribal recipients had to take to access and
use the funds. See appendix I for more details of selected federal relief
Approaches to programs to tribal recipients.
Provide COVID-19
Funds to Tribal
Recipients, Who Had
to Take a Range of
Steps to Access and
Use Them
Statutory and Other Statutes established various requirements, such as disbursement
Requirements requirements, eligibility requirements, and deadlines for federal COVID-
19 relief programs for tribal recipients.
Page 13 GAO-23-105473 COVID-19 Relief Funds
Disbursement requirements. Federal relief programs varied in the way
that agencies were required to disburse funds to tribal recipients, such as
in the form of grants or payments to individuals. For example:
• Grants. ARPA created an Emergency Grants for the Native American
Language Preservation and Maintenance program and appropriated
$20 million for it. The Department of Health and Human Services
(HHS) distributed the funds by awarding 210 grants through a
noncompetitive grants process. HHS decided to make the grants
noncompetitive after consultations with tribes.
• Payments to individuals. ARPA authorized the U.S. Department of
Agriculture (USDA) to provide payments for up to 120 percent of
outstanding direct and guaranteed farm loan balances for socially
disadvantaged farmers and ranchers to pay off the balance of their
loans. 36 According to USDA, of the approximately 23,402 socially
disadvantaged agricultural producers who qualified for these debt
relief payments for direct loans, 12,220 were AI/AN producers. In
addition, of approximately 4,540 socially disadvantaged agricultural
producers who qualified for debt relief payments for guaranteed loans,
1,606 were AI/AN producers. 37
36In June 2021, a federal judge issued a temporary restraining order prohibiting USDA
from forgiving loans under this debt relief program until such time as the court could rule
on whether a preliminary injunction was warranted. A preliminary injunction would prevent
USDA from issuing debt relief payments pending the outcome of a court case alleging
discrimination. Later in June 2021, another federal judge issued a preliminary injunction
preventing USDA from making debt relief payments nationwide. According to USDA
officials, prior to the courts issuing the injunction, USDA processed four payments, three
of which were to AI/AN borrowers. In August 2022, section 22008 of the Inflation
Reduction Act of 2022 repealed the statutory provision that authorized these debt relief
payments.
37The Farm Service Agency (FSA) labeled 318 of the 12,200 AI/AN producers who qualify
for direct loans, and 120 of the 1,606 producers who qualify for guaranteed loans, as “not
verified.” According to an August 2021 USDA report to Congress, “not verified” numbers
include instances where a customer’s race or ethnicity information was observed and
recorded by an FSA employee or a third party rather than declared by the customer.
According to the report, with future customers, FSA is transitioning away from any
employee and third-party observations and relying on voluntary self-reporting by
customers. We reported in September 2022 that FSA was asking socially disadvantaged
producers to voluntarily certify their race or ethnicity. See U.S. Department of Agriculture’s
Farm Production and Conservation Business Center, Report to Congress, A Comparison
of Transfers and Subsidies to Minority and Non-Minority Producers Associated with Key
Farm and Conservation Programs as Requested by House Report 116-107 (Washington,
D.C.: Aug. 5, 2021); and GAO, Coronavirus Food Assistance Program: USDA Should
Conduct More Rigorous Reviews of Payments to Producers, GAO-22-104397
(Washington, D.C.: Sept. 8, 2022).
Page 14 GAO-23-105473 COVID-19 Relief Funds
Additionally, in certain cases, statutes required agencies to allocate an
appropriation to tribal recipients based on a specified formula. For
example, the Consolidated Appropriations Act, 2021, required allocations
of its appropriation for the Low Income Household Water Assistance
Program (LIHWAP) to tribes based on the percentage of households
under the jurisdiction of the tribe with income equal to or less than 150
percent of the federal poverty line, and the percentage of such
households that spend more than 30 percent of monthly income on
housing. 38
Eligibility requirements. Programs had various eligibility requirements
for COVID-19 funds. For example:
• Indian tribes. All federally recognized Indian tribes were eligible for
Interior’s Aid to Tribal Governments, which provides funds to tribes to
support general tribal government operations and programs.
• Tribal entities. Certain tribally designated housing entities were
eligible for grants from Treasury’s Emergency Rental Assistance
Tribal Community Set-Aside. 39
• Tribal organizations. Certain tribal organizations that had been
designated by a tribe to receive the tribe’s funding allocation were
eligible for HHS’s Emergency Grants for the Native American
Language Preservation and Maintenance program. 40
• Individuals. Certain tribal fishery participants who incurred specific
economic revenue losses or negative impacts to subsistence, cultural,
or ceremonial fisheries as a direct or indirect result of the coronavirus
pandemic were eligible for the National Oceanic and Atmospheric
38Pub. L. No. 116-260, div. H, tit. V, § 533, 134 Stat. 1182, 1627 (2020). HHS officials said
nine tribes eligible for LIHWAP funding would not have received a LIHWAP award
because of the data sources available to develop the funding formula. These officials said
that HHS took additional steps to ensure that LIHWAP recipients had sufficient funds to
administer an effective program. For more information on these steps, see HHS’s
LIHWAP One-Pager for Tribes.
39The Consolidated Appropriations Act, 2021, appropriated $25 billion for Emergency
Rental Assistance 1 and required Treasury to allocate $800 million of that appropriation to
tribal communities, including certain tribes and tribally designated housing entities. Tribes
were not eligible for the Emergency Rental Assistance program created by ARPA.
40In addition to tribes, these entities are eligible recipients: incorporated nonprofit,
multipurpose, community-based Indian organizations; nonprofit Native organizations in
Alaska with village-specific projects; incorporated nonprofit Alaska Native multipurpose,
community-based organizations; and tribal colleges and universities.
Page 15 GAO-23-105473 COVID-19 Relief Funds
Administration’s (NOAA) Assistance for Fisheries Participants
payments. 41 In another example, socially disadvantaged farmers and
ranchers, including AI/AN individuals, with direct and guaranteed farm
loans from USDA were eligible to receive payments from USDA’s
Agricultural Debt Relief program to repay those loans. 42
Deadlines. Various types of statutory and other deadlines applied to tribal
recipients and agencies. For example:
• Notice of intent deadlines. For Treasury’s State Small Business
Credit Initiative (SSBCI) program, ARPA authorized Treasury to
establish a deadline requiring tribal governments that wished to
participate in the program to file a notice of intent not later than 30
days after ARPA enactment. 43
• Distribution deadlines. Sometimes agencies had to meet statutory
deadlines to distribute COVID-19 funds. For example, for the HHS
Emergency Grants for Native American Language Preservation and
Maintenance program, ARPA required HHS to award grants to
recipients within 180 days of the act’s enactment. Since this was the
first time that HHS’s Administration for Native Americans had made
noncompetitive awards for Native language funding, the
Administration for Native Americans had to develop and publish a
funding announcement, review applications, and issue the grant
awards in this time frame. 44
• Reporting deadlines. Tribal recipients had to meet deadlines to
report on funding. For example, ARPA required that all recipients of
Treasury’s Coronavirus State and Local Fiscal Recovery Funds
(CSLFRF), including tribal governments, provide Treasury with
41In addition to tribal fishery participants, subsistence, commercial, and charter fishery
participants are eligible for this assistance.
42Socially disadvantaged farmers or ranchers are farmers or ranchers who are members
of a socially disadvantaged group, which means a group whose members have been
subjected to racial or ethnic prejudice because of their identity as members of a group
without regard to their individual qualities. 7 U.S.C. § 2279(a)(5), (6).
