In 1992 Public Law 102-477 was enacted, allowing tribes to combine several employment, education, and training programs funded by Health and Human Services, the Bureau of Indian Affairs (BIA), and the Department of Education into one program in their accounting records and financial statements. However, the Office of Management and Budget issued guidance in 2009 requiring that individual programs be reported and treated separately on the Schedule of Expenditures of Federal Awards (SEFA).
To address this conflicting guidance, the BIA formed a work group to create proposed changes, with the latest version being released on January 13, 2012, in the form of an FAQ.
Summary of the New Guidance
- The 2009 requirements to separately report each individual program have been eliminated
- Auditors may treat the covered programs as a cluster
- Findings from the previous reporting guidance should be ignored for current audits
While the work group is still deliberating on final guidance, you may now report your 102-477 program expenditures in the SEFA in the same manner you were reporting them prior to the issuance of the 2009 supplemental guidance. For most tribes, this means reporting the individual programs as one combined program. If you have questions about the FAQ, please contact your Moss Adams LLP professional.
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