Full text
United States Government Accountability Office
Report to Congressional Committees
SINGLE AUDITS
November 2024
Interior and Treasury
Need to Improve Their
Oversight of COVID-
19 Relief Funds
Provided to Tribal
Entities
GAO-25-106741
November 2024
SINGLE AUDITS
Interior and Treasury Need to Improve Their
Oversight of COVID-19 Relief Funds Provided to
Highlights of GAO-25-106741, a report to
Tribal Entities
congressional committees
Why GAO Did This Study What GAO Found
Treasury and Interior awarded $32.7 For the audit period of this report, the Single Audit Act requires nonfederal
billion in COVID-19 relief funds to tribal entities that spend $750,000 or more in federal awards in a year to undergo a
entities, including two of the largest single audit, which is an audit of an entity’s financial statements and federal
COVID-19 relief programs for tribal awards, or in select cases a program-specific audit. The Office of Management
governments. Under the Single Audit and Budget’s (OMB) single audit guidance requires that federal awarding
Act, federal agencies are required to agencies ensure that award recipients submit single audit reports timely. As
provide oversight for the funds that federal awarding agencies, the Department of the Interior and the Department of
they award. the Treasury track the submission of required single audit reports from tribal
The CARES Act includes a provision recipients (see figure). Interior appropriately designed procedures to identify and
for GAO to report on its ongoing track tribal recipients that did not submit required single audit reports or were not
monitoring efforts related to the required to do so, but Treasury has not. Treasury stated that it did not have
COVID-19 pandemic. This report existing single audit processes when its COVID-19 relief programs were
examines Interior’s and Treasury’s established. By finalizing and implementing such procedures, Treasury could
policies and procedures for (1) tracking better ensure that its recipients are meeting its program requirements.
the timely submission of required
single audit reports from tribal entities Single Audit Report Submissions Tracked by Interior and Treasury for Tribal Recipients
to which the agencies awarded Awarded COVID-19 Relief Funds, Fiscal Years 2020 through 2022, as of October 31, 2023
COVID-19 relief funds and (2)
reviewing and following up on the
findings of these audits. It also
describes the assistance these
agencies provided to tribal entities to
help them navigate the single audit
process.
GAO interviewed agency officials,
three tribal-serving organizations, and
a Tribe; analyzed agency data on tribal
recipients of COVID-19 relief funds and
tribal single audit submissions; and
reviewed relevant federal statutes,
regulations, and agency policies and OMB’s single audit guidance also requires awarding agencies to follow up on
procedures related to tracking and single audit findings to ensure that award recipients take timely and appropriate
reviewing single audit reports. action to correct deficiencies identified by the audits. GAO found that both Interior
What GAO Recommends and Treasury have policies and procedures to review findings and issue
management decisions on the adequacy of tribal entities’ plans to correct
GAO urges prompt implementation of findings, but Treasury did not issue timely management decisions. In addition,
an open recommendation that neither agency has procedures for appropriately monitoring the implementation
Treasury issue timely management of tribal entities’ corrective action plans. Until Interior and Treasury develop such
decisions. GAO is making three new procedures, these agencies may be missing opportunities to improve their
recommendations—two to Treasury
oversight of federal awards and to help tribal entities address findings.
and one to Interior—to further enhance
the single audit oversight provided to Interior and Treasury assisted tribal entities that received COVID-19 relief funds
tribal entities. Interior and Treasury in complying with funding and single audit requirements. In general, tribal-serving
agreed with the recommendations. organizations and a tribal official that GAO spoke with stated that Interior and
Treasury have improved their assistance since the beginning of the COVID-19
View GAO-25-106741. For more information,
contact Anne Sit-Williams at (202) 512-7795
pandemic. However, the tribal-serving organizations also noted that agency
or sitwilliamsa@gao.gov. assistance did not fully consider the unique needs of tribal recipients and offered
suggestions for enhancing such assistance.
United States Government Accountability Office
Contents
Letter 1
Background 4
Interior and Treasury Track Single Audit Reports from Tribal
Entities Awarded COVID-19 Relief Funds, but Treasury Does
Not Identify Late or Missing Reports 14
Interior and Treasury Have Procedures for Reviewing and
Following Up on Single Audit Findings, but Do Not Include Key
Monitoring Activities 19
Interior and Treasury Reported Assisting Tribal Entities throughout
the Single Audit Process 27
Conclusions 33
Recommendations for Executive Action 34
Agency Comments and Our Evaluation 34
Appendix I COVID-19 Relief Funding Administered by Interior and Treasury 39
Appendix II Objectives, Scope, and Methodology 42
Appendix III Comments from the Department of the Interior 45
Appendix IV Comments from the Department of the Treasury 47
Appendix V GAO Contact and Staff Acknowledgments 50
Tables
Table 1: Select Single Audit Responsibilities for Federal Awarding
Agencies 6
Table 2: Status of Single Audit Report (SAR) Submissions from
Tribal Entities Awarded COVID-19 Relief Funds by the
Department of the Interior, Fiscal Years 2020 through
2022, as of October 31, 2023 16
Table 3: Status of Single Audit Report (SAR) Submissions from
Tribal Entities Awarded COVID-19 Relief Funds by the
Page i GAO-25-106741 Single Audits of Tribal Entities
Department of the Treasury, Fiscal Years 2020 through
2022, as of October 31, 2023 17
Table 4: COVID-19 Relief Funding for Eligible Tribal Entities
Administered by the Departments of the Interior and the
Treasury 39
Figures
Figure 1: Single Audit Report Process and Example Time Frames 8
Figure 2: The Department of the Interior, Indian Affairs’
Organizational Chart for Single Audit Oversight 9
Figure 3: The Department of the Interior’s Process for Reviewing
Tribal Entities’ Single Audit Reports and Issuing
Management Decision Letters 21
Figure 4: Department of the Treasury’s Process for Reviewing
Tribal Entities’ Single Audit Reports and Issuing
Management Decision Letters 24
Page ii GAO-25-106741 Single Audits of Tribal Entities
Abbreviations
AO awarding official
ARTT Audit Report Tracking Tool
BIA Bureau of Indian Affairs
BIE Bureau of Indian Education
DIEA Division of Internal Evaluation and Assessment
FAC Federal Audit Clearinghouse
IA Indian Affairs
ISDEAA Indian Self-Determination and Education Assistance Act,
as amended
OCA Office of Capital Access
OMB Office of Management and Budget
OSG Office of Self-Governance
OTNA Office of Tribal and Native Affairs
SAR single audit report
SLFRF State and Local Fiscal Recovery Funds
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Page iii GAO-25-106741 Single Audits of Tribal Entities