43According to Treasury officials, Treasury extended this deadline and set it for December
2021 to encourage tribal participation.
44According to Administration for Children and Families (ACF) officials, ACF held tribal
consultations to seek input on the application process and how to reduce the
administrative burden for the emergency language grant. During these meetings, officials
said there was widespread support among tribes to award funds on a noncompetitive
basis.
Page 16 GAO-23-105473 COVID-19 Relief Funds
periodic reports that include a detailed accounting of the uses of funds
during the covered period.
Distribution and Payment Federal agencies used various methods to provide payments to tribal
Mechanisms recipients, including existing mechanisms or a direct deposit or check. For
example:
• Existing mechanisms. Some agencies used existing mechanisms,
such as existing contracts and compacts and interstate commissions,
to distribute funds to tribal recipients.
• Contracts and compacts. BIA distributed COVID-19 funding
mostly through self-determination contracts and self-governance
compacts, with some tribes choosing to receive direct services.
Using these existing mechanisms generally allowed tribes to take
few administrative steps to access and use funds, which allowed
them to do so more quickly. For example, the CARES Act was
enacted on March 27, 2020, and BIA was able to begin
distributing funds on April 13, 2020, to tribes that had existing
contracts and compacts.
• Interstate commissions. NOAA distributed Fisheries Assistance
payments from the CARES Act through interstate marine fisheries
commissions—which play an important role in disbursing funds to
fishery participants as part of NOAA’s fishery disaster assistance
program. 45 The respective interstate marine fisheries commissions
disbursed the appropriate amount of funds directly to the fishery
participant, consistent with an approved spend plan, though some
states and tribes were able to disburse funds themselves. For
example, according to NOAA, Alaska provided payments to
eligible tribal members in that state and, on the East Coast, states
or the Atlantic States Marine Fisheries Commission are disbursing
funds to tribes.
In certain instances, agencies transferred some of their appropriations to
agencies that had existing mechanisms in place to make distributions to
tribal recipients. For example, the Fisheries Disaster Assistance
appropriation that NOAA received in the Coronavirus Response and
Relief Supplemental Appropriations Act, 2021, included a line item
appropriation for tribal fishery participants. NOAA transferred this line item
appropriation to BIA, which BIA then distributed to tribes using existing
45For more information on NOAA’s Assistance for Fishery Participants, see
GAO-22-105051.
Page 17 GAO-23-105473 COVID-19 Relief Funds
mechanisms, according to BIA officials (see fig. 1 below). Additionally, as
we reported in March 2022, the CDC transferred $210 million of its
appropriation from the Coronavirus Response and Relief Supplemental
Appropriations Act, 2021, to IHS. IHS then used these funds for direct
services or distributed it to tribes through self-determination contracts and
self-governance compacts. 46
Figure 1: Steps Taken to Distribute Certain National Oceanic and Atmospheric Administration (NOAA) COVID-19 Relief for
Tribal Recipients
46GAO-22-104360.
Page 18 GAO-23-105473 COVID-19 Relief Funds
• Direct deposit or check. According to the Health Resources and
Services Administration (HRSA), HRSA distributed Provider Relief
Fund (PRF) payments either through an automated direct deposit
system (if bank account information was available) or via check to the
recipient. 47 Officials said that HHS’s Immediate Office of the Secretary
worked directly with IHS to develop the PRF Tribal Distribution
funding allocation methodology and eligibility criteria. IHS developed
the source file, which included the list of eligible providers, their
calculated payment, address, and tax identification numbers. HRSA
used this source file to develop the payment files for eligible tribal,
IHS, and urban Indian organization health care providers, including
identifying banking information, when available. HRSA officials said
that they identified recipients by their tax identification number.
According to HRSA, if they or their contractor did not already have a
recipient’s bank account information on file, they had to distribute
funds via a check mailed to the recipient address listed in the IHS
source file. They also noted that if they were able to distribute PRF
payments via bank accounts, the funds appeared immediately, but if
by mail, it took roughly 3 to 4 days for checks to arrive. We have
ongoing work examining HRSA’s implementation of the PRF.
Steps to Access and Use The number and type of steps necessary for tribal recipients to access
Funds and use funds varied across selected federal relief programs. Generally,
for programs that distributed funds through existing mechanisms, such as
self-determination contracts and self-governance compacts, tribal
recipients did not need to take action. In other cases, tribal recipients had
to take steps, such as applying for and receiving approval to access and
use certain COVID-19 funds. For example:
• Take no action. For HHS’s PRF and BIA’s Aid to Tribal
Governments, the agencies generally disbursed payments without
47The PRF reimburses eligible health care providers—which includes IHS, tribal, and
Urban Indian Health programs—for health care-related expenses or lost revenues
attributable to COVID-19.
Page 19 GAO-23-105473 COVID-19 Relief Funds
recipients needing to take any prior action. 48 While PRF recipients did
not need to take further action to receive funds, they did have to attest
to the payment terms and conditions for allowable uses of PRF
payments and subsequently report on the use of funds. 49
• Apply to receive funds. For Treasury’s SSBCI Capital Program,
tribal governments had to submit a notice of intent and then must
submit an application for the SSBCI Capital Program for Treasury to
review and approve before any payments are issued. 50 For HHS’s
Native Language Grants, tribes had to determine if they wanted to
receive the funding directly or if they wanted to have another tribal
organization receive their allocation. If they wanted to designate
another tribal or native organization, they had to provide a letter of
designation to that entity as part of their grant application. The
Administration for Children and Families (ACF) accepted an
abbreviated application consisting of 5 to 10 pages of a project
narrative, a line-item budget and budget justification, and a simplified
work plan, in addition to other required grant application forms.
• Gain approval to receive funds for distribution. For the Assistance
for Fishery Participants appropriation that NOAA received in the
CARES Act, interstate marine fisheries commissions worked with
tribes to develop spend plans for NOAA’s review and approval before
tribes could accept applications from potential recipients. These plans
proposed a disbursement methodology for fishery participants and
detailed how these participants would meet the requirements of the
CARES Act to receive payments. Once NOAA approved a tribe’s
spend plan, that tribe solicited and reviewed applications from fishery
participants, determined whether participants met the eligibility
criteria, and determined the direct payment amount based on the
methodology outlined in its spend plan.
48For example, under Interior’s approach to distributing COVID-19 relief appropriated by
the CARES Act, tribes that had a self-determination contract or self-governance compact
that already included Aid to Tribal Government and Welfare Assistance could receive
these funds without having to take additional steps. If a tribe did not have a self-
determination contract or self-governance compact that included Aid to Tribal Government
or Welfare Assistance, BIA provided those programs’ services to the tribes or its members
as a direct service, or tribes could modify or amend their existing contract or compact to
include these programs.
49The PRF is to reimburse eligible health care providers for health care-related expenses
or lost revenues that are attributable to COVID-19.
50For Treasury’s SSBCI Capital Program, tribal governments had to submit a notice of
intent by December 11, 2021.
Page 20 GAO-23-105473 COVID-19 Relief Funds
According to our prior work and interviews with agency officials, tribal
Lessons Learned recipients, tribal organizations, and researchers, lessons learned from the
from Various administration of COVID-19 relief funding for tribal recipients could
improve the administration of future federal emergency relief. Specifically,
Challenges That leveraging existing mechanisms to distribute funds to tribal recipients and
Agencies and providing clear guidance to recipients on funding would reduce the
administrative burden for federal agencies and tribal recipients, one of the
Recipients Faced barriers to accessing and using federal relief. We also found that
Could Improve Future increasing federal capacity and expertise for working with tribal recipients
could improve future federal administration of emergency funding for
Federal Emergency these recipients.
