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COVID-19 Relief Funds: Lessons Learned Could Improve Future Distribution of Federal Emergency Relief to Tribal Recipients

GAO-23-105473 Published: Dec 15, 2022. Publicly Released: Dec 15, 2022.
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Fast Facts

The public health and economic effects of COVID-19 on tribal nations have been especially severe. To help tribes recover, Congress's pandemic relief funding has included at least $43.6 billion to support new and existing programs that tribes could use to address their unique needs.

While some agencies used existing programs to distribute funds quickly, others had to develop new ones. In some cases, these new programs inadvertently created barriers for tribes' access to relief funds.

We recommended that Congress consider taking steps to ensure that agencies can distribute future emergency funding to tribal recipients quickly with fewer barriers.

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What GAO Found

Agencies used various approaches to provide COVID-19 pandemic relief to tribal entities, tribal members, and American Indian or Alaska Native individuals (tribal recipients). Disbursement and eligibility requirements, distribution and reporting deadlines, and the number and type of steps that tribal recipients had to take to access and use funds varied across federal relief programs (see fig. for examples). For programs that distributed funds through existing mechanisms, such as self-determination contracts and self-governance compacts, tribal recipients generally did not need to take action. These contracts and compacts authorize federally recognized tribes to take over the administration of certain federal programs previously administered by agencies. For other programs, tribal recipients had to take additional steps, such as applying for and receiving approval to access and use certain COVID-19 funds.

Examples of How Federal COVID-19 Relief Programs Distributed Funds for Tribal Recipients

Examples of How Federal COVID-19 Relief Programs Distributed Funds for Tribal Recipients

GAO identified lessons learned from selected agencies' administration of COVID-19 relief funding that could improve future federal relief for tribal recipients. For example, using existing mechanisms, such as contracts and compacts, can enable agencies to more quickly distribute funds to recipients and mitigate administrative burden for agencies and tribes. By enabling agencies to use existing mechanisms to distribute funds, Congress would better ensure that they 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 selected agency is implementing an action plan that includes building capacity and expertise to better meet the unique needs of tribes and tribal communities.

Why GAO Did This Study

COVID-19 has disproportionately harmed the public health and economies of federally recognized tribes and their members. Congress has appropriated at least $43.6 billion since March 2020 for federal programs serving tribes, their members, and tribal organizations. These programs include preexisting and new programs.

The CARES Act includes a provision for GAO to conduct monitoring and oversight related to the COVID-19 pandemic. GAO was also asked to review efforts to provide COVID-19 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.


Congress should consider enabling agencies to use existing mechanisms and structures, such as self-determination contracts and self-governance compacts, as appropriate, to distribute emergency relief to tribal recipients.

Matter for Congressional Consideration

Matter Status Comments
Congress should consider, when seeking to provide tribes with emergency relief that it wants to be distributed as quickly as possible, providing this relief in a manner that enables agencies to distribute it through existing mechanisms and structures, such as self-determination contracts and self-governance compacts, as appropriate. (Matter for Consideration 1)
As of March 5, 2024, Congress has not introduced or passed legislation to address this matter.

Full Report

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Access to health careEmergency reliefFederal agenciesFederal assistance programsNative AmericanspandemicsPublic health emergenciesTribal governmentsSelf-determinationSet-asides