Letter
441 G St. N.W.
Washington, DC 20548
November 7, 2024
Congressional Committees
Since March 2020, the federal government has awarded billions of dollars
in response to the COVID-19 pandemic, including awarding funds to
Tribes and tribal entities. 1 The unprecedented increase in federal awards
distributed due to the COVID-19 pandemic, including many awards to
recipients receiving a substantial amount of federal funds for the first time,
has emphasized the importance of single audits. Single audits provide an
oversight tool for federal agencies to help ensure that funds are properly
used for allowable purposes.
Of the at least $43.6 billion 2 that COVID-19 relief laws 3 appropriated for
federal programs serving Tribes, tribal citizens, and tribal organizations, 4
1For the purposes of this report, “Tribes” refers to Indian Tribes that have been federally
recognized. As of June 2024, there were 574 such Tribes. Federally recognized Tribes
and individuals who meet the applicable statutory and regulatory definitions of “Indian”
have a unique political status and are eligible for certain federal programs, benefits, and
services because of that status. In this report, we collectively refer to federally recognized
Tribes, tribally controlled schools, tribally designated housing entities, tribal governments,
and tribal organizations as “tribal entities.” For the purposes of this report, we refer to
individuals who meet the applicable statutory and regulatory definitions of “Indian” as
“tribal citizens.” Tribal citizens are not required to undergo a single audit and are therefore
not included in the scope of our work.
2The $43.6 billion includes appropriations for programs for which Native Hawaiians are
also eligible; however, Native Hawaiians are not tribal citizens because they are not
citizens of a federally recognized Indian Tribe. Further, the amount does not reflect the
permanent rescissions enacted in the Fiscal Responsibility Act of 2023, Pub. L. No. 118-5,
137 Stat. 10 (June 3, 2023). Effective as of the act’s date of enactment in June 2023, Title
I of Division B of that act permanently rescinded the unobligated balances of certain
COVID-19 relief funding.
3For the purposes of this engagement, the COVID-19 relief laws consist of the six laws
providing comprehensive relief across federal agencies and programs that the Department
of the Treasury uses to record and track COVID-19 relief spending in accordance with
Office of Management and Budget (OMB) guidance. These six laws are the American
Rescue Plan Act of 2021, Pub. L. No. 117-2, 135 Stat. 4 (Mar. 11, 2021); Consolidated
Appropriations Act, 2021, Pub. L. No. 116-260, div. M and N, 134 Stat. 1182 (Dec. 27,
2020); Paycheck Protection Program and Health Care Enhancement Act, Pub. L. No. 116-
139, 134 Stat. 620 (Apr. 24, 2020); CARES Act, Pub. L. No. 116-136, 134 Stat. 281 (Mar.
27, 2020); Families First Coronavirus Response Act, Pub. L. No. 116-127, 134 Stat. 178
(Mar. 18, 2020); and Coronavirus Preparedness and Response Supplemental
Appropriations Act, 2020, Pub. L. No. 116-123, 134 Stat. 146 (Mar. 6, 2020).
4Tribal organizations are the recognized governing bodies of Indian Tribes and other
entities meeting the definition of a tribal organization in 25 U.S.C. § 5304(l).
Page 1 GAO-25-106741 Single Audits of Tribal Entities
$2.27 billion was appropriated to the Department of the Interior. Also, the
Department of the Treasury administered two of the largest COVID-19
relief programs for tribal governments—$20 billion from the Coronavirus
State Fiscal Recovery Fund Tribal Government Set-Aside and $8 billion
from the Coronavirus Relief Fund Tribal Government Set-Aside. See
appendix I for more details about the COVID-19 relief funding that Interior
and Treasury administered.
Under the Single Audit Act, 5 Interior and Treasury have oversight
responsibilities for the funds awarded to tribal entities. 6 For the audit
period of this report, the Single Audit Act and the Office of Management
and Budget’s (OMB) single audit guidance required tribal entities that
spent $750,000 or more in federal awards in a fiscal year to undergo a
single audit (an audit of an entity’s financial statements and federal
awards). 7 These single audits help Interior and Treasury reasonably
ensure that federal funds are used in accordance with applicable legal
requirements. Interior and Treasury are responsible for reviewing these
single audits and following up on any audit findings to provide reasonable
assurance that tribal recipients take timely and appropriate action to
correct deficiencies identified through the single audit process.
The CARES Act includes a provision for us to conduct oversight of the
funds made available to respond to the COVID-19 pandemic. 8 This report
examines the extent to which Interior and Treasury appropriately
designed and implemented policies and procedures to help ensure they
(1) track the timely submission of required single audit reports from tribal
entities to which they awarded COVID-19 relief funds and (2) review and
follow up on the findings of these audits, including issuing written
5The Single Audit Act is codified, as amended, at 31 U.S.C. §§ 7501-7506, and the OMB
single audit guidance is reprinted in 2 C.F.R. part 200, subpart F.