Relief to Tribal
Recipients
Reducing Administrative The administrative burden associated with certain COVID-19 relief funds
Burden Could Address created barriers for some tribal recipients to accessing and using these
funds, according to selected agency officials, tribal recipients, and others
Barriers to Accessing and
we interviewed. In some cases, agencies leveraged existing mechanisms
Using Federal Relief to distribute funding and provided clear guidance about funding
requirements, which reduced the administrative strain on agencies and
recipients. Applying these lessons learned for future emergency relief
could help address similar barriers, according to some selected agency
officials, tribal recipients, and others we interviewed and our review of our
prior work and agency consultation documents.
Some tribes in particular faced challenges with the administrative burden
because of limited staffing and capacity to carry out additional
administrative functions during the pandemic, according to our prior work,
agency officials, and two researchers we interviewed. In a June 2020
hearing, the Director of IHS testified that many tribes did not have the
administrative capacity to take on burdensome applications or reporting
requirements for COVID funding. The Director noted that organizational
capacity within tribes varies greatly and that smaller tribes especially do
not have the organizational capacity to take on the additional
administrative burden of applying for relief funding through grants,
particularly during a pandemic. 51 For example, two researchers we
interviewed said that one tribe they were working with had five employees
to run the government and did not have the capacity to complete
extensive applications, despite needing the relief funds. Officials from one
51Indian Health Service Covid-19 Response, Before the H. Subcomm. on Interior,
Environment, and Related Agencies, 116th Congress (June 11, 2020) (statement of Rear
Adm. Michael D. Weahkee, Director, Indian Health Service).
Page 21 GAO-23-105473 COVID-19 Relief Funds
agency also said that they learned from a tribal staff member that this
staff person was the sole employee responsible for running eight different
government programs. Additionally, these officials said that tribal offices
were closed for long periods of time and severely short-staffed because
of COVID-19 illnesses.
Further, managing varying reporting requirements and deadlines for
multiple programs across several agencies can strain the administrative
capacity of tribal recipients, according to our prior work and two tribal
recipients, two tribal organizations, and two researchers we interviewed.
For example, in October 2021, we found that tribes had been more likely
to need CRF reporting extensions compared to other government entities,
and they cited extenuating circumstances in their extension requests that
included office shutdowns because of COVID-19 outbreaks; internet
connectivity issues; and weather events, such as wildfires. 52 For the first
three quarterly reporting cycles, 19 percent of tribal government CRF
recipients were granted a reporting extension—compared to 0 to 9
percent for other government entities. 53 Treasury officials attributed the
large volume of reporting extension requests from tribal governments to
the limited staff resources and infrastructure of some tribes, especially
tribes that are small or more remote. These circumstances can create
barriers to accessing and using federal funds, according to our prior
work. 54
Using Existing Mechanisms Using existing mechanisms enabled certain agencies to more quickly
Helped Distribute Funds More distribute funds to tribal recipients, thereby mitigating the strain on
Quickly, with Less Strain on agencies’ and tribes’ administrative capacities, according to our prior work
Agency Capacity and Fewer and interviews with selected agency and tribal recipients. For example:
Errors
• Interior and Treasury. In October 2021, we found that Interior
officials faced fewer challenges than Treasury with administering
CARES Act relief funds for tribal recipients, in part because Interior
distributed its appropriation through existing programs, while Treasury
had to set up a new program. Interior officials said that distributing
Operation of Indian Programs payments using a preexisting program
structure allowed the agency to provide relief quickly because it did
52GAO-22-104349.
53Reporting extensions for tribal government CRF recipients decreased to 7 percent for
the fourth reporting cycle and increased to 10 percent in the fifth reporting cycle.
54See, for example, GAO-22-104349 and GAO-22-104241.
Page 22 GAO-23-105473 COVID-19 Relief Funds
not have to develop new distribution or reporting mechanisms. In
contrast, because Treasury had not previously distributed direct relief
payments to tribal recipients and, therefore, did not have an existing
mechanism to leverage when implementing the new CRF program,
Treasury had to take several steps to implement it. 55 Specifically,
Treasury had to create a new distribution mechanism, as well as
develop allocation methods and procedures for the CRF Tribal Set-
Aside, which Treasury officials said delayed distribution of the funds. 56
Interior’s approach resulted in less administrative burden for Interior
officials and tribes, which had to take fewer steps to access and use
Interior’s appropriation than for Treasury’s program. 57
• NOAA and BIA. During their consultations with tribes, NOAA officials
said that they received comments about the administrative burden of
applying for previous fisheries assistance that was not exclusive to
tribal recipients through interstate commissions under the CARES Act.
In response, NOAA officials explored alternatives to streamline the
process for tribal recipients for future COVID-19 relief. This resulted in
NOAA transferring the Fisheries Disaster Assistance line item
appropriation for tribal fishery recipients to BIA for distribution to tribes
via BIA’s self-determination contracts and self-governance compacts,
according to NOAA officials. 58 Leveraging BIA’s existing mechanisms
allowed the agency to distribute funds more quickly. This transfer also
helped streamline the process for NOAA officials and reduced the
administrative burden on the agency and tribes, the officials told us.
NOAA officials said that they were previously unaware of BIA’s
55During two April 2020 tribal consultations that Treasury held on the CRF, some tribal
leaders said that they preferred to receive relief funding through existing mechanisms,
including contracts and compacts. Specifically, of the 22 leaders that commented on
distribution mechanisms, 21 tribal leaders said that they supported receiving money from
the CRF directly through existing mechanisms, including contracts and compacts.
However, Treasury could not distribute relief funding through these mechanisms because
it does not have the authority to enter into self-determination contracts and self-
governance compacts. Treasury officials also noted that some tribes may not prefer to
receive funding through contracts and compacts.
56We also reported that unclear eligibility requirements in the CARES Act contributed to
delayed distribution of CRF Tribal Set-Aside payments because of litigation over
Treasury’s interpretation of the statute. However, we found that clarity in ARPA about
eligibility for the CSFRF helped avoid similar litigation over agencies’ interpretation of the
eligibility of corporations established pursuant to the Alaska Native Claims Settlement Act.
57GAO-22-104349.
58This appropriation was made in the Coronavirus Response and Relief Supplemental
Appropriations Act, 2021. Pub. L. No. 116-260, div. M, tit. I, 134 Stat. 1182, 1909-1910.
Page 23 GAO-23-105473 COVID-19 Relief Funds
existing mechanisms for distributing relief funding and that enabling
emergency relief funding to be distributed through existing
mechanisms in the future would be very helpful.
• HRSA’s PRF. Although HRSA has previously awarded grant funds to
tribal providers, HRSA did not have a mechanism for distributing
direct relief payments to any provider, including tribal recipients, prior
to the pandemic, according to HRSA officials. Consequently, HRSA
did not have a mechanism in place to distribute PRF payments to
tribal providers. HRSA officials said that they used information
provided by IHS to distribute payments, including recipient names,
mailing addresses, and tax ID numbers. However, according to HRSA
officials, this information contained errors, which resulted in delayed
payments and additional administrative burden for HRSA, IHS, and
recipients to identify the errors and return funds, as applicable. 59
Payments were delayed for 47 tribal health providers (11 percent of
tribal providers), who received payments up to 9 months later than
intended, according to HRSA officials. We have ongoing work
examining HRSA’s administration of the PRF.
