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U.S. Department of the Treasury, Emergency Rental Assistance: "Data and Methodology for Tribal Communities"

Summary

Treasury's Emergency Rental Assistance data and methodology, dated January 19, 2021, for allocating $797.6 million to Indian tribes and tribally designated housing entities based on what each was eligible to receive for FY 2020 from the Indian Housing Block Grant (IHBG) program. The $797.6 million is what remains of $800 million for tribal communities after 0.3 percent ($2.4 million) for the Department of Hawaiian Home Lands. The Chicken Ranch Rancheria of Me-Wuk Indians and the Prairie Island Indian Community declined to participate, while the Mohegan Tribe of Indians of Connecticut opted in and was assigned the IHBG minimum pro-rata share. Each tribe will receive approximately 121 percent of the FY 2020 IHBG formula allocation.

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“U.S. Department of the Treasury, Emergency Rental Assistance: ‘Data and Methodology for Tribal Communities.’” Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/u-s-department-of-the-treasury-emergency-rental-assistance-data-and-me-750ea53732/, SHA-256 eabc7196e048b666f4fc99cad48240c147a1f799bc522caefd17fe183cff8a72.

Full text

                           U.S. DEPARTMENT OF THE TREASURY
                       EMERGENCY RENTAL ASSISTANCE PROGRAM
                             Data and Methodology for Allocations to
                      Indian Tribes and Tribally Designated Housing Entities
                                        January 19, 2021

Section 501(b)(2)(A)(ii) of Division N of the Consolidated Appropriations Act, 2021 (the “Act”)
requires Treasury to allocate $797.6 million to Indian tribes and tribally designated housing
entities (TDHE) using a formula based on the amounts they were eligible to receive for Fiscal
Year (FY) 2020 from the Indian Housing Block Grant (IHBG) program. 1 Those amounts can be
found here:
https://www.hud.gov/sites/dfiles/PIH/documents/FY%202020%20Final%20Allocation%20Sheet
s.xls, column T.

The statute provides that each IHBG participant receives the same proportion of the $797.6
million as it was eligible to receive of total funding in FY 2020 for the IHBG program. The
statute also provides that tribes that did not participate in the IHBG program in FY 2020 be given
30 days to determine whether to participate in the Emergency Rental Assistance (ERA) program.
Treasury has received responses from those tribes. There are three tribes that elected not to
participate in the total funding for the IHBG program.

The Chicken Ranch Rancheria of Me-Wuk Indians and the Prairie Island Indian Community, two
of the three Indian tribes that did not choose to receive an FY 2020 IHBG allocation, have
declined to participate in the ERA program.

The third Indian tribe that did not choose to receive an FY 2020 IHBG allocation, the Mohegan
Tribe of Indians of Connecticut (Mohegan), has opted to participate in the ERA program.

To determine an amount to add for Mohegan, Treasury asked HUD to recompute the FY 2020
IHBG tribal allocations as though Mohegan had participated in the program. According to HUD,
the allocation Mohegan would have received under the FY 2020 IHBG allocations is equal to the
IHBG minimum. Accordingly, Treasury has assigned Mohegan an allocation equivalent to the
IHBG minimum pro-rata share of ERA funding. This approach treats Mohegan equitably
because it uses the same allocation framework as applies to the other Indian tribes. Further, it
uses data available from HUD of the same vintage to make the computation and thereby does not
place other participating Indian tribes at a disadvantage. Pro-rata reductions authorized under
Section 501(b)(2)(B)(i) of Division N of the Act were made to ensure the total ERA tribal
funding including Mohegan did not exceed $797.6 million.

Each tribe will receive approximately 121 percent of their FY 2020 IHBG formula allocation.




1
 Section 501(a)(2)(B) of Division N of the Act provides a total of $800 million for tribal communities. After
subtracting the 0.3 percent ($2.4 million) allocated for the Department of Hawaiian Home Lands directed under
Section 501(b)(2)(A)(i) of Division N of the Act, $797.6 million is available for Indian tribes and TDHEs.


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