6See 31 U.S.C. § 7502(f)(1) and 2 C.F.R. § 200.513(c).
7See 31 U.S.C. § 7502 and 2 C.F.R. § 200.501. In limited circumstances, tribal entities
may be permitted to undergo a program-specific audit rather than a single audit. For
federal awards issued on or after October 1, 2024, OMB’s Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards, reprinted in 2
C.F.R. § 200.501, raised the single audit expenditure threshold from $750,000 in federal
awards per year to $1 million per year. See OMB’s final rule for OMB Guidance for
Federal Financial Assistance, which was issued in April 2024. 89 Fed. Reg. 30,046 (Apr.
22, 2024). For purposes of this report, we used the $750,000 threshold because it was in
effect during our review.
8See the CARES Act, Pub. L No. 116-136, div. B, § 19010(b), 134 Stat. 281, 580 (Mar.
27, 2020), reprinted in 31 U.S.C. § 712 note.
Page 2 GAO-25-106741 Single Audits of Tribal Entities
management decisions on tribal entities’ plans to correct findings in a
timely manner. This report also describes Interior’s and Treasury’s
assistance, and tribal perspectives on this assistance, to help tribal
entities navigate the single audit process, address single audit findings,
and prevent future single audit deficiencies.
For our first and second objectives, we interviewed Interior and Treasury
officials to discuss their single audit processes for tracking, reviewing, and
following up on single audit reports. We also obtained and reviewed the
design of Interior’s and Treasury’s single audit policies and procedures.
We assessed Interior’s and Treasury’s policies and procedures against
the Single Audit Act, 9 OMB’s single audit guidance, 10 and federal internal
control standards 11 related to the control activities component to
determine the extent to which the agencies conducted appropriate
oversight using single audit reports.
To address our first objective, we obtained Interior’s and Treasury’s lists
of tribal entities to which they awarded COVID-19 relief funds for fiscal
years 2020, 2021, and 2022. We compared this list to a list of single audit
reports that Interior and Treasury obtained from tribal entities for the
same period (the most recent period for which single audit reports were
submitted). For those tribal entities that Interior and Treasury awarded
COVID-19 relief funds but had not submitted single audit reports, we
reviewed each agency’s data and inquired with agency officials to
determine whether Interior and Treasury had implemented a process to
track whether a tribal recipient was required to submit a single audit
report and had not.
For our second objective, we selected and reviewed a sample of single
audit reports that (1) were submitted by tribal entities that received most
of their funding from Interior or Treasury; (2) contained findings related to
Interior or Treasury COVID-19 relief programs; and (3) were submitted for
fiscal years 2020, 2021, and 2022. For Interior, we reviewed all 28 single
audit reports that met the criteria. For Treasury, we randomly selected a
nongeneralizable sample of 30 single audit reports from the 177 reports
that met the criteria. Because we used a nongeneralizable sample to
9The Single Audit Act is codified, as amended, at 31 U.S.C. §§ 7501-7506.
10OMB’s implementing single audit guidance is reprinted in 2 C.F.R. part 200, subpart F.
11GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: Sept. 2014).
Page 3 GAO-25-106741 Single Audits of Tribal Entities
select the single audit reports, our findings cannot be used to make
inferences about the entire population of reports.
To address our third objective, we met with Interior and Treasury officials
to discuss the assistance these agencies provide to tribal entities for
complying with requirements of the Single Audit Act and OMB’s single
audit guidance. We also interviewed representatives from three tribal-
serving organizations and one tribal official to obtain their perspectives on
the support Interior and Treasury provide to tribal entities. We identified
and selected tribal-serving organizations that (1) operate nationally; (2)
focus on strengthening tribal finance, supporting economic development,
and building tribal government capacity; and (3) were willing to meet with
us. Using the list of single audits reviewed under objective two, we
identified and selected Tribes that (1) had single audit findings related to
both Interior and Treasury programs; (2) had not been recently contacted
by GAO in the course of other GAO engagements; and (3) were willing to
meet with us. The perspectives of the representatives from three tribal-
serving organizations and one tribal official we interviewed cannot be
generalized to those we did not interview. Additional details regarding our
objectives, scope, and methodology are provided in appendix II.
We conducted this performance audit from March 2023 to November
2024 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
Background
The Single Audit Act and For the audit period of this report, the Single Audit Act and OMB’s single
Federal Agencies’ audit guidance required nonfederal entities that spent $750,000 or more
in federal awards in a fiscal year to undergo a single audit or, in limited
Responsibilities circumstances, a program-specific audit. 12 Single audits must be
performed by an independent auditor and conducted pursuant to
generally accepted government auditing standards. 13 Single audits are
12See 31 U.S.C. § 7502 and 2 C.F.R. § 200.501.
1331 U.S.C. § 7502(c); 2 C.F.R. § 200.514(a).
Page 4 GAO-25-106741 Single Audits of Tribal Entities
typically done either by a private firm hired by the award recipient or by a
state or local government audit agency.
OMB’s single audit guidance requires each award recipient that meets the
single audit threshold to submit an audit reporting package to the Federal
Audit Clearinghouse (FAC). 14 The reporting package must include (1) the
award recipient’s financial statements and schedule of expenditures of
federal awards; (2) a summary schedule of prior audit findings; (3) the
auditor’s report, including an opinion on whether the award recipient’s
financial statements and schedule of expenditures of federal awards are
fairly stated; and (4) the award recipient’s corrective action plans to
address the auditor’s findings, as applicable. 15 Federal agencies and
other interested parties may access the reporting package through the
FAC. 16
OMB’s single audit guidance requires that federal awarding agencies
assume oversight responsibility for the funds that they award to
14See 2 C.F.R. § 200.512 for OMB’s single audit guidance on report submission. As
required by the Single Audit Act, OMB designated the FAC as the central repository for
single audit reporting packages prepared and submitted by nonfederal entities (e.g.,
states, local governments, nonprofit organizations, Indian Tribes and tribal organizations,
and institutions of higher education). In October 2023, responsibility for maintaining the
FAC shifted from the U.S. Census Bureau to the General Services Administration.