• IHS and CDC. CDC transferred a certain amount of its appropriation
from the Coronavirus Response and Relief Supplemental
Appropriations Act, 2021, to IHS, as authorized by the act, which was
enacted in December 2020. 60 Both federal officials and national tribal
organizations have indicated to Congress that authorizing HHS
components to transfer funds to IHS for distribution through existing
mechanisms would help emergency funds reach tribal recipients more
quickly. For example, two national tribal health organizations stated
that many agencies lack expertise with quickly disbursing funds to
tribal recipients, and barriers with other federal agency funding
structures—including CDC—would cause unequal and delayed
access to relief funding. Additionally, the Director of IHS stated in a
June 2020 testimony that the application process for some relief
funding created administrative burden for tribes and that, in the future,
distributing funding through existing contracts and compacts or
59According to HRSA officials, they collaborated with IHS on addressing the identified
payment issues. According to IHS officials, HHS ultimately distributed all corrected
payments to the correct provider, despite the data challenges.
60The act required IHS to distribute the transferred appropriation through direct services,
or to tribes and tribal organizations under the Indian Self-Determination and Education
Assistance Act, and through Indian Health Care Improvement Act title V contracts and
grants to urban Indian organizations. Pub. L. No. 116-260, div. M, tit. III, 134 Stat. 1182,
1911-1912 (2020).
Page 24 GAO-23-105473 COVID-19 Relief Funds
transferring funds from other agencies to IHS for distribution would
streamline the process.
Agency officials also described challenges in implementing other modified
or new programs for tribal recipients that necessitated additional agency
and recipient administrative resources. For example, ACF officials said
that it was challenging to implement the modified Emergency Language
Grant—including developing the noncompetitive grant, reviewing
applications, and issuing awards within the 180-day time frame—while
simultaneously managing existing competitive awards. ACF officials also
said that applying the statutory allocation formula for the new LIHWAP
program would have resulted in nine tribal recipients receiving few, if any,
funds. As a result, ACF took additional steps to ensure that all recipients
would receive sufficient funding to implement the program. 61 Additionally,
ACF officials said that some tribes expressed concern regarding their
capacity to navigate and fulfill the LIHWAP program requirements
because of tribal office closures and staff shortages on account of the
pandemic. To address these concerns, ACF officials said that they
provided training and technical assistance to tribes to help reduce the
administrative burden of LIHWAP program requirements. 62
In addition, Treasury faced challenges including tribes for the first time in
the existing SSBCI program, when ARPA made tribal governments
eligible recipients in March 2021. For example, Treasury officials said that
they had to develop an allocation methodology for tribal recipients and
faced challenges in obtaining the necessary tribal economic employment
data for the formula because of limited availability. Treasury officials also
said that the statutory language superimposes the preexisting structure
for states onto tribes and does not consider the unique circumstances of
tribal governments or tribal economies, making SSBCI challenging to
implement for tribal recipients. Two tribal recipients we met with also
expressed concern over the SSBCI program, including that the program
was not designed for tribes and was incredibly complex to understand. To
encourage tribal participation, Treasury has extended application
deadlines, according to Treasury officials. As of September 2022,
Treasury has not yet disbursed SSBCI funding to tribal recipients,
according to Treasury officials.
61For more information on these steps, see HHS’s LIHWAP One-Pager for Tribes.
62For example, ACF officials said that they provided training and technical assistance on
categorical eligibility, which makes households automatically eligible for LIHWAP benefits
based on their enrollment in other means-tested federal programs.
Page 25 GAO-23-105473 COVID-19 Relief Funds
Existing Reporting Tribal recipients of certain relief funds distributed through existing
Mechanisms Were Familiar to mechanisms and structures were familiar with the reporting requirements
Tribal Recipients and Did Not for these mechanisms and structures, which reduced the time and burden
Require Learning New needed to learn new systems and processes, as we previously found. For
Systems and Processes example, in October 2021, we reported that Interior directed tribes to
report on its CARES Act funds through the standard reporting
requirements for their contracts and compacts, such as single agency
audit reports. To illustrate segregation of CARES Act expenditures from
its annual appropriations, Interior asked recipients to separately identify
CARES Act expenditures within these standard reports, which one tribal
recipient told us did not require excessive new reporting. 63 Interior used
the same mechanisms, including similar reporting requirements, for
ARPA relief funding.
In contrast, for newly established programs, such as the CRF, some tribal
recipients may have had to submit reports through electronic systems that
they had not used before on an expedited basis. 64 These systems were
designed to collect information from multiple types of recipients, including
state and local governments, and we found in October 2021 that some
functions of the reporting portal were made unavailable to tribes.
According to officials from one tribe interviewed for our prior work, this
caused time-consuming manual entry of data and additional
administrative burden to meet reporting requirements. 65
One tribal recipient we spoke to said that Treasury had since incorporated
certain lessons learned from distributing CARES Act funding to improve
the tribal reporting process for distributing funding from ARPA, including
simplifying some report categories. Treasury officials said that they have
worked to accommodate the unique reporting needs of tribes, including
63GAO-22-104349.
64We reported in October 2021 that the CARES Act requires certain recipients to submit to
agencies and the Pandemic Response Accountability Committee within 10 days of the
end of each calendar quarter a report containing information on amounts received and
projects or activities for which funds were expended or obligated, among other things.
Pub. L. No. 116-136, § 15011(b)(2), 134 Stat. 281, 541 (2020). Treasury’s Office of the
Inspector General (OIG) incorporated this provision’s 10-day deadline into its CRF
reporting guidance because tribes’ submissions to the OIG are transmitted to the
committee and serve as these statutorily required reports. See GAO-22-104349.
65We reported in October 2021 that Treasury OIG officials told us that the GrantSolutions
portal, the reporting portal for Treasury funding, allows for data uploads, but this feature
was not made available to tribal governments because of the volume of recipients. See
GAO-22-104349.
Page 26 GAO-23-105473 COVID-19 Relief Funds
providing alternative reporting mechanisms for tribal recipients. However,
according to one tribal recipient we interviewed, the reporting process is
still designed for all recipients, not just tribal governments, and this
uniform approach does not always make sense for tribes because of their
unique circumstances. 66 For example, the subrecipient reporting category
for tribes sometimes prompts extra reporting requirements for entities that
are part of the tribal government, such as a nonprofit organization that
serves as the tribe’s housing department.
We previously reported that during public health and other emergencies
or economic crises, federal agencies must get relief funds out quickly,
while ensuring that appropriate financial and other safeguards are in
place. 67 This is consistent with an April 2020 Office of Management and
Budget (OMB) memorandum that stated that the administration was
committed to rapid delivery of COVID-19 funds and directed federal
agencies to rapidly issue awards and fund programs to meet crucial
needs and that transparency and regular reporting would provide
accountability. 68
Congress considers multiple priorities when drafting emergency relief
legislation, such as getting funds to recipients quickly and including
mechanisms to ensure that funds are distributed in a controlled manner
so that they are used as Congress intended. When Congress wants to
prioritize getting emergency relief to tribes quickly, explicitly enabling
agencies to use existing mechanisms and structures, such as contracts
and compacts, to distribute the funds could help ensure that tribal
recipients can access these funds more quickly. It also would ensure
minimal additional administrative burden on tribes and agencies, while
leveraging existing program reporting mechanisms for accountability.
However, not all agencies have existing mechanisms for quickly
distributing funds to tribal recipients nor the authority to transfer funds to
Interior or other agencies, such as IHS, that do. Interior officials told us
that they could distribute any future emergency funding for tribes—either
received directly or via transfer from another agency—through existing
66According to Treasury officials, Treasury’s funds are for all governments, and Treasury
tries to customize for tribal recipients, where possible.
