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Fair Market Rental Value as Match

Hello Directors – 

I would really appreciate responses from any tribes affected as described below:

1) Were you affected by the 2016 change to OCSE/OGM’s policy allowing fair market rental value of office space (i.e. the “less-than-arms-length” issue)?  

2)  If you were affected, was that value part of your match, or was it a cost on the federal side of your grant?

Please respond on this discussion or email me directly at  Further, if anyone has any prior research or experience with this issue please get in touch.


Thank you!


Kate McKay

Northern Arapaho Program Attorney

(on behalf of Karen Returns To War, Director)

4 Responses

  1. It was a huge part of my match, $24,000. I was forced to find that amount elsewhere. That was when I decided to create a job for the CS clerk that would be part of the elder program and paid for by the department of Labor. – Linda

  2. Quinault was also greatly impacted by the fair market rental value of office space, around $19,000.00. I could not find enough in-kind so the tribe has to cash match.

  3. For the Nez Perce Tribe this was right before I came to this position and we were previously using this as a $38,000 match. At the time I came in I had to ask the tribe for a cash match and we also asked for an emergency waiver as that was the year we had bad fires. Since then I have increased some match and the Tribe has continued our cash match.

  4. Thanks for your responses. We are working hard on an argument to get the match back. Contact us directly if you would like more information.


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