152 C.F.R. § 200.512(c).
16The FAC must make reporting packages publicly available, except in cases when an
Indian Tribe or tribal organization (as defined in the Indian Self-Determination and
Education Assistance Act, as amended, which is classified, as amended, in part at 25
U.S.C. § 5304(l)) exercises the option not to authorize the FAC to make the reporting
package publicly available on a website. See OMB’s single audit guidance at 2 C.F.R. §
200.512(b).
Page 5 GAO-25-106741 Single Audits of Tribal Entities
nonfederal entities, including tribal entities. 17 As shown in table 1, these
responsibilities include (1) ensuring timely receipt of completed audit
reports, (2) following up on audit findings, (3) monitoring recipient’s
corrective actions on findings, and (4) tracking effectiveness of the single
audit process.
Table 1: Select Single Audit Responsibilities for Federal Awarding Agencies
1. Ensure that audits are completed and reports are received in a timely manner.
2. Provide technical audit advice and assistance.
3. Follow up on audit findings and monitor the recipient taking appropriate and timely corrective action.
4. Coordinate with other agencies on management decisions for audit findings that affect the federal programs of more than one
agency.
5. Issue management decisions.
6. Appoint an official who is responsible for ensuring that the agency fulfills single audit requirements.
7. Appoint a key management single audit liaison to serve as the point of contact for the single audit process and promote
interagency coordination, consistency, and sharing.
8. Use audit follow-up techniques to promote prompt corrective action by improving communication, fostering collaboration,
promoting trust, and developing an understanding between the federal agency and the nonfederal entity.
9. Provide OMB annual updates to the compliance supplement, which is an authoritative source for auditors to use in identifying and
understanding existing compliance requirements that should be considered as part of an audit.
10. Develop a baseline, metrics, and targets to track the effectiveness of the single audit process.
11. Oversee training related to the single audit process.
Source: GAO summary of Office of Management and Budget (OMB) guidance. I GAO-25-106741
As part of their responsibilities, federal awarding agencies must ensure
that award recipients complete and submit single audit reports within the
earlier of 30 calendar days after receipt of the auditor’s report or 9 months
17A federal awarding agency is any federal agency that provides a federal award directly
to a nonfederal entity. 2 C.F.R. § 200.1. See, in particular, 31 U.S.C. § 7504(a) and 2
C.F.R. § 200.513(c), which set out certain single audit responsibilities of federal awarding
agencies. Nonfederal entities may have multiple federal awarding agencies and will have
one cognizant or oversight agency. The cognizant agency for audit is the federal awarding
agency designated to carry out the responsibilities described in 2 C.F.R. § 200.513(a)
when the award recipient expends more than $50 million of federal awards in a fiscal year.
The oversight agency for audit is the federal awarding agency that provides the
predominant amount of direct funding to an award recipient that is not assigned a
cognizant agency for audit. 2 C.F.R. § 200.513(b). When there is no direct funding, the
federal awarding agency with the predominant source of pass-through funding must
assume the oversight responsibilities. See 2 C.F.R. § 200.1 and 2 C.F.R. § 200.513(b). A
federal awarding agency that is designated as the cognizant agency for audit or the
oversight agency has additional single audit responsibilities, respectively, under 2 C.F.R. §
200.513(a) and 2 C.F.R. § 200.513(b).
Page 6 GAO-25-106741 Single Audits of Tribal Entities
after the recipient’s audit period. 18 However, as we have previously
reported, the FAC does not have the capability to identify federal award
recipients that are required to submit a single audit. Thus, federal
agencies are not able to use the FAC to identify recipients that were
required to submit a single audit but did not do so, including those that
received federal awards from multiple federal agencies that, when
combined, could have caused them to spend at least $750,000. In
addition, there is no oversight mechanism (i.e., responsible government-
wide entity or comprehensive database) that tracks federal award
expenditures in real time or determines when an award recipient,
including a tribal entity, should submit a single audit report. Federal
awarding agencies often do not have a means for determining whether a
federal award recipient met the expenditure threshold for a single audit.
Some federal agencies reported that they do not have access to other
agencies’ awards information to be able to make such a determination. 19
OMB’s single audit guidance requires that federal awarding agencies
follow up on audit findings to ensure that the recipient takes appropriate
and timely corrective action. 20 As part of this follow-up, the agencies must
issue management decisions—written determinations on the adequacy of
recipients’ proposed corrective action plans to address audit findings—
within 6 months of acceptance of the audit report by the FAC. 21
The agencies must also monitor recipients taking appropriate and timely
corrective action and provide technical advice and counsel to award
recipients and auditors as requested. 22 In addition, federal awarding
agencies must develop a baseline, metrics, and targets to track the
effectiveness of their process to follow up on audit findings and on the
effectiveness of single audits in improving nonfederal entity accountability
and their own federal award decisions. 23 Figure 1 depicts the overall
182 C.F.R. §§ 200.507(c)(1), 200.512(a)(1). If the due date falls on a weekend or a federal
holiday, then the submission due date is the next business date. For program-specific
audits, the audit guide may specify a different period.
19GAO, Single Audits: Improving Federal Audit Clearinghouse Information and Usability
Could Strengthen Federal Award Oversight, GAO-24-106173 (Washington, D.C.: Apr. 22,
2024).
