The 638 and ISDEAA landscape
The Indian Self-Determination and Education Assistance Act (ISDEAA) enables tribes and tribal organizations to assume control of federal programs previously administered by the Bureau of Indian Affairs and Indian Health Service. Title I (Public Law 93-638) contracts and Title V compacts are the two primary mechanisms, each with distinct reporting and financial requirements.
Tribal health consortia managing multiple 638 contracts and ISDEAA compacts face the same portfolio management challenges as other intermediaries — but with additional layers of complexity. Contract support costs must be tracked separately. Indirect cost rates are negotiated individually. And reporting requirements vary by IHS area office, making standardization difficult.
Contract support cost tracking
Contract support costs (CSC) are the administrative overhead costs associated with carrying out a 638 contract. These costs are funded separately from the program and must be tracked, reported, and reconciled independently. Underfunding of CSC has been a long-standing issue, and accurate tracking is essential for both compliance and for supporting claims for full funding.
WeavePulse tracks CSC at the contract level, including direct CSC (costs directly attributable to a specific contract) and indirect CSC (shared administrative costs allocated across contracts). This separation is critical for accurate reporting to IHS and for supporting cost proposals in future contract negotiations.
Negotiated indirect cost rates
Tribal organizations negotiate indirect cost rates with their cognizant federal agency, typically the Department of the Interior. These rates vary by organization and by fiscal year, and applying the wrong rate to the wrong period can result in audit findings.
WeavePulse stores the negotiated indirect cost rate for each sub-grantee and applies it automatically in financial calculations and reports. When rates change, the system applies the correct rate to the correct period without manual intervention.
GPRA performance measures
The Government Performance and Results Act (GPRA) requires IHS-funded programs to report on specific clinical and public health performance measures. These measures — covering areas like diabetes management, immunization rates, behavioral health screening, and prenatal care — are reported through the IHS reporting system but must also be tracked at the program level.
WeavePulse includes GPRA measure tracking as a built-in reporting template. Consortia managing multiple tribal health programs can collect GPRA data from each member program and generate consolidated performance reports showing progress toward IHS targets.
Respect for tribal sovereignty
Tribal health data is sovereign data. WeavePulse is designed with the understanding that data ownership belongs to the tribal organization, not the software provider. Data access is controlled entirely by the tribal organization's administrators. Data is never shared, aggregated, or used beyond what the organization explicitly authorizes.
We work directly with tribal health organizations during onboarding to ensure the system's configuration respects governance structures, data sharing agreements, and the specific requirements of each tribe's self-determination framework.