OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

CARES Act Flash Report 

Bureau of Indian Affairs Funding Snapshot 

BIA Overview 

Established in 1824 (predating 

the creation of the DOI), the 

BIA provides services to 

approximately 1.9 million 

American Indians and Alaska 

Natives. 

The BIA serves 574 federally 

recognized tribes through four 

offices: 

• The Office of Indian

Services, which oversees

services and programs for

welfare, self-determination,

infrastructure, tribal

government, and workforce

development and education

• The Office of Justice

Services, which operates or

funds law enforcement, tribal

courts, and detention facilities

on Indian Country lands

• The Office of Trust

Services, which carries out

trust responsibilities to Indian

tribes and individuals

• The Office of Field

Operations, which oversees

12 regional offices and 83

agencies that carry out the

BIA mission at the tribal level

Under the Coronavirus Aid, Relief, and Economic Security Act 

(CARES Act) enacted on March 27, 2020, the Bureau of Indian 

Affairs (BIA) received $453 million of the $909.7 million 

appropriated and transferred to the U.S. Department of the Interior 

(DOI) to prevent, prepare for, and respond to the coronavirus 

pandemic. 

In addition, the CARES Act allotted funds to American Indian tribes 

and Alaska Native organizations from the U.S. Departments of the 

Treasury, Agriculture (USDA), and Health and Human Services 

(HHS). The BIA will have varying roles and responsibilities for the 

funding from Treasury, the USDA, and the HHS. Figure 1 provides 

the total breakdown of the allotted funds and the amount specifically 

appropriated to the BIA. 

Figure 1: CARES Act BIA Funding Breakdown 

Funding Source Amount ($) 

Treasury 8,000,000,000 

DOI 453,000,000 

USDA 100,000,000 

HHS 33,461,097 

Total $8,586,461,097 

The BIA can use this funding for numerous purposes, including public 

safety and justice programs, deep cleaning of facilities, personal 

protective equipment (PPE), information technology to improve 

teleworking capabilities, and welfare assistance and social services for 

tribal governments. 

The BIA’s Spend Plan for DOI Funds 

According to its spend plan for the $453 million from the DOI, the 

BIA will distribute funds for staffing, immediate response activities, 

and contracted services. The CARES Act states that no less than 

$400 million shall be made available to meet the direct needs of 

tribes. The funds are to remain available until September 30, 2021. 

CARES Act Flash Report • No. 2020-FIN-051 • Issued September 3, 2020 1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The BIA’s Aid to Tribal 

Government program 

supports tribal government 

operations, elections, policies, 

legislation, and regulations. 

The BIA’s Welfare 

Assistance program provides 

financial assistance for the basic

needs of American Indians who 

reside on or near reservations, 

including payments for food, 

clothing, shelter, social services,

burial expenses, and other 

emergency assistance. 

Top Five Recipients of BIA 

Direct Payments to Tribes 

• Cherokee Nation –

$7,459,874

• Navajo Nation – 

$7,008,211

• Choctaw Nation –

$6,450,137

• Muscogee (Creek) Nation –

$3,781,384

• Sault Ste. Marie Tribe of

Chippewa Indians –

$2,888,284

In a letter to tribal leaders on April 13, 2020, the BIA stated that 

$420 million of the $453 million will be used for direct payments to 

tribes to meet their needs. Of the $420 million, $400 million would be 

distributed through its Aid to Tribal Government program and 

$20 million through its Welfare Assistance program. 

The remaining funds—$33 million—will support the needs of the 

BIA’s immediate response activities, which include COVID-19 

requirements for wildfire operations, PPE and cleaning, equipment 

and supplies for law enforcement in high-risk COVID-19 situations, 

and quarantines in detention centers. Some funds will be held in 

reserve to respond to future pandemic response needs. Figure 2 

provides a breakdown of how the $33 million will be allocated. 

Figure 2: Use of Funds for Immediate Response Activities 

Funding Description Amount ($) 

Personnel/labor costs 1,325,000 

Wildfire operations 1,856,000 

PPE and cleaning supplies 2,199,000 

Community policing equipment and supplies 6,000,000 

IT equipment 7,000,000 

Detention center quarantine 7,500,000 

Facility cleaning 5,600,000 

Reserve 1,520,000 

Total $33,000,000 

The BIA established a formula for distribution of CARES Act funds. 

Aid to Tribal Government funding was allocated based on tribal 

enrollment data, grouping tribes into funding levels based on 

enrollment numbers. Higher enrollment numbers will receive higher 

funding amounts, and tribes with the lowest enrollment numbers will 

receive at least $60,000. Welfare Assistance funding was also 

allocated based on enrollment data for a prorated distribution of the 

$20 million appropriated. 