67GAO-22-105715.
68Office of Management and Budget, Implementation Guidance for Supplemental Funding
Provided in Response to the Coronavirus Disease 2019 (COVID-19), M-20-21
(Washington, D.C.: Apr. 10, 2020).
Page 27 GAO-23-105473 COVID-19 Relief Funds
mechanisms, such as contracts and compacts, but that Interior could use
more staff resources to build its capacity to do so. 69
Greater Flexibility and Longer According to officials from four agencies, two tribal recipients we
Spending Time Frames Helped interviewed, and our prior work, greater program flexibility and longer
Tribal Recipients Use Relief spending time frames to use relief funds helped tribal recipients more
Funds to Efficiently Address efficiently address their unique needs. For example, tribes that received
Their Unique Needs disbursements of CARES Act relief funding from Interior through
contracts and compacts could then choose to reprogram the funds, as we
reported in October 2021. Specifically, they could move funds from Aid to
Tribal Government, Welfare Assistance, or both, to another Tribal Priority
Allocation account, as long as the funds were used solely to prepare for,
prevent, and respond to COVID-19. According to Interior officials, this
flexibility allowed tribes to address their unique circumstances by
determining the best use of funds to meet their citizens’ needs. 70
Further, in March 2021, we found that OMB and selected agencies had
leveraged existing grants management processes to develop and
implement flexibilities that reflected the unprecedented organizational
challenges of the pandemic and that were aligned with relevant internal
control standards. 71 We reported that OMB intended the COVID-19-
related grant flexibilities to help grantees respond to, and address,
organizational challenges stemming from the pandemic by reducing their
administrative burden without compromising accountability. Specifically,
OMB identified flexibilities for agencies to use to help ease the
administrative burden in cases in which grantees or applicants were
affected by the loss of operational capacity and increased costs on
account of COVID-19. Examples of OMB-identified flexibilities include
allowing for application deadline flexibility and waiving requirements for
prior approvals of special or unusual costs to effectively address the
69Interior officials also noted that if Congress wants to implement additional reporting
requirements for tribes on emergency relief funding beyond what is required for existing
contracts and compacts, those reporting requirements should be written into statute.
70GAO-22-104349.
71For example, OMB consulted with agencies involved in a government-wide effort to
modernize grants management policy to identify flexibilities that would strike a balance
between helping grantees respond to the pandemic and maintaining controls against
waste, fraud, and abuse of federal grant funds. Offices responsible for grants
management policy at each selected agency then issued agency-wide guidance
communicating the available flexibilities and policies and procedures for implementing
them. See GAO, Grants Management: OMB Should Collect and Share Lessons Learned
from Use of COVID-19-Related Grant Flexibilities, GAO-21-318 (Washington, D.C.; Mar.
31, 2021).
Page 28 GAO-23-105473 COVID-19 Relief Funds
pandemic response. We reported that officials from organizations
representing grantees—including tribal grantees—said that they used
these flexibilities to address unprecedented operational disruptions, such
as having to close offices in response to stay-at-home orders.
We also found in October 2021 that a lesson learned from the CARES
Act is to allow more time to spend relief funds. Specifically, the CARES
Act had an original statutory deadline of December 30, 2020—9
months—to incur costs for the CRF. Because of disbursement delays,
tribal recipients had roughly 7 months to incur costs, which was
challenging to manage, given construction challenges with supplies and
weather, according to one research institution we spoke to for our prior
work. 72 ARPA provided a longer time frame for recipients to use
payments from the CSFRF—over 3 years to incur costs, instead of the
original 10 months for the CARES Act’s CRF. We found that the longer
time frame provides recipients with more time to plan projects to
maximize the cost-effectiveness of relief spending. In the preamble to the
final rule implementing the CSLFRF, Treasury noted that CRF recipients
expressed great interest in using the CRF to pursue water infrastructure
projects, including provision of drinking water and internal plumbing on
tribal lands and in Alaskan villages, but the short deadline for the use of
funds made it difficult to use the CRF funds in that way. The preamble
also noted that the CSLFRF funds’ longer eligible use date is responsive
to this unmet need. 73
Unclear and Changing Unclear and changing guidance for certain programs increased tribal
Guidance Contributed to recipients’ administrative burden and contributed to delays in their
Added Burden and Delays in spending funds. Specifically, as agencies repeatedly modified guidance
Tribal Recipients’ Spending or provided additional information, tribal recipients had to expend more
Funds time and effort to determine which requirements applied for audit
compliance. This hampered recipients’ plans to use funds as efficiently as
possible, according to representatives from three tribal recipients, one
tribal organization, and our prior work. For example, in October 2021, we
found that one tribe invested an inordinate amount of time, effort, and
72On December 27, 2020, the Consolidated Appropriations Act, 2021, amended the
CARES Act to extend the deadline for CRF recipients to incur costs by 1 year, to
December 31, 2021. Pub. L. No. 116-260, div. N, tit. X, § 1001, 134 Stat. 1182, 2145
(2020).
7387 Fed. Reg. 4338, 4411 (Jan. 27, 2022). The preamble also noted that Congress’
inclusion of the water, sewer, and broadband clause in the ARPA is responsive to this
unmet need.
Page 29 GAO-23-105473 COVID-19 Relief Funds
legal fees to verify that its proposed expenditures of funds from the CRF
were allowable, according to an official from that tribe. By the time the
tribe received clarification from Treasury, the tribe had only 2 to 3 months
to spend the funds before the original statutory deadline for incurring
costs. 74
In another example, HRSA added to or modified the “Use of Funds”
section of its PRF Frequently Asked Questions document several times
after May 2020 to provide answers to a total of 23 questions—after the
majority of tribal recipients had received their PRF payments. Given the
frequent guidance updates, one tribal recipient said that they had to
create a budget for the funding that they could easily change. Although
HRSA provided the date each time it added or modified a frequently
asked question on allowable uses of the PRF, the Frequently Asked
Questions document did not state whether these new or modified
guidelines applied retroactively to previous expenses.
Such continuous updates to guidance on the allowable uses of relief
funds also caused concerns about the possibility of recovery of funds for
unallowable uses. Specifically, one tribal recipient, one tribal organization,
and one researcher we met with raised concerns about the implications of
inadvertently spending funds on ineligible expenses because of untimely
updates to guidance or rulemakings on eligible expenses. For example,
one tribal recipient said that they were concerned about having to repay
federal relief funds to agencies because the recipient might not have the
resources to repay the funds if it had already spent them. This tribal
recipient said that they took painstaking actions to document all expenses
to avoid any question of eligibility because Treasury had released so
many iterations of its CRF guidance on the use of funds. One tribal
organization and one researcher we interviewed reiterated the concern
among tribes of potentially having to return relief funds if they
inadvertently did not use them for the intended purpose. One tribal official
said that most tribes do not have the ability to repay ineligibly used funds,
making timely and articulate guidance essential.
74GAO-22-104349. In April 2022, we found that having timely and sufficient policies and
procedures for monitoring CSLFRF recipients—including compliance with reporting
requirements—is critical for providing assurance that recipients are managing their
allocations in compliance with laws, regulations, agency guidance, and award terms and
conditions, including ensuring that expenditures are made for allowable purposes. See
GAO-22-105397. The original statutory deadline for incurring costs was December 30,
2020, but was later extended to December 31, 2021.