202 C.F.R. § 200.513(c)(3).
212 C.F.R. § 200.513(c)(3)(i) and 2 C.F.R. § 200.521.
222 C.F.R. § 200.513(c)(3)(ii) and (c)(2).
232 C.F.R. § 200.513(c)(3)(iv).
Page 7 GAO-25-106741 Single Audits of Tribal Entities
process and example time frames for single audit report submissions by
tribal recipients, as well as for single audit reviews conducted by federal
awarding agencies.
Figure 1: Single Audit Report Process and Example Time Frames
a
Agencies may award funds in a prior fiscal year or in the same fiscal year that they are spent.
b
The independent auditor or the tribal recipient uploads the single audit reporting package to the
Federal Audit Clearinghouse (FAC). Both the auditor and the tribal recipient are required to certify the
submission of the single audit reporting package. See 2 C.F.R. § 512(b).
c
The Office of Management and Budget (OMB) directed federal awarding agencies to allow federal
award recipients and subrecipients with fiscal year-end dates through June 30, 2021, to delay
completing and submitting their single audit reporting packages to the FAC to 6 months beyond the
normal due date. See Office of Management and Budget, Promoting Public Trust in the Federal
Government through Effective Implementation of the American Rescue Plan Act and Stewardship of
the Taxpayer Resources, OMB Memorandum M-21-20 (Washington, D.C.: Mar. 19, 2021).
Page 8 GAO-25-106741 Single Audits of Tribal Entities
Interior and Treasury Interior. The Office of Assistant Secretary – Indian Affairs (IA) is in the
Offices Responsible for Office of the Secretary of the Interior and administers federal programs
for Tribes and tribal citizens. As shown in figure 2, IA includes
Single Audit Oversight of
components, such as the Bureau of Indian Affairs (BIA) and the Bureau of
Federal Awards to Tribal Indian Education (BIE), and other offices and divisions under IA’s
Entities responsibilities. IA directly administers programs (direct service) or award
funding for tribally administered programs. IA oversees the processing of
single audit reports for federal awards administered through cognizant
bureaus and offices under its purview, including BIA, BIE, and the Office
of Self-Governance (OSG). As part of its single audit oversight
responsibilities, IA designated the Division of Internal Evaluation and
Assessment (DIEA) to coordinate with BIA, BIE, and OSG and manage
the overall single audit oversight and review process for tribal entities.
Figure 2: The Department of the Interior, Indian Affairs’ Organizational Chart for
Single Audit Oversight
As outlined in IA’s Single Audit Report Handbook, 24 DIEA monitors the
submission of tribal single audit reports, the review of single audit
findings, issuance of management decisions, and audit resolution and
closure. DIEA also serves as the liaison office between applicable offices
within IA (i.e., BIA, BIE, and OSG), Interior’s Office of Financial
Management, Interior’s Office of Inspector General, and external auditors.
DIEA is responsible for IA policy and provides guidance to IA offices on
tribal single audits to help ensure IA compliance with the Single Audit Act
and OMB’s single audit guidance.
24Department of the Interior, Indian Affairs, Single Audit Report Handbook, 5 IAM 2-H
(Reston, Va.: Oct. 28, 2021).
Page 9 GAO-25-106741 Single Audits of Tribal Entities
Treasury. Prior to the COVID-19 pandemic, Treasury did not have
existing single audit processes or staff. The agency built its single audit
capabilities by hiring additional staff with single audit expertise and
developing policies and procedures for reviewing single audit findings and
issuing management decisions. Treasury designated its Office of
Recovery Programs as the office responsible for overseeing its single
audit responsibilities for COVID-19 relief programs. In 2023, this office
was renamed the Office of Capital Access (OCA). 25
OCA manages the single audit review process for its programs and tracks
the submission of single audit reports from tribal entities and other
nonfederal entities. As outlined in Treasury’s Single Audit Procedures,
OCA’s responsibilities include 26
• monitoring the submission of single audit reports to the FAC;
• reviewing single audit reports to assess findings related to Treasury’s
awards and the recipients’ corrective action plans, and issuing
management decision letters to Treasury’s COVID-19 relief fund
recipients;
• providing technical advice and counsel to recipients to help ensure
their compliance with the terms and conditions of their award
agreements;
• collecting, storing, and conducting analyses on single audit data
retrieved from the FAC for award recipients to enable OCA to perform
its single audit-related responsibilities; and
• coordinating single audit efforts, as appropriate, with other Treasury
offices, OMB, and the audit community.
Treasury also established the Office of Tribal and Native Affairs in
September 2022 to advise on economic and recovery programs and other
policy matters that affect tribal communities and to coordinate tribal
consultations and listening sessions, among other services.
25See app. I for a list of COVID-19 relief funds administered by Treasury.
26Department of the Treasury, Office of Recovery Programs, Single Audit Procedures,
vers. 1.1 (June 14, 2023).
Page 10 GAO-25-106741 Single Audits of Tribal Entities
Importance of Single Audit
Reporting for Tribal
Entities
Single Audit Reports Provide Single audit reports provide valuable information on the design
Information on Tribal appropriateness and operating effectiveness of internal controls over
Recipients’ Financial compliance for major federal award programs. 27 For example, single audit
Management, Internal Control, reports convey whether a tribal entity’s accounting system has adequate
and Compliance internal controls to provide full accountability for assets, liabilities,
revenues, and expenditures. Single audit reports can also help determine
whether financial reports contain accurate and reliable financial data and
if federal award funds were spent in accordance with the terms and
conditions of award agreements and applicable laws or regulations that
may have a direct and material effect on major programs.
