Sorry for posting this so late. I received this from Melissa Johnson on June 5, 2019. Please also see attached document as well CFR 2015 title45 vol1 sec75 305 pms draw down
As mentioned on our call last month, I have some guidance on the issue of how frequently a tribe may drawdown their funds from PMS. This was brought up in April in context of the federal shutdown and doing a monthly drawdown causing reduced hours for the program.
45 CFR 75.305 (b) requires that the tribes “minimize the time elapsing from the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…”
(b)(1) speaks to payments in advance of the expenditure as needing to be “as close as is administratively feasible to the actual disbursement by the non-Federal entity”. This has been determined to be no more than 3 business days. So if the tribe needs to drawdown their funds prior to the actual disbursement of the expense, it should be no more than 3 business days prior to the disbursement for the expense. There are some additional items in (b) for advanced payments.
However, it further sets out in (b)(3) that reimbursement is the preferred method if the tribe cannot meet the stringent requirements for advance payment. There is no limitation on submitting payment on a reimbursement method to be only monthly as was the example given in April. It could be weekly, biweekly, monthly, quarterly or any incremental amount that fits the tribe’s need as long as the expenditure as already occurred and it is being done as a reimbursement of that expense.
I hope this helps and please feel free to share on your site with the directors and to ask me any questions.
Melissa D. Johnson
Director, Division of Regional Operations
Office of Child Support Enforcement
Administration for Children and Families, U.S. Department of Health and Human Services
601 East 12th Street, Room 349, Kansas City, MO 64106
firstname.lastname@example.org | 816 426-2269