April 7, 2020
The Honorable Steven Mnuchin Secretary of the Treasury
U.S. Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 E-mail: tribal.consult@treasury.gov Re: Each Tribe’s Total Government Employment Must Be Included In The Treasury’s Calculation For Corona Virus Relief Funds Dear Secretary Mnuchin: I write on behalf of the __________(Tribe/Nation) to urge the Department to include distribution of the $8 billion Tribal Corona Virus Relief Fund. Our Tribe/Tribal Nation/Pueblo directly employs ________ workers. Their continued employment is vital as we battle through this pandemic. The COVID-19 pandemic is inflicting significant adverse impacts on Indian tribal government health care systems and economies. Without a tax base to generate revenue, many tribes rely on tribally-owned entities to provide funding for basic governmental programs and services, such as health care, education, and public safety, for our communities. At the same time, tribally-owned entities are the largest employers in many of our rural regions. Tribally- owned entities provide jobs, health care, and other benefits for more than 310,000 Americans annually. Congress acknowledged the importance of tribally-owned entities by including this term in Section 601(c)(7) of the CRF. This term is not included in the allocation and distribution portion of the CRF for state and local governments. As Treasury implements the CRF, it must acknowledge the unique importance of tribally-owned entities in both the allocation and distribution method, and the guidance developed for permissible uses of the fund. To meet the legal construct of the Coronavirus Relief Fund (CRF) – which again expressly references “tribally-owned entities”, the allocation method that the Administration forms under Section 601(c)(7) should include the number of tribal government and tribally- owned entity employees and wages in your formula, which could be determined using existing IRS Form 941 submissions from tribes and tribally-owned entities. In addition, it is critical that the Department issue broad guidance regarding permissible uses of the Fund under subsection (d). Such guidance must acknowledge the unique importance of tribally-owned entities to tribal government economies by providing broad guidance that the term “necessary expenditures” includes, but is not limited to: o Expenditures associated with the diminished capacity or closure of governments or tribally- owned entities. o Payments, including payroll, health care and related expenses, for employees while governments or entities are at diminished capacity or closed.
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