Single audit reports convey whether a tribal recipient has federal award
audit findings, including certain types of questioned costs and likely or
known fraud. 28 For example, in one of the single audit reports we
reviewed, an independent auditor found that a Tribe lacked sufficient
oversight to ensure that procurement policies were consistently followed
when spending COVID-19 relief funds, resulting in questioned costs of
about $7,000. In another single audit report, an independent auditor
reported that a Tribe was not able to provide sufficient support to confirm
that COVID-19 relief funds were spent in accordance with the terms and
27Among the federal programs under which a recipient undergoing a single audit expends
federal awards, certain programs are designated as “major programs.” An auditor
determines that a federal award program is a major program using a risk-based approach
and process outlined in 2 C.F.R. § 200.518. Alternatively, a federal awarding agency or
pass-through entity identifies a program as a major program in accordance with 2 C.F.R. §
200.503(e).
28A single audit report summarizes the results of an audit and reports any program-related
audit findings that contributed to an overall opinion on the recipient’s compliance with
award requirements and internal control over compliance. 2 C.F.R. § 200.515. A federal
award audit finding is a deficiency in the recipient’s internal control over major programs;
material noncompliance with the provisions of federal statutes, regulations, or the terms
and conditions of federal awards related to a major program; known questioned costs that
are greater than $25,000 for a type of compliance requirement for a federal program; or
known or likely fraud affecting a federal award. 2 C.F.R. § 200.516. A questioned cost is a
cost that is questioned by the auditor because (1) there was a violation or possible
violation of a statute, regulation, or the terms and conditions of a federal award; (2) the
cost is not supported by adequate documentation; or (3) the cost appears unreasonable
and does not reflect the actions a prudent person would take in the circumstances. 2
C.F.R. § 200.1. In their management decisions, federal awarding agencies must
determine whether questioned costs related to their programs should be sustained
(disallowed) or reinstated (allowed). 2 C.F.R. § 200.521.
Page 11 GAO-25-106741 Single Audits of Tribal Entities
conditions of the award, resulting in questioned costs of approximately
$180,000. Reported federal award findings help identify weaknesses in a
timely manner. Correcting these identified weaknesses may help
reasonably assure the effective use of federal funds and reduce the
likelihood of federal improper payments.
Single Audit Reports Could By correcting single audit deficiencies, Tribes may improve their financial
Affect Tribes’ Eligibility for stability and financial management capability. In addition, single audit
Participation in Self- results may affect tribes’ eligibility for self-governance compacts under
Governance the Indian Self-Determination and Education Assistance Act, as amended
(ISDEAA). 29 ISDEAA authorizes Interior to enter into self-determination
contracts and self-governance compacts at the request of eligible
Tribes. 30 Both self-determination contracts and self-governance compacts
authorize Tribes to take over the administration of certain federal
programs previously administered by Interior and other federal agencies.
Self-governance compacts, in particular, provide the Tribes with some
flexibility in program administration by allowing Tribes to redesign or
consolidate programs included in the compact and to reallocate funds
among those programs. 31 For example, such flexibility allowed a Tribe to
develop and manage its own COVID-19 response programs without
obtaining permission from the federal agency; as a result, the Tribe
29Pub. L. No. 93-638, 88 Stat. 2203 (Jan. 4, 1975) (classified, as amended, at 25 U.S.C.
§§ 5301-5423). Two or more Tribes may jointly negotiate, execute, and implement a self-
governance compact with Interior by forming a consortium. 25 C.F.R. § 1000.2 and 25
U.S.C. § 5362(b)(3). Each member of the consortium must meet the eligibility
requirements for self-governance compacts. 25 C.F.R. § 1001.2(c).
30In addition to Interior, the Department of Health and Human Services’ Indian Health
Service has the authority to enter into self-determination contracts and self-governance
compacts with Tribes. 25 U.S.C. §§ 5321, 5384. Furthermore, the U.S. Department of
Agriculture has limited authority to enter into self-determination contracts with Tribes and
tribal organizations. Specifically, the Agriculture Improvement Act of 2018 authorized
demonstration projects for Agriculture’s Food Distribution Program on Indian Reservations
to enter into self-determination contracts with tribal organizations and Agriculture’s Tribal
Forest Management Program to enter into self-determination contracts with tribal
organizations and Tribes. Pub. L. No. 115-334, 132 Stat. 4490, 4624-27, 4877, §§ 4003,
8703 (Dec. 20, 2018), which is, respectively, reprinted in 7 U.S.C. § 2013 note and
classified in 25 U.S.C. § 3115b.
3125 U.S.C. §§ 5363(b)(3), 5365(d).
Page 12 GAO-25-106741 Single Audits of Tribal Entities
quickly responded to and mitigated risks related to the pandemic as well
as protected the health and well-being of the tribal community. 32
Interior’s OSG is responsible for developing and implementing the Tribal
Self-Governance Program. To be eligible to participate in the Tribal Self-
Governance Program and enter into self-governance compacts, ISDEAA
requires a Tribe to (1) successfully complete the mandatory planning
process, (2) request participation in self-governance by an official action
of a tribal governing body, and (3) demonstrate financial stability and
financial management capability. 33
To demonstrate the required financial stability and financial management
capability to be eligible to enter into a self-governance compact, ISDEAA
requires that a Tribe, for the 3 fiscal years preceding the date on which it
requests to participate in the Tribal Self-Governance Program, have no
uncorrected significant and material audit exceptions in the required
annual audit of its self-determination or self-governance agreements with
any federal agency. 34 As such, major deficiencies identified in a single
audit report can affect a Tribe’s eligibility for self-governance compacts,
which provide tribal autonomy over administration of federal programs.