On May 18, 2020, the BIA announced the distribution amounts per 

tribe for Aid to Tribal Government and Welfare Assistance funds. The 

top five recipients (see sidebar) have been quick to act in establishing 

spend plans and distributing the funds to tribal members: 

• The Cherokee Nation issued its “Respond, Recover, Rebuild” plan

in late May 2020. The plan will largely offset unbudgeted expenses

due to COVID-19, protect employees from layoffs, add safety

measures to infrastructure, increase services for citizens, and invest

in strengthening the Cherokee community’s recovery.

CARES Act Flash Report • No. 2020-FIN-051 • Issued September 3, 2020 2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

- -

-

Success Stories 

The Cherokee Nation has 

invested in healthcare and 

facilities, which positioned the 

tribe well to respond to the 

pandemic. In November 2019, the 

Cherokee Nation invested in a 

469,000 square foot outpatient 

facility, the Cherokee Nation 

Outpatient Health Center, which 

provides access to 30 different 

medical specialties under one roof. 

To respond to the pandemic, it set 

up a call center at the facility to 

answer tribal members’ COVID 19 

questions. The Cherokee Nation 

also broke ground in May 2019 for 

the first medical school in Indian 

Country at W. W. Hastings Hospital 

in Tahlequah, OK, where the 

Cherokee Nation hopes to train its 

own physicians to specialize in 

Indian health issues. The medical 

school is slated to open in fall 2020. 

The Chilkoot Indian 

Association acted quickly to 

assist tribal members facing 

hardships due to the pandemic. 

The Association proactively mailed 

out assistance applications to 

tribal members and has purchased 

food and grocery vouchers for 

members as well as refrigerators, 

freezers, and harvesting 

equipment. The Association has 

also used funds to purchase 

cleaning supply kits (containing 

masks and gloves) and to 

establish a safe quarantine space. 

• The Navajo Nation’s spend plan (issued June 9) funds water

infrastructure projects, PPE, hazard pay, and other services.

• The Choctaw Nation of Oklahoma’s spend plan (issued June 26)

offers income support, technology assistance, student support, elderly

food security, and housing assistance, among other programs.

• On June 23, the Muscogee (Creek) Nation passed legislation to

begin disbursement of funds for individual and family support

programs and healthcare services.

• On July 6, the Sault Ste. Marie Tribe of Chippewa Indians

approved using part of its CARES Act funds to provide emergency

financial assistance to tribal members through its Anishnaabek

Community and Family Services.

Treasury Funding 

Treasury reserved $8 billion for payments to tribal governments to 

cover costs incurred between March 1, 2020, and December 30, 2020, 

as part of its Coronavirus Relief Fund. The funds will allow the tribal 

governments to respond directly to the coronavirus emergency, such 

as addressing medical or public health needs. The funds can also be 

used for second-order effects of the emergency, such as providing 

economic support to those suffering from employment or business 

interruptions due to COVID-19 related business closures. 

Treasury used Indian Housing Block Grant population data from the 

U.S. Department of Housing and Urban Development, rather than the 

tribal enrollment data that tribes reported to Treasury, to apportion 

60 percent of the $8 billion. The remaining 40 percent was apportioned 

based on employment and expenditures of tribes and tribally owned 

entities. Treasury has published two documents on its website regarding 

the allocation method and use of the block grant population data rather 

than the tribal enrollment data. Treasury started making payments to 

tribal governments based on the block grant population data on May 5, 

2020. Treasury started making payments on June 12, 2020, to distribute 

the remaining funds based on employment and expenditures. 

The BIA is not responsible for overseeing the funds from Treasury. 

Treasury’s Office of Inspector General (OIG) has made the BIA 

aware of recipient reporting and record retention requirements to 

assist in answering questions that tribes may have. 

USDA Funding 

The CARES Act provided $100 million to the USDA’s Food 

Distribution Program on Indian Reservations, to remain available until 

September 30, 2021. Of the $100 million, $50 million is to be used for 

facility improvements and equipment updates, including but not limited 

to physical barriers, sinks, sanitation stations, and PPE. The remaining 

CARES Act Flash Report • No. 2020-FIN-051 • Issued September 3, 2020 3 
 

 

 

 

 

 

 

 

442.9 

FRAUD 

1 4.77 

979 

Look for Red Flags That 

Indicate Potential Fraud 

Questions to help the BIA 

identify possible issues include: 

• Is someone exceeding their

authority, routinely overriding

controls, or steering contracts

to a particular vendor?

• Are there gaps in

documentation?

• Do vendor bids match the

Government estimate so

precisely as to raise suspicion

that Government information

may have been improperly

divulged?

• Is the right work being

performed?

