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Are Tribes Ready for Expanded Coronavirus Relief Fund Regulations?

Dear Tribal Leaders & Enterprise Operators:

The Office of Inspector General and the federal CARES Act audit manager make it clear for tribes: they are NOT the oversight.  

It is the Tribes responsibility to ensure compliance with CARES requirements. OIG will do audits and “spot checks” on the new quarterly reporting requirements. 

The latest guidance explains that liabilities must be incurred by December 30, 2020, meaning goods and services must be ordered and delivered by that date.  

Tribes will have till September 2021 to pay those liabilities, but it DOES NOT mean encumbered or set aside orders. It means goods ordered and or services delivered by December 30.  

It is important that DOCUMENTATION policies and procedures be developed for all expenditures. It is the TRIBES responsibility to monitor the spending of money’s disbursed.  

This includes all documentation for money sent to divisions or departments, enterprises, small businesses, and emergency supplemental payments to individuals. Guidance on Single Audit requirements are still in the works. 

The Department of Treasury and OIG handle monitoring, and oversight of Coronavirus Relief Funds, among other things. 

Specifically, Treasury OIG handles monitoring and oversight of the receipt, disbursement, and use of payments. Treasury OIG also has authority to recover funds if it is determined a recipient of payment does not comply.  

According to a recent memorandum from Treasury, “recipient reporting and record retention requirements are essential for the exercise of these responsibilities, including our conduct of audits and investigations.” 

Treasury will use reported data to support compliance monitoring and oversight efforts and for audit and investigative purposes. 

There are different reporting requirements for different types of payments and expenditures, including the following:  

  • Projects 
  • Expenditure Categories  
  • Contracts Greater Than or Equal to $50,000  
  • Grants Greater Than or Equal to $50,000  
  • Loans Greater Than or Equal to $50,000  
  • Transfers to Other Government Entities Greater Than or Equal to $50,000  
  • Direct Payments Greater Than or Equal to $50,000  
  • Aggregate reporting below $50,000  

Treasury has procedures for authorized officials of prime recipients to certify and send their most recent data on a quarterly basis.  

According to the memorandum, once a report is sent, Treasury will review the submission to ensure that the prime recipient has reported all required information and accounted for the current period’s obligations, expenditures, and loan payments, among other information.  

For help with setting up accounting systems with policies and procedures to fit your organization’s needs, contact McCabe CPA & Consulting Group, LLC. We would love to speak with you.  

Sincerely,

Sean McCabe, CPA, Managing Member

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