Page 30 GAO-23-105473 COVID-19 Relief Funds
Some selected agencies have made efforts to clarify information,
including about the potential for recovery of funds. For example, in
January 2022, Treasury issued a statement on compliance with the
CSLFRF interim final and final rules that included the date for when the
final rule goes into effect for recipients and stated that the interim final
rule remains in effect until that date. The statement also indicates that, to
the extent that a recipient has taken significant steps toward obligating
CSLFRF funds in a manner consistent with the interim final rule prior to
January 6, 2022, Treasury generally will not take action to enforce
provisions contained in the final rule, if they are more restrictive than
those in the interim rule. In contrast, although HRSA provided dates for
when it added or modified frequently asked questions on allowable uses
of the PRF, HRSA did not make it clear whether these new or modified
guidelines applied retroactively to previous expenses or projects in
process.
Federal standards for internal control for information and communication
state that management should externally communicate the necessary
quality information to achieve the entity’s objectives and to address
related risks. 75 In addition, the Pandemic Response Accountability
Committee reported in June 2022 that recipients and administrators need
timely and clear guidance to get benefits out efficiently and accurately. 76
By communicating expectations to recipients more clearly and earlier,
federal agencies would better ensure that tribal recipients of future
emergency relief could help agencies proactively address compliance
risks without inadvertently causing tribal recipients to delay using relief
funds until guidance is stable. We have ongoing work examining HRSA’s
implementation of the PRF and are not making a recommendation at this
time. However, monitoring the clarity and timeliness of agencies’
guidance to recipients of emergency relief warrants ongoing attention as
implementation continues in the coming years.
Increased Federal As noted above, certain agencies in our review had substantial
Capacity and Expertise for experience in working with tribes and could leverage existing program
mechanisms to distribute funds to tribal recipients. In contrast, other
Working with Tribes Could
agencies’ lack of experience working with tribes led to several challenges
Improve Future Program for agencies and recipients that negatively affected the timeliness and
Delivery equity of relief funding allocations. For example, agency officials’ lack of
75GAO-14-704G.
76Pandemic Response Accountability Committee, Lessons Learned in Oversight of
Pandemic Relief Funds (Updated) (Washington, D.C.: June 8, 2022).
Page 31 GAO-23-105473 COVID-19 Relief Funds
familiarity with tribal governments and revenue structures contributed to
delayed disbursements of the CRF and the Small Business
Administration’s (SBA) Paycheck Protection Program (PPP).
Furthermore, Treasury faced legal challenges to its administration of the
CRF Tribal Government Set-Aside. 77
• Treasury’s CRF. Treasury initially used data in allocation formulas
that undercounted some tribal populations, as we have previously
reported. Specifically, in October 2021, we found that Treasury’s use
of Department of Housing and Urban Development’s Indian Housing
Block Grant population data to allocate the CRF Tribal Government
Set-Aside did not take into account that many tribes provide services
to members that do not live in their local formula area and that the
relative share of population would, consequently, be undercounted for
such tribes. 78
• SBA’s Paycheck Protection Program. SBA did not consult with
tribal leaders prior to implementing the PPP and initially excluded
critical business sources of tribal government financing, such as
gaming businesses, from receiving relief, as we previously reported.
Specifically, we found in June 2020 that tribal gaming businesses—an
important source of employment and income for many tribes—were
initially ineligible for SBA’s paycheck protection loans because of
77As we reported in October 2021, Treasury faced lawsuits over Alaska Native Claims
Settlement Act corporations’ eligibility for the CRF Tribal Government Set-Aside, the
missed statutory deadline for disbursing the set-aside, and the use of certain data to
allocate the set-aside to tribal governments. See GAO-22-104349. As of November 2022,
a lawsuit over the data used to allocate the set-aside was pending before the federal
appeals court. Shawnee Tribe v. Yellen, No. 22-5089 (D.C. Cir.).
78Treasury officials said that a benefit of using the Indian Housing Block Grant formula
area population data as a proxy for increased expenditures was that it helped them avoid
double-counting population for CRF recipients in Alaska. Specifically, this formula includes
a process for identifying overlapping service areas. See GAO-22-104349. However, in
April 2021, Treasury recognized that the Indian Housing Block Grant formula area
population data may prove insufficient in estimating a tribal government’s increased
expenditures, particularly when a tribe does not have a formula area, and reallocated a
portion of the remaining CRF Tribal Set-Aside pursuant to a new methodology that
accounts for certain scenarios in which the data might prove insufficient.
Page 32 GAO-23-105473 COVID-19 Relief Funds
restrictions in SBA’s interim final rule. 79 SBA did not consult with tribal
leaders about program implementation until 11 days after the agency
started accepting PPP applications and did not modify its eligibility
requirements until after the initial appropriation of $349 billion in PPP
funding was exhausted. 80 After hearing tribal leaders’ concerns about
the exclusion of legal gaming businesses, SBA modified its interim
final rule to remove these restrictions, which allowed these
businesses to apply for PPP loans under the additional appropriation
of $321 billion in PPP funding. 81
We have previously found that improving federal capacity for working with
tribes could help agencies better design programs to meet the unique
needs of tribes, improve federal agencies’ ability to conduct meaningful
consultations, and improve the quality of technical assistance for tribal
recipients. 82 For example, Treasury took steps to improve its capacity by
adding staff with extensive experience in working with tribes. According to
Treasury officials, the Office of Recovery Programs, which was
established in April 2021 to lead Treasury’s implementation of economic
relief and recovery programs, has a tribal team with tribal policy,
organization, government, and enterprise experience to support the
deployment of tribal funds and significantly increased communication with
tribes, including over 100 engagement sessions in 2021. In September
2022, Treasury announced the appointment of the first Native American
Treasurer of the United States and established a new Office of Tribal and
79The CARES Act appropriated $349 billion for the Paycheck Protection Program under
SBA’s 7(a) small business lending program. SBA’s initial interim final rule for the PPP said
that businesses with revenue from legal gaming were not ineligible for a loan from the
program, if certain conditions were met. 85 Fed. Reg. 21747, 21751 (Apr. 20, 2020).
SBA’s initial interim final rule required these conditions to balance the long-standing policy
reasons for limiting lending to businesses primarily and substantially engaged in gaming
activity, with the policy aim of making the program available to a broad segment of U.S.
businesses and their employees.
80According to the consultation notice, SBA decided to consult with tribes only after tribes
raised concerns about program eligibility and requested a consultation.
81SBA updated its interim final rule to allow legal gaming businesses that were otherwise
eligible to apply for paycheck protection loans beginning on April 28, 2020, for the
additional appropriation of funding. See GAO-20-625.
82See examples in GAO-19-22, GAO-22-104241, and GAO-22-104349.
Page 33 GAO-23-105473 COVID-19 Relief Funds
Native Affairs. Its recovery team has moved into this office to further its
support for tribal recovery and economic development. 83
Other selected agencies also provided technical assistance to tribal
recipients to help mitigate the administrative burden while administering
relief programs. For example, ACF officials said that they developed a
training and technical assistance strategy to support both the LIHWAP
and Emergency Grants for Native American Language Preservation and
Maintenance recipients, including actions tailored to tribal recipients to
address their needs. ACF officials held office hours, training, and other
assistance for tribal recipients as they developed plans for the LIHWAP
program and assigned program specialists to each grant recipient to
answer any program questions. Similarly, NOAA officials said that they
provided technical assistance and worked directly with tribes to try and
mitigate tribal capacity concerns. NOAA officials said that they
communicated extensively with tribes, including hosting two tribal
consultations, multiple webinars for tribes on the application process for
CARES Act fisheries funding, and working directly with recipients to
provide feedback on spending plans.