• Are invoices prepared in

accordance with the terms

and conditions of the grant or

contract?

$50 million is for additional food purchases. The BIA is not providing 

oversight and is not involved in the process of distributing these funds. 

HHS Funding 

The HHS authorized a transfer of $33 million from its Child Care and 

Development Fund (CCDF) to the BIA, to be available to various 

tribal and Alaska Native organizations. The CCDF helps low-income 

families obtain childcare so they can work or attend training or 

education and promotes coordination among early childhood 

development and afterschool programs. 

The HHS has allocated funds to the BIA within an HHS-maintained 

account. The funds are to remain available until September 30, 2021. The 

BIA will allocate and spend the money directly from the HHS account. 

The BIA received access to the funds on April 21, 2020, and processed 

assistance awards for 44 tribes as directed by the HHS. The HHS retains 

ownership and is responsible for reporting on use of the funds. 

Fraud Awareness and Controls 

The BIA is the largest recipient of DOI funds and has received 

sizeable amounts from other Government agencies; therefore, 

awareness of fraud risks and related internal controls are critical for 

effective oversight. As CARES Act funding gets distributed and 

spent, knowing about potential fraud indicators and controls will help 

the BIA and the tribes protect against misuse or mismanagement that 

could result in the loss of funds. While fraud is not easily discovered, 

behavioral red flags that are commonly displayed include living 

beyond one’s means, unusually close relationships with vendors or 

customers, and an unwillingness to share duties. In addition, red flags 

within transactions that can point to potential fraud include altered 

documents, missing supporting documentation, missing approvals, 

backdated agreements, and questionable costs. 

To detect red flags, the BIA will need to effectively monitor and 

oversee procurements, work performed, invoices, and daily 

transactions. Being aware of the red flags will help managers identify 

possible issues. See the sidebar for questions to consider. 

In addition, effective internal controls have proven to mitigate 

fraudulent activity. Key actions the BIA can take as it provides 

oversight for CARES Act funding include the following: 

1. Establish a written code of conduct.

2. Perform periodic reconciliations of financial reports and

supporting documentation.

3. Implement a system of checks and balances for financial and

program oversight.

CARES Act Flash Report • No. 2020-FIN-051 • Issued September 3, 2020 4 
 

 

Internal Controls Are 

Essential To Prevent Fraud 

A 2018 DOI OIG investigation 

provides an example of how a 

breakdown of internal controls 

can lead to fraud: 

We found that a tribal official 

embezzled more than $98,000 

using a tribal government charge 

card for personal expenses such as

airfare, retail purchases, food, and 

utility and telephone services. The 

charges were billed to the tribe 

and paid using a combination of 

Federal and tribal funds. 

According to a recent study on 

occupational fraud, the top three

weaknesses that led to fraud 

were: 

• Lack of internal controls

• Lack of management review

• Override of existing internal

controls

4. Perform risk assessments of potential vendors that include

background research, experience, and suspension and debarment

coordination with the OIG.

5. Review and update as needed policies and procedures in areas

such as cash disbursements, purchase cards, expense and travel

reimbursements, use of assets, and conflicts of interest.

6. Document clear lines of authority.

7. Perform regular management reviews with corresponding

approvals.

8. Provide fraud awareness training.

9. Review system access controls on a regular basis.

10. Document account codes for Federal funds and tribal funds and

review periodically to ensure the funding is not commingled

across the numerous accounts.

11.Apply professional skepticism—an attitude that includes a

questioning mind, being alert to red flags for fraud or error, and a

critical assessment—to financial data and supporting documents.

12. Report suspected fraud, waste, and abuse immediately to the

appropriate OIG.

Timeline of BIA CARES Act-Related Events 

March 6 The DOI Assistant Secretary for Indian Affairs 

issues a letter to tribal leaders regarding the 

coronavirus. 

March 29 The BIA receives the $453 million from the DOI 

appropriation. 

April 1 The BIA awards the first grant to a tribe. 

April 14 The BIA issues a press release announcing it 

“stands ready” to assist tribes eligible to receive 

funding from Treasury’s Coronavirus Relief Fund. 

April 16 The DOI Assistant Secretary for Indian Affairs 

issues a press release about Coronavirus Relief 

Fund payments to tribal governments. 

April 17 The BIA awards the first contract for services, 

specifically for janitorial services. 

May 19 The BIA issues an Adaptive Operations Recovery 

Plan for phased opening of facilities and offices 

consistent with State and tribal guidance. 

June 2 The DOI Assistant Secretary for Indian Affairs 

approves the pandemic plan for BIA employee 

safety and health and continuity of operations. 

CARES Act Flash Report • No. 2020-FIN-051 • Issued September 3, 2020 5