The Single Audit, and the new $1M threshold

Reviewed against current law and federal sources, 2026.

The threshold is measured on total federal awards expended across every program, not grant by grant. A tribe drawing from many programs can cross the line even when no single grant is large.

• $1,000,000 the Single Audit trigger now
• $750,000 the old threshold it replaced
• Oct 1, 2024 effective date of the change
• 9 months outer deadline to file the report

Do you need one this year?

Any tribe or tribal organization that expends $1,000,000 or more in federal awards during its fiscal year must have a Single Audit under the Uniform Guidance (2 CFR 200.501). The 2024 revision raised the trigger from $750,000 to $1,000,000, effective for fiscal years beginning on or after October 1, 2024. Below the line, a tribe is exempt from the audit requirement, but its records stay open to review by the awarding agency and the Government Accountability Office.

1. Sum federal awards expended Add everything expended across all programs and funding sources: 638 contracts, health, housing, justice grants. It is expended, not received.
2. Compare to $1,000,000 One combined total against one threshold, not a grant-by-grant test.
3. Check your fiscal-year start A year that began before October 1, 2024 still uses the old $750,000 threshold; the $1M applies to years beginning on or after that date.

The readiness checklist

A Single Audit produces two opinions: on the financial statements, and on compliance for each major program. What makes it go smoothly is preparation the tribe controls.

• A Schedule of Expenditures of Federal Awards (SEFA) prepared for the year.
• A summary schedule of prior audit findings.
• A corrective action plan for any current findings.
• The auditor's access to personnel, books, and records.

The deadline that trips people up

The reporting package is due to the Federal Audit Clearinghouse within the earlier of 30 days after the tribe receives the auditor's report, or nine months after the fiscal year ends. The nine-month outer limit is where tribes most often run late.

A tribe may choose not to authorize the Clearinghouse to post its reporting package publicly (2 CFR 200.512(b)(2)). The tribe still submits to pass-through entities and keeps copies available, but the sovereignty option is written into the rule.

Where tribal grantees lose points

Recurring findings cluster in four places: whether costs were allowable, whether the supporting documentation exists, whether subrecipients were monitored, and whether reports were filed on time. Each traces back to a record that should have been complete and attributed when it was made. Federal award records must be kept three years from the final financial report (2 CFR 200.334), and a system that tracks awards expended in real time keeps a tribe on the right side of the $1,000,000 line year-round, instead of reconstructing it at year-end.