To strengthen government-to-government relationships with tribes, a
2021 presidential memorandum directed federal agencies to submit a
detailed plan of actions to OMB on how each agency plans to implement
the policies and directives of Executive Order 13175 on tribal
consultation. 84 Additionally, the memo directs agencies to submit
progress reports to OMB on the status of their plans and any proposed
updates. Each of the selected agencies’ action plans included building
capacity and expertise, such as designating subject matter experts,
creating and consulting internal work groups, working with tribal advisory
groups to identify improvements to their processes for engaging with
tribes, or training employees to increase their understanding and to
83In September 2022, Treasury notified recipients of certain relief programs that Treasury
planned to curtail some of its administrative support for recipients because it did not have
sufficient funds for these programs. In October 2022, Treasury ended its call center,
curtailed its email response operations, and notified recipients of new resources on
commonly asked questions. Treasury acknowledged that the greatest impact of these
changes will likely be felt by the smallest jurisdictions and tribal governments. According to
the agency, Treasury officials are working with Congress to seek flexibility in how
administrative funds can be used across programs, which would restore its ability to
provide additional administrative support.
84Memorandum, Tribal Consultation and Strengthening Nation-to-Nation Relationships, 86
Fed. Reg. 7491 (Jan. 29, 2021).
Page 34 GAO-23-105473 COVID-19 Relief Funds
strengthen agency consultation policies. 85 Agencies’ ongoing
implementation of these action plans will be an important step toward
helping agencies better understand and meet the unique needs of tribes
and tribal communities.
COVID-19 has disproportionately harmed the health and welfare of AI/AN
Conclusions individuals, tribal government operations, and tribal economies. To
address these and other impacts, Congress has appropriated at least
$43.6 billion in COVID-19 relief laws for several existing and new federal
programs serving tribes, their members, and tribal organizations. In some
cases, agencies were able to leverage established mechanisms, such as
contracts and compacts, to quickly disburse funds and maintain
accountability, with few additional steps. In other cases, agencies needed
to quickly develop new mechanisms for recipients to access and use
relief funds, without prior experience in providing such assistance to
tribes. These new programs generally required more time and
administrative capacity for agencies to implement and for tribal recipients
to access and use, which inadvertently created barriers for tribal
recipients’ use of relief funds to address the disproportionate impacts in
tribal communities.
Since March 2020, agencies, tribes, and others have identified several
lessons learned that could help mitigate these barriers and improve future
federal administration of emergency relief for tribes. In some instances,
agencies applied lessons learned from their implementation of early
COVID relief programs to their implementation of relief programs under
subsequent COVID-19 relief laws, such as by clarifying which
requirements apply to spending decisions and taking steps to increase
their capacity to work with tribes. However, in other instances, additional
action is necessary to mitigate barriers for future emergency relief and to
ensure that tribal recipients can access and use funds as Congress
intends. For emergency relief that Congress wants tribes to receive as
quickly as possible, providing agencies with the explicit authority to use
established mechanisms, such as contracts and compacts, as
appropriate—either directly or through interagency transfers—would help
85For example, HHS officials told us that they formed a working group with the HHS
Secretary’s Tribal Advisory Committee members to review tribal leaders’ input on ways to
improve HHS’s tribal consultation practices and develop recommendations for changes to
HHS’s policy. HHS expects to finalize its policy in early 2023, after additional consultation
with tribes.
Page 35 GAO-23-105473 COVID-19 Relief Funds
agencies administer future relief efficiently without compromising
accountability.
Congress should consider, when seeking to provide tribes with
Matter for emergency relief that it wants to be distributed as quickly as possible,
Congressional providing this relief in a manner that enables agencies to distribute it
through existing mechanisms and structures, such as self-determination
Consideration contracts and self-governance compacts, as appropriate. (Matter for
Consideration 1)
We provided a draft of this report to Commerce, HHS, Interior, Treasury,
Agency Comments and USDA for review and comment. Commerce, HHS, Treasury, and
USDA provided technical comments, which we incorporated, as
appropriate. Interior responded by email that they did not have comments
on the draft report.
We are sending copies of this report to appropriate congressional
committees, the Secretaries of Agriculture, Commerce, Health and
Human Services, the Interior, and the Treasury; and other interested
parties. In addition, the report is available at no charge on the GAO
website at https://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at (202) 512-3841 or ortiza@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made key contributions to this report are
listed in appendix II.
Anna Maria Ortiz
Director, Natural Resources and Environment
Page 36 GAO-23-105473 COVID-19 Relief Funds
List of Addressees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Kyrsten Sinema
Chair
The Honorable James Lankford
Ranking Member
Subcommittee on Government Operations and Border Management
Committee on Homeland Security and Governmental Affairs
United States Senate
Page 37 GAO-23-105473 COVID-19 Relief Funds
The Honorable Rosa L. DeLauro
Chair
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard E. Neal
Chairman
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives
Page 38 GAO-23-105473 COVID-19 Relief Funds
Appendix I: Additional Information about Appendix I: Additional Information about
Selected Federal COVID-19 Relief to Tribal
Selected Federal COVID-19 Relief to Tribal
Recipients
Recipients
Table 3: Characteristics of Selected Federal COVID-19 Relief to Tribal Recipients
Appropriation / Amount Distribution
Department Agency / office program (in dollars) Eligible recipients mechanism Steps to access
Appropriations for tribal recipients
Treasury Office of Recovery Coronavirus Relief 8 billion Tribal governmentsa New Tribes had to submit
Programs Fund Tribal two rounds of data
Government Set-
Aside
Emergency Rental 800 million Tribe or eligible New Tribes that did not
Assistance 1 tribally designated participate in the
Tribal Community housing entityb Indian Block Grant
Set-Aside program in fiscal
year 2020 had 30
days to notify
Treasury whether
they wished to
participate in the
ERA program
State Small 500 million Tribal governmentsc Newd Submit notice of
Business Credit intent and then
Initiative (SSBCI) submit a capital
Tribal Set-Aside application
Coronavirus State 20 billion Tribal governmentse New Submit a request for
Fiscal Recovery funding
Fund Tribal
Government Set-
Aside
Interior Bureau of Indian Operation of 453 million Tribes, tribal Existing Nonef
Affairs (BIA) Indian Programs organizations, and
BIA
Bureau of Indian American Rescue 900 milliong Tribes, tribal Existing The potable water
Affairs Plan Act of 2021 organizations, BIA portion of funding
was issued through
an application.
