The U.S. Treasury Department has clarified that audits for tribally owned commercial entities which received COVID-19 Relief Funds (CRF) from their tribes do not have to have a single audit. Since the covered period is soon ending, a number of tribal governments had asked the Native American Finance Officers Association (NAFOA) to obtain clarification on the applicability of a single audit for tribally owned enterprises that received â€œeconomic support paymentsâ€ or who are â€œbeneficiaries of an assistance support programâ€ using CRF monies as outlined in Treasury CRF FAQs B.13 on October 19, 2020. NAFOA sent a letter to the Treasury on October 21 requesting the explanation.
According to the Treasuryâ€™s response on November 20: In general, if a tribally-owned commercial enterprise received â€œeconomic support paymentsâ€ or is a â€œbeneficiary of an assistance support programâ€ using CRF monies as outlined, the entity would be considered a beneficiary and would not be subject to the Single Audit Act. However, if an entity is carrying out a program (as an equivalent non-profit type entity) on behalf of the Indian tribal government, then it would be considered a sub-recipient and thus subject to the single audit requirements. Also noted in the letter is that the Tribes are to monitor both sub-recipients and beneficiaries for necessary reporting and necessary records regarding their use of CRF payments for compliance with reporting and record retention requirements.
The full letter from the Treasury Department is available, here.
How REDW Can Help
REDW is committed to assisting Tribes and their commercial entities with all aspects of COVID-19 Relief Funds, as well as the myriad aspects of tribal financial management. For more information, contact Corrine Wilson, Principal and National Tribal Practice Leader.
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