For tribal nations and their governments
Not a demographic, not a nonprofit, and not a subdivision of anybody. The relationship is government-to-government, the jurisdiction is the nation’s, and the terms follow from that. Data about the nation and its citizens is governed by the nation’s own law, exportable in full at any moment without a request to us, and never used to train anything. Enrolment, eligibility and benefit determinations remain the nation’s alone.
A nation operates the functions of a government — courts, police, health, housing, social services, education, environment, enterprises — and frequently does so for a citizenry spread far beyond its own lands, which means service delivery is a distance problem as well as a capacity one.
Funding arrives through compacts, self-determination contracts, programme grants and enterprise revenue, each with its own reporting, its own period and its own auditor, and several of them structured by agencies that do not always administer them consistently.
Reporting burden is disproportionate. A nation may report to several federal agencies, a state on some matters, its own council, and an auditor, on programmes that would be one department elsewhere — with an administrative staff sized for the nation rather than for the number of reports.
Vendor systems are usually built for counties and states and assume structures that do not apply. Enrolment is not residency, jurisdiction is not a county line, and a system that cannot represent those correctly produces data that is wrong in ways only the nation notices.
And the history is present in the room. Data about Native people has been collected, held and used by outside institutions without consent for a very long time, and any proposal involving a nation’s data starts from that rather than from a blank page.
A nation reports to several agencies on programmes another government would run as one department, and the administrative staff is sized for the nation rather than for the reporting — so capacity is consumed by accounting for the work rather than doing it.
That is an arithmetic problem rather than a management one, and it does not resolve by working harder. It is also the part that can legitimately be carried, because it is document work with written rules.
The first act is the obligation map, done under the nation’s direction: every compact, contract and grant with its reporting calendar, its period, its conditions and its auditor. One document, held by the nation.
What can then be carried is the assembly and the chasing. Reports built from data the nation already holds. A subrecipient or partner document chased. A period ending with funds unspent, surfaced with lead time. A records request answered. Completeness checked against a programme’s own requirement list.
What never moves: any enrolment determination, which is a matter of the nation’s own law and citizenship and is not a vendor’s business under any circumstances; any eligibility or benefit determination; any programme judgement; and any decision reserved to the council, the courts, or an officer of the nation.
And what is structural rather than promised is the data position, which is set out in the next section because it is the substance of the relationship rather than a term inside it.
Whether every reporting obligation is written down in one place — measured by whether one document holds every compact, contract and grant with its calendar — most administrations start without it.
Time to assemble a report — measured by elapsed hours from a report becoming due to submission, per funder.
Periods ending with funds unspent — measured by count surfaced with lead time, against those previously found at closeout.
Staff hours accounting for work rather than delivering it — measured by time-on-task sampling across reporting and programme delivery, before and after.
Partner and subrecipient documents outstanding — measured by count and age, by partner.
Whether the nation can export everything at any moment — measured by a real export performed during the engagement rather than described in a contract.
any enrolment determination, which is a matter of the nation’s own law and citizenship; any eligibility, benefit or programme determination; any decision reserved to the council, the courts or an officer of the nation; and any authority over the nation’s data. Nothing here asserts jurisdiction, and nothing here holds anything the nation cannot take back unilaterally.
Enrolment is not residency and jurisdiction is not a county boundary. Where a system in scope cannot represent those correctly, that is stated as a limitation of the system rather than worked around by mapping the nation onto a structure that misrepresents it — a workaround there produces data that is wrong in ways that later matter.
It reads and writes the nation’s own systems through documented interfaces and creates no second record of a citizen. No enrolment data is required for any function described here, and it is not requested.
Reporting is assembled to each funder’s format from data the nation already holds. Nothing interprets a compact or a contract; where two documents disagree, that is reported to the nation’s administration rather than resolved.
And where a federal or state system in the chain cannot be reached through a documented interface, that is a limitation and the step stays manual.
Data about the nation and its citizens is the nation’s. That is a position on ownership rather than on stewardship, and it produces specific terms: the nation may export everything, in full, in an open format, at any moment, without a request to us and without our assistance being required.
It is governed by the nation’s own law. Where the nation’s law and another jurisdiction’s conflict, that is identified during scoping rather than resolved by us, and it may close the scope — which is the correct outcome rather than a failure.
It is never training material, at any tier, under any agreement, with no exception for aggregated or de-identified forms. The history here makes a narrow promise worthless: a commitment that permits aggregate use is a commitment to use it.
On termination the nation instructs and we comply: data returned in full, and destroyed on the nation’s schedule with confirmation. Nothing is retained for our own purposes.
And the export is demonstrated during the engagement rather than described in a contract, because a contractual export right nobody has exercised is a right nobody has verified.
The council approves, and what it should read is the data position rather than the capability description — ownership, export, training, termination, and which law governs. Those are the terms that matter and they are short enough to read completely.
The nation’s attorney should confirm that governing law is the nation’s and that dispute resolution does not require the nation to submit to another forum. If a proposed term does, that is a term to refuse rather than negotiate.
The administration’s question is capacity, and the honest framing is that the obligation map is useful even if nothing else follows and can be produced without any system access.
And the auditor should review the record format against a real single audit, because the reporting assembly is what it will examine.
Every compact, contract and grant mapped to one document — calendar, period, conditions, auditor — transcribed from the nation’s own agreements, with no system access and no citizen data.
No credentials, no integration, no data about anybody. The map is built from agreements the nation already holds, which means the first engagement carries no data risk at all — and given the history, a first step that requires no data is the right first step.
The map is frequently the whole value and stopping there is expected. It is a document the nation keeps, it survives staff turnover, and it is the thing that makes reporting capacity plannable.
If anything follows, the data terms are settled before it — ownership, export, training, termination and governing law — as terms rather than as assurances, and the export is demonstrated rather than described.
That history is why the terms on this page are stronger than anywhere else in this architecture, and why they are terms rather than values. Full unilateral export at any moment, in an open format, without asking us. Never training material at any tier — with no exception for aggregated or de-identified forms, because a promise with that exception is a promise to use it. Return and destruction on your instruction and your schedule. And the export demonstrated during the engagement rather than described in a contract, because an unexercised right is an unverified one.
Most are, and the failure is not cosmetic — enrolment is not residency and jurisdiction is not a county line, and a system that maps the nation onto those structures produces data that is wrong in ways only you will notice, years later. Where a system in scope cannot represent it correctly, the honest answer is to state the limitation rather than to map around it. If that closes the scope, it closes the scope.
The nation’s law governs, and a term requiring the nation to submit to another forum is one to refuse rather than negotiate. Where the nation’s law and another jurisdiction’s genuinely conflict on a specific programme, that is identified during scoping and may close the scope — which is the correct outcome. Your attorney should read those terms before the capability description, because they are the substance of the relationship rather than a clause inside it.
Then the obligation map is the right and possibly the only step: no credentials, no integration, no data about any citizen, and an output the nation keeps. It is built from agreements you already hold. If it produces nothing you did not know, very little was spent. If it shows a period ending with funds unspent — which is the usual finding — it has paid for itself before any question of capacity arises.