Generally, no
additional steps were
needed for other
portions of fundingh
Commerce National Oceanic Fisheries Disaster 30 million Federally recognized Existing Submit application to
and Atmospheric Assistance for tribes determine
Administration Tribal Fisheries suballocation
(NOAA) Participants amounts
Health and The Administration Emergency Grants 20 million Specified entitiesi Existing Submit grant
Human Services for Children and for Native application
(HHS) Families American
Language
Preservation and
Maintenance
Page 39 GAO-23-105473 COVID-19 Relief Funds
Appendix I: Additional Information about
Selected Federal COVID-19 Relief to Tribal
Recipients
Appropriation / Amount Distribution
Department Agency / office program (in dollars) Eligible recipients mechanism Steps to access
The Administration Low Income Up to 34.1 Tribes and tribal New Submit designation
for Children and Household Water millionj organizations letter, grant
Families Assistance application form, and
Program Tribal an implementation
Set-Aside plan
Agriculture Farm Service Agricultural Debt As much as Socially New Not applicablen
(USDA) Agency Reliefk necessaryl disadvantaged
farmer or rancherm
Allocations for tribal recipients
Commerce National Oceanic Assistance for 16.8 milliono Tribal, subsistence, Existing Tribes had to submit
and Atmospheric Fishery commercial, and a spend plan and
Administration Participants charter fishery then, once the plan
participants was approved, tribes
had to solicit and
review application
from fishery
participants
Health and Health Resources Provider Relief 520 millionp Eligible health care New Noner
Human Services and Services Fund (PRF) providersq
Administration
Source: GAO analysis of the six laws providing comprehensive relief across federal agencies and programs that the Treasury uses to report COVID-19 spending, agency interviews, agency
documentation, and prior work. | GAO-23-105473.
a
“Tribal government” is defined to mean the recognized governing body of an Indian tribe, which the
CARES Act defined as any Indian tribe, band, nation, or other organized group or community,
including any Alaska Native village or regional or village corporation as defined in or established
pursuant to the Alaska Native Claims Settlement Act, which is recognized as eligible for the special
programs and services provided by the United States to Indians because of their status as Indians. 42
U.S.C. § 801(g)(1).
b
Tribe, or its tribally designated housing entity, that was eligible to receive a grant under Title I of the
Native American Housing Assistance and Self-Determination Act of 1996 for fiscal year 2020. In
addition, the Department of Hawaiian Homelands is eligible for this program. 15 U.S.C. §
9058a(b)(2)(A).
c
“Tribal government” is defined to mean the recognized governing body of any Indian or Alaska
Native tribe, band, nation, pueblo, village, community, component band, or component reservation,
individually identified (including parenthetically) in the list published most recently as of March 11,
2021, pursuant to section 104 of the Federally Recognized Indian Tribe List Act of 1994. 12 U.S.C. §
5701(19).
d
SSBCI was created by the State Small Business Credit Initiative Act of 2010, but tribes were not
eligible recipients until the act was amended by the American Rescue Plan Act of 2021 (ARPA).
e
“Tribal government” is defined to mean the recognized governing body of any Indian or Alaska
Native tribe, band, nation, pueblo, village, community, component band, or component reservation,
individually identified (including parenthetically) in the list published most recently as of March 11,
2021, pursuant to section 104 of the Federally Recognized Indian Tribe List Act of 1994. 42 U.S.C. §
802(g)(7).
f
If a tribe did not have a self-determination contract or self-governance compact that included Aid to
Tribal Government or Welfare Assistance, BIA provided those programs’ services to the tribes or its
members as a direct service, or tribes could modify or amend their existing contract or compact to
include these programs.
g
Of the $900 million ARPA appropriation, $100 million was for tribal housing improvement; $772.5
million was for tribal government services, public safety and justice, social services, child welfare
assistance, and other related expenses; $20 million was to provide and deliver potable water; and
Page 40 GAO-23-105473 COVID-19 Relief Funds
Appendix I: Additional Information about
Selected Federal COVID-19 Relief to Tribal
Recipients
$7.5 million was for federal administrative costs and oversight. Pub. L. No. 117-2, tit. XI, § 11002, 135
Stat. 4, 241-242 (2021).
h
According to Interior officials, tribes that did not operate a Housing Improvement Program had to
create a new Housing funding contract with BIA to allow distribution of funding.
Public and nonprofit private agencies, including, but not limited to, governing bodies of Indian tribes
i
on federal and state reservations, Alaska Native villages and regional corporations established by the
Alaska Native Claims Settlement Act, and such public and nonprofit private agencies serving Native
Hawaiians, and Indian and Alaska Native organizations in urban or rural areas that are not Indian
reservations or Alaska Native villages. 42 U.S.C. §§ 2991b-3(a)(1), 2991b(a).
j
Division H of the Consolidated Appropriations Act, 2021, created the Low-Income Household
Drinking Water and Wastewater Emergency Assistance Program and appropriated $638 million for it.
Up to 3 percent of that appropriation was reserved for Indian tribes and tribal organizations. Pub. L.
No. 116-260, div. H, tit. V, § 553, 134 Stat. 1182, 1627 (2020). The ARPA of 2021 appropriated $500
million for the program and also reserved up to 3 percent of that appropriation for Indian tribes and
tribal organizations. Pub. L. No. 117-2, tit. II, § 2912, 134 Stat. 4, 51-52. HHS’s Office of Community
Services allocated $34.1 million to the LIHWAP Tribal Set-Aside.
k
In June 2021, a federal judge issued a temporary restraining order prohibiting USDA from forgiving
loans under this program until such time as the court could rule on whether a preliminary injunction
was warranted. Faust v. Vilsack, No. 21-cv-548 (E.D. Wis. June 10, 2021). Before that judge ruled on
a preliminary injunction, other federal courts issued preliminary injunctions preventing USDA from
making debt relief payments nationwide pending the outcome of the lawsuits. Wynn v. Vilsack, No.
21-cv-514 (M.D. Fla. June 23, 2021); Miller v. Vilsack, No. 21-cv-595 (N.D. Tex. Oct. 18, 2021).
Section 22008 of the Inflation Reduction Act of 2022 repealed the ARPA provision authorizing this
program. Pub. L. No. 117-169.
The ARPA appropriated such sums as may be necessary for the cost of loan modifications and
l
payments under this program. Pub. L. No. 117-2, tit. I, § 1005(a)(1), 135 Stat. 4, 12 (2021).
m
Socially disadvantaged farmers or ranchers are farmers and ranchers who are a members of a
socially disadvantaged group, which is a group whose members have been subjected to racial or
ethnic prejudice because of their identity as members of a group without regard to their individual
qualities. 7 U.S.C. § 2279(a)(5), (6).
n
Prior to the program ending, officials said that the steps to access included a small payment
notification on complex cases, where farmers had to return the acceptance of the payment offers,
which certified that the information that USDA had on file about the qualification for the program was
correct.
o
The CARES Act appropriated $300 million for assistance for fishery participants but did not include a
set-aside for tribes. Pub. L. No. 116-136, tit. II, § 12005, 134 Stat. 281, 518 (2020). After reviewing
relevant information submitted by tribes, NOAA determined tribe suballocations, totaling $16.8 million.
p
The fund received appropriations totaling $178 billion. HHS allocated $520 million of the fund for
tribal distribution.
q
PRF eligible health care providers are public entities, Medicare- or Medicaid-enrolled suppliers and
providers, and for-profit and not-for-profit entities that the Secretary of HHS specifies. Pub. L. No.
116-136, div. B, tit. VIII, 134 Stat. 281, 563 (2020).
r
While PRF recipients did not need to take further action to receive funds, they did have to attest to
the payment terms and conditions for allowable uses of PRF payments; entities that took no action
and retained funds were deemed to have attested to the terms and conditions after 90 days. PRF
recipients were also required to subsequently report on the use of funds, if they received more than
$10,000 in a given reporting period.
Page 41 GAO-23-105473 COVID-19 Relief Funds
Appendix II: GAO Contact and Staff
Appendix II: GAO Contact and Staff
Acknowledgments
Acknowledgments
Anna Maria Ortiz, (202) 512-3841 or OrtizA@gao.gov
GAO Contact
In addition to the contact named above, Lisa Van Arsdale (Assistant
Staff Director), Michelle Wong and Caroline Prado (Analysts in Charge),
Acknowledgments Estelle Bowman, Tara Congdon, Cindy Gilbert, Samantha Jorgensen,
Brooke Linsenbardt, Dan Royer, and Jeanette M. Soares made key
contributions to this report.
(105473)
Page 42 GAO-23-105473 COVID-19 Relief Funds
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