32Chairwoman Cheryl Andrews-Maltais, Wampanoag Tribe of Gay Head Aquinnah,
Advancing Tribal Self-Determination: Examining the Bureau of Indian Affairs’ 638
Contracting, testimony before the House Committee on Natural Resources, Subcommittee
on Indian and Insular Affairs, 118th Cong., 2nd sess., March 6, 2024.
3325 U.S.C. § 5362(c).
3425 U.S.C. § 5362(c)(3). The required annual audit under ISDEAA refers to the Tribe’s
single audit reports. 25 U.S.C. § 5305(f).
Page 13 GAO-25-106741 Single Audits of Tribal Entities
As part of their oversight responsibilities under the Single Audit Act,
Interior and Treasury Interior and Treasury track the submission of required single audit reports
Track Single Audit from tribal entities to which they awarded COVID-19 relief funds. Interior
has a process for identifying and following up with tribal entities that did
Reports from Tribal not submit a single audit report. Treasury considered several methods for
Entities Awarded developing such a process but has not yet designed and implemented
procedures for identifying tribal entities with late or missing single audit
COVID-19 Relief reports and for following up with those entities.
Funds, but Treasury
Does Not Identify
Late or Missing
Reports
Interior Appropriately Interior designed and implemented procedures to track single audit report
Tracks Single Audit Report submissions from tribal entities and documented these procedures in its
Single Audit Report Handbook. 35 To help ensure that tribal recipients
Submissions from Tribal
submit single audit reports in a timely manner, awarding officials (AO)
Entities within IA’s cognizant offices (i.e., BIA, BIE, and OSG) send a letter to
each tribal recipient prior to the single audit report due date. 36 The letter
informs the tribal recipient of single audit requirements and requests that
the recipient submit a single audit report. AOs also request certification
statements from those tribal entities that assert that they do not meet the
effective expenditure threshold requirement for single audits. When a
single audit report or certification statement is received, DIEA staff notes
its receipt in its Audit Report Tracking Tool (ARTT). 37 DIEA uses the data
in ARTT to track the status of single audit report and certification
submissions.
Interior also has appropriately designed procedures for identifying and
following up with tribal recipients that did not submit a single audit report
or certification statement. DIEA maintains a comprehensive list of tribal
35Department of the Interior, Indian Affairs, Single Audit Report Handbook.
36An AO is someone who has been delegated authority to award self-determination
contracts, self-governance funding agreements, tribally controlled school grants, or other
grant assistance on behalf of the Secretary of the Interior.
37Interior obtains single audit reports either through a portal on the FAC website weekly or
directly from the tribal recipients through mail or email.
Page 14 GAO-25-106741 Single Audits of Tribal Entities
entities that have received federal awards from IA cognizant offices. 38
Using the data in ARTT, DIEA is able to determine which tribal entities
submitted a single audit report or certification statement, had a late or
missing submission, or otherwise were not required to submit a single
audit report. 39
DIEA notifies the AOs of any late or missing single audit reports, and the
AOs send letters to tribal recipients reminding them of the single audit
requirements and requesting that they submit the late or missing
reports. 40 DIEA also sends status reports regarding late or missing single
audit reports to AOs, IA cognizant offices, and BIA regional management
monthly and to IA leadership, Interior’s Office of Financial Management,
and Interior’s National Single Audit Coordinator on a quarterly basis. 41
These status reports help Interior track the effectiveness of its procedures
to ensure that single audits are completed and reports are received in a
timely manner.
As part of our audit, we obtained a list of tribal entities that received
COVID-19 relief funds from Interior and identified those entities that
submitted single audit reports to the FAC and DIEA. As shown in table 2,
DIEA provided us with the status of single audit report submissions from
tribal recipients as of October 31, 2023. Based on our review, we found
38New tribal entities are added to the list when an AO notifies DIEA of new federal award
recipients or when DIEA identifies new tribal recipients that submitted single audit reports
to the FAC, indicating that they received and spent award funds from Interior.
39In addition to situations where a tribal entity did not meet the $750,000 expenditure
threshold, there are certain circumstances in which a tribal entity may report under a
consortium and does not submit a separate single audit report.
40Indian Affairs’ Single Audit Report Handbook provides procedures for imposing
conditions on tribal entities that do not submit a single audit report by the due date.
Conditions could include IA disbursing award funds in monthly installments or withholding
payments. In our report, Bureau of Indian Education: Improved Oversight of Schools’
COVID-19 Spending is Needed (GAO-24-105451), we found that BIE did not consistently
apply the conditions in accordance with IA’s procedures on tribally controlled schools that
did not submit timely single audit reports.
41Each cognizant office has a director who is responsible for ensuring that their respective
AOs issue timely management decisions on single audit findings and addressing
significant problems or material weaknesses that jeopardize federal resources. For BIE,
the Grants Management Division under School Operations is designated for oversight of
single audits relevant to tribally controlled schools. In addition, BIA has 12 regional offices,
each headed by a regional director who is responsible for all BIA activities within a defined
geographical area. These regional directors report to the BIA Deputy Director and assist
with single audit responsibilities and oversight for their regions.
Page 15 GAO-25-106741 Single Audits of Tribal Entities
that Interior’s procedures for tracking single audit report submissions
were appropriately designed and implemented.
Table 2: Status of Single Audit Report (SAR) Submissions from Tribal Entities Awarded COVID-19 Relief Funds by the
Department of the Interior, Fiscal Years 2020 through 2022, as of October 31, 2023
2020 2021 2022
Tribal recipients with SAR submissions 486 424 248
Tribal recipients that did not submit a SAR 68 100 152
Certified that SAR submission was not required 21 8 3
Identified as late in submitting SAR or certification 30 82 129
Reported under a tribal consortiuma 17 10 20
Tribal recipients’ SAR submission status not trackedb 4 2 4
Total number of tribal recipientsᶜ 558 526 404
Legend: DIEA = Division of Internal Evaluation and Assessment
Source: GAO analysis of Interior documents. I GAO-25-106741
Tribes that report under a consortium are not required to submit a separate SAR.
a
b
DIEA was not notified by the awarding officials to track recipients. The number of tribal recipients not
tracked by DIEA represents less than 1 percent of the total number of tribal recipients.
