Finance & Grants

The audit is the design, not the deadline

A tribe that expends a million dollars or more in federal awards in a fiscal year must have a Single Audit, or a program-specific audit in the limited case where every award falls under one federal program. That threshold rose from seven hundred fifty thousand dollars for fiscal years beginning on or after October 1, 2024, and it is measured across every federal program together, not grant by grant. A tribe drawing from several sources can cross it without any single award being large.

The findings that recur for tribal entities cluster in a predictable place: allowable costs, missing supporting documentation, subrecipient monitoring, and reporting. Most of that is documentation, and documentation is what an attributed, sealed record produces as a byproduct of doing the work correctly the first time.

Money moves only when a person says so

Seeing a payment, approving one, and carrying one out are three separate authorities here, granted deliberately and to different people. The system can prepare a payment and request it. It cannot send one. A person authorizes, and that authorization is itself a sealed record naming who gave it.

Separating those powers is what closes the oldest exposure in any finance office: one person holding cash authority, approval authority, and an unattributed ledger. Here the ledger attributes every entry as it is made, and no single account can close the loop alone.

• Every entry is attributed to a person and a date as it is made, not reconciled to one later.
• Approval is a separate authority from action, with a ceiling you set.
• The system cannot move money on its own. It can request a payment; a person has to approve it.
• Every approval is sealed, so who authorized what is provable rather than remembered.
• The prior version is always kept, so an adjustment is visible and attributed rather than quiet.

Many awards at once, each on its own clock

A tribal finance office is rarely running one grant. It is running a portfolio, and the awards arrive from different places on different calendars: self-determination contracts and BIA programs, IHS, housing funds, justice funds, health and human services funds. Each award carries its own reporting cadence and its own period of performance, so the office is never working toward one deadline. It is working toward all of them at once.

The Justice Department's Coordinated Tribal Assistance Solicitation shows both halves of that. Since fiscal year 2010, DOJ has combined its tribal government-specific competitive funding opportunities into one solicitation and required only one application from each tribe or tribal consortium, administered across four components. One application, then several awards, each reporting on its own schedule for years after the money lands.

Which is why reporting belongs on the record as a by-product of the work rather than a reconstruction of it. When every entry names its award, its person, and its date at the moment it is made, the quarterly report is a read of the record instead of a winter spent rebuilding a year out of folders and a spreadsheet.

The clocks outlast the award, and they stagger. Federal award records are kept three years from the date that award's final financial report is submitted, so each award opens its own retention window on its own date. Property and equipment records run three years from final disposition instead. Program income earned after the period of performance runs three years from the end of the fiscal year in which it was earned. One history, kept whole and provable, carries all three without anyone tracking them by hand.

Records technology is fundable. Purpose Area 3 of the FY25 solicitation funded developing or enhancing adult tribal justice systems, expressly including data collection and analysis and information technology for court operations, at an anticipated ceiling of $900,000. Purpose Area 5 listed data management systems for record keeping and case management as allowable equipment. Those are FY25 planning estimates, not guarantees, and purpose-area numbering, ceilings, and award counts change year to year (FY25 had no Purpose Area 7 or 10 at all). Check the open cycle before planning against any of these numbers.

The Single Audit is two opinions, and the second one is about your record

A Single Audit produces two opinions, not one. The first is whether the financial statements are fairly presented in accordance with generally accepted accounting principles. The second is whether the tribe complied with the requirements that could have a direct and material effect on each major program, measured against federal statutes, regulations, and the terms and conditions of the awards themselves. The second opinion is the one your record answers.

Not every program gets examined to the same depth. The higher-scrutiny Type A floor starts at one million dollars in federal awards expended, and for a tribe expending up to thirty-four million dollars, the Type A and Type B dividing line sits at that same one million. Above thirty-four million the threshold scales on the table in 2 CFR 200.518(b)(1), which a larger tribe should read directly rather than from anyone's summary.

The auditee has its own list, and it is longer than hiring an auditor.

