Dawn Star Consulting, LLC

If your Tribal government, housing authority, or Native-serving nonprofit expends $1,000,000 or more in federal awards in a fiscal year, you are required to have a Single Audit under 2 CFR 200 Subpart F. (OMB’s 2024 revisions to the Uniform Guidance raised the threshold from $750,000, effective for fiscal years beginning on or after October 1, 2024.) The organizations that come through audits cleanly aren’t the ones with the biggest finance departments — they’re the ones that prepared before the auditors arrived. Here’s the checklist we use.

Know your deadline

Under 2 CFR 200.512, your Single Audit package is due to the Federal Audit Clearinghouse within the earlier of 30 calendar days after you receive the auditor’s report, or nine months after your fiscal year ends. In practice: a December 31 fiscal year end means September 30; a June 30 fiscal year end means March 31; a September 30 fiscal year end means June 30. Missing the deadline can jeopardize your standing with awarding agencies — put it on the calendar the day your fiscal year closes.

The preparation checklist

1. Build your SEFA early. The Schedule of Expenditures of Federal Awards is the backbone of the audit. Reconcile it to your general ledger quarterly — not the week before fieldwork — and confirm every award’s Assistance Listing Number, awarding agency, and pass-through entity.
2. Reconcile drawdowns to expenditures. Federal cash draws should match what you actually spent, by award. Unexplained differences between drawdowns and the SEFA are one of the first things auditors test.
3. Document your internal controls — as they actually operate. Auditors test the controls you say you have. If your written procedures describe a three-signature process nobody follows, update the procedures or follow the process. Segregation of duties in small finance offices deserves special attention.
4. Pull your procurement files. For each federally funded purchase, be able to show the method used, cost or price analysis where required, and suspension/debarment verification. Procurement documentation is among the most common findings in Indian Country and everywhere else.
5. Tighten subrecipient monitoring. If you pass funds through to other entities, document your risk assessments, monitoring activities, and review of their audit results. “We sent them the money and they reported back” is not a monitoring program.
6. Support personnel costs. Time and effort records must support salaries charged to federal awards. If staff split time across programs, make sure the documentation reflects how they actually worked.
7. Close out prior findings. Auditors follow up on every prior-year finding. A corrective action plan that was written but never implemented becomes a repeat finding — and repeat findings draw agency attention.
8. Assemble the package before fieldwork. Financial statements, SEFA, notes, corrective action plan, and the data collection form (SF-SAC) — have drafts ready so the audit tests your records, not your ability to produce them under pressure.

Sovereignty and the Single Audit

For Tribal Nations, the Single Audit is more than a compliance exercise — it’s evidence of governance capacity that supports self-determination contracting, compacting, and direct funding relationships. A clean audit history strengthens your position in every negotiation with a federal agency. One note specific to Indian Country: under 2 CFR 200.512(b), an Indian Tribe or tribal organization may opt out of authorizing the FAC to make its reporting package publicly available — a sovereignty protection worth discussing with your auditor.

This article is general information, not legal, audit, or accounting advice. Requirements vary by award — always confirm against your award terms, 2 CFR 200, and your auditor’s guidance.