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Guidance on how tribes can modernize technology with CARES Act funds

Aug 04, 2020

As most reading this article already know, the CARES Act allocated $8 billion of relief funding for tribal governments, and those funds have come with a usage deadline of December 30, 2020. It’s now August, and tribes are experiencing increasing anxiety over what many consider to be vague guidance on how funds can be spent and how to properly document/justify spend.

Guidance we’ve received from the Treasury

The challenge for tribal governments and organizations is not only determining where to put their stimulus funds but also speeding up the bidding, selection and implementation process.

Here at Wipfli, we’ve had many tribes ask us to engage in collaborative efforts with their committees, policy boards and other working groups to point the needle in the right direction for their spend planning, as well as whether there are ways they can speed up their regulatory obligations to get things in place by the end of December.

Joseph Eve and Grant Eve, leaders in our tribal-focused consulting practice, have been partnering with members of tribal governments and gaming enterprises to help them navigate the guidance on spending CARES Act funds. They’ve both been staying on top of every bit of government guidance, and Grant is a member of the National Indian Gaming Association’s COVID-19 executive committee.

“As infection rates continue to rise, tribal administrations are scrambling to respond to the best of their abilities. It’s imperative that tribes and their enterprises construct the proper infrastructure to weather this storm of unprecedented challenges,” said Wipfli Tribal Practice Leader, Grant Eve. 

In Wipfli’s communication with the Treasury’s tribal consulting group, we’ve recently obtained guidance specifically on IT infrastructure enhancements. The Treasury suggests tribes address two questions when determining whether they’re spending CARES Act funds appropriately:

  1. Is this an expenditure that is significantly different from the most recently adopted budget?
  2. Is this an expenditure directly related to response to COVID-19?

The Treasury additionally suggested documenting the justification of the spend for reporting on these expenditures.

Given this guidance, we at Wipfli have put together a list of technology-related areas and solutions that, if properly documented, we believe meet the qualifying requirements:

  • Accounting and finance (i.e., choosing a system that can handle GL, AP, AR, procurement, expense management, multi-entity consolidated enterprise revenue management, allocations and project accounting)
  • Budgeting and multi-scenario planning
  • Business intelligence, data and analytics
  • Cybersecurity
  • Managed IT services
  • Organizational performance and change management
  • Payroll and HR
  • Policy and procedure creation
  • Web-based internal communications portals

The CARES Act funds are a tremendous opportunity for tribes to invest in technology infrastructure and gain the benefits of modern, remote-enabled, paperless systems. Because so many organizations run lean, they can benefit from the many ways the technologies of today streamline processes — creating greater efficiencies and leading to strong ROI on their investment. They enable access from anywhere, at any time, from any web-based device — a necessity during this pandemic and any future challenge leading to brick-and-mortar closure.

Because of the urgency imposed by the December 30 deadline, we’ve put together a more in-depth guide on how tribes can strategically plan, spend and track their CARES Act dollars. This guide can help you identify and understand the areas you can invest in to make the biggest impact on your tribe while leveraging CARES Act relief dollars.

Click here to download the guide.

We invite you to leverage Wipfli as a resource in your CARES Act planning voyage. For a no-cost, no-commitment conversation, email our Director of Tribal Business Services, Jason Winkler, at

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