• Arrange the audit, and give the auditor access to personnel, books, and records.
• Prepare the Schedule of Expenditures of Federal Awards, which is a read of where the money went across every program at once.
• Prepare the summary schedule of prior audit findings, which asks what you said last year and what you did about it.
• Prepare the corrective action plan for this year's findings.
• Follow up promptly and take corrective action, which is the part the next auditor checks first.

Two more facts shape the arithmetic. The program-specific audit, the lighter option, is available only when the awards are expended under a single federal program, so a tribe drawing from several does not reach it. And a tribe under the threshold is exempt from the federal single-audit requirement, not from scrutiny: its records remain subject to review or audit by the awarding agency, the pass-through entity, and the Government Accountability Office. The record earns its keep at every level of federal funding, not just above the line.

Expended is not the same as cash out the door. Federal awards expended can include the value of federally funded loans and loan guarantees, donated property, and certain noncash assistance, so the count runs on 2 CFR 200.502 rather than on a checkbook. Some tribal funding also sits outside this framework: self-governance and self-determination compacts and certain awards follow specialized audit rules. Confirm which awards count toward the threshold for your tribe.

Fees, fines, and per-capita: money attached to a person and a date

Most of the money a tribal government handles belongs to somebody in particular. A court fee, a fine, a bond, a housing payment, a per-capita distribution: each one attaches to a person and a date, and nearly every report that will ever be asked about it is a count of those two facts. When the entry carries them from the moment it is made, the count the report asks for is already there.

Per-capita is where this turns strict. Under the Indian Gaming Regulatory Act, net gaming revenues may be distributed per capita only under a revenue allocation plan the Secretary of the Interior has approved as adequate, with the interests of minors and legally incompetent persons protected, and with payments subject to federal taxation and notice to members. Making per-capita payments without an approved plan puts the tribe in violation of IGRA, and the Justice Department or the National Indian Gaming Commission may enforce it.

Read what the plan itself has to contain and you are reading a specification for a record: a percentage breakdown of net-revenue uses totaling one hundred percent, protection of minors and legally incompetent persons, a description of how members are notified of tax liability and how taxes are withheld under IRS rules, specific per-capita eligibility requirements, and a tribal court system, forum, or administrative process for resolving disputes. Every one of those is a fact your record either carries or does not.

• Eligibility from the same person record the enrollment office maintains, so the roll and the distribution list are one list rather than two that somebody reconciles.
• Minors' and legally incompetent persons' interests held on the person, so the plan's protection is a live state of the record rather than a paragraph in a binder.
• Notice and withholding captured as events, naming who was notified, on what date, and what was withheld.
• Every fee and fine attributed to the person, the matter, and the date as it is taken, so the court's money and the court's docket are one record.
• The percentage breakdown as a read of the ledger, current whenever the plan is reviewed rather than assembled the month it is due.
• Disputes reaching your forum with the evidence attached, because the payment, the eligibility determination, and the roll are already linked.

Per-capita is a choice, not an obligation. A tribe is not required to distribute net gaming revenues per capita, and many do not. IGRA permits net revenues to fund tribal government operations and programs, the general welfare of the tribe and its members, tribal economic development, charitable donations, and the operations of local government agencies. The plan requirement attaches only if the tribe elects to distribute. And this is federal law and federal regulation: your own constitution, your own ordinances, and your own approved plan control in practice, and those are what we build in.

Questions treasurers ask

Do we have to publish our Single Audit?

You must submit the reporting package, and it still goes to the funders and pass-through entities entitled to it. A tribe may choose not to authorize the Federal Audit Clearinghouse to publish it on a public website. The obligation to report is not an obligation to publish, and that choice is yours.

How does this help with per-capita?

Eligibility comes from the same person record the enrollment office maintains, and every distribution is attributed to a person and a date. The roll and the payment stop being two lists that somebody reconciles by hand.

When can we turn finance on?

Finance runs on the same record model as everything else, and it is built with your government from your own procedures and reporting obligations. Every deployment is a build, so the order the departments come up in is yours to choose.