ᶜTribal recipients included in this table consist of federally recognized Tribes, tribally controlled
schools, and tribal organizations to which Interior awarded COVID-19 relief funds.
Treasury Tracks Single Treasury has procedures to identify the single audit reports that
Audit Report Submissions nonfederal entities, including tribal entities, submitted. As noted above,
Treasury’s OCA is responsible for monitoring the submission of single
but Does Not Identify and
audit reports to the FAC. To do so, OCA accesses the FAC website to
Follow Up on Late or obtain single audit reporting and finding data and transfers the data to its
Missing Reports electronic single audit dashboard. 42 The dashboard is a monitoring tool
that contains program and recipient data from the Treasury Recovery
Awards Management System and single audit data obtained from the
FAC, including the number of single audit reports submitted. Treasury
relies on the dashboard to track the submission of single audit reports
and identify reports for review.
However, Treasury has not established a process for identifying all tribal
recipients that are required to submit a single audit report. Without this
42Prior to the transition of the FAC from the U.S. Census Bureau to the General Services
Administration, Treasury updated its single audit dashboard with data from the FAC
monthly. According to Treasury officials, Treasury has updated its single audit dashboard
every couple of months after the transition and was able to return to monthly updates in
August 2024.
Page 16 GAO-25-106741 Single Audits of Tribal Entities
information, Treasury has not been able to identify and follow up with all
tribal entities that have late or missing single audit reports.
Our analysis of federal award data found Treasury did not track the status
of single audit report submissions for a significant number of tribal
recipients because it does not have a process to identify whether tribal
recipients are required to submit a report. As shown in table 3, for fiscal
years 2020 through 2022, the percentage of tribal recipients for which
Treasury did not track whether single audit report submission is required
ranged from 30 percent to over 45 percent. Because Treasury does not
identify tribal recipients that are not required to submit single audit
reports, Treasury does not know whether the recipients are late in
submitting those reports or not required to do so.
Table 3: Status of Single Audit Report (SAR) Submissions from Tribal Entities Awarded COVID-19 Relief Funds by the
Department of the Treasury, Fiscal Years 2020 through 2022, as of October 31, 2023
2020 2021 2022
Tribal recipients with SAR submissions 400 470 248
Tribal recipients’ SAR submission status not trackedᵃ 174 393 164
Percentage of tribal recipients for which SAR submission status not tracked 30.3% 45.5% 39.8%
Total number of tribal recipientsb 574 863 412
Source: GAO analysis of Treasury documents. I GAO-25-106741
SAR submission may be late or not required.
a
b
Tribal recipients included in this table consist of eligible tribal governments and tribally designated
housing entities to which Treasury awarded COVID-19 relief funds. In 2021, Treasury began making
awards from the Coronavirus Relief Fund Tribal Government Set-Aside to corporations established
pursuant to the Alaska Native Claims Settlement Act because the U.S. Supreme Court ruled that they
were eligible tribal governments. See Yellen v. Confederated Tribes of the Chehalis Reservation, 594
U.S. 338 (June 25, 2021).
According to Treasury officials, Treasury did not have existing single audit
processes when its COVID-19 relief programs were established, and the
agency is still developing procedures to fully carry out its single audit
responsibilities as a federal awarding agency. Also, Treasury officials
stated that maintenance of the FAC transitioned from the U.S. Census
Bureau to the General Services Administration in October 2023, creating
technological challenges and further delaying Treasury’s efforts toward
designing effective processes.
Treasury officials noted that the agency first attempted to use its
recipient-reported expenditure data from its Treasury Recovery Awards
Management System to identify tribal recipients that reported spending
Page 17 GAO-25-106741 Single Audits of Tribal Entities
$750,000 or more in COVID-19 relief funds from Treasury programs but
had not submitted a single audit report. However, when comparing
recipient-reported data to single audit data from the FAC, Treasury noted
that limitations with the data prevented it from effectively identifying late or
missing single audit reports using an automated process. For example, if
a recipient submitted a single audit report to the FAC with a different
identification number than the number associated with its Treasury award,
Treasury’s automated processes could not match the single audit report
with the recipient.
Treasury officials stated that the agency has taken additional steps to
identify tribal recipients that were required to submit, but did not submit or
may be late in submitting, a single audit report:
• Manual reviews. Treasury has conducted limited manual reviews of
recipient-reported expenditures and FAC data to identify Tribes that
had failed to submit single audit reports. For example, according to
Treasury officials, in January and February 2024, the agency
conducted a review of 292 tribal entities awarded funds through one
of the COVID-19 relief programs it administers. Based on this review,
Treasury identified 41 Tribes that were required to submit a single
audit report but had not done so yet. Treasury sent notices of
noncompliance to those Tribes. 43 As of July 11, 2024, 8 of those
Tribes have come into compliance by submitting a single audit report.
Treasury officials stated that replicating this review for all recipients
would be burdensome given the number of federal award recipients.
• COVID-19 required reporting. In early 2024, Treasury added
questions to required reporting for certain Treasury-administered
COVID-19 relief programs, inquiring whether tribal recipients had met
the single audit expenditure threshold and submitted a single audit
report to the FAC. Treasury is currently assessing how to use
information obtained from the questions to identify tribal recipients that
are required to submit a single audit report.
• Coordination with Interior. Treasury is planning on entering into a
memorandum of understanding with Interior’s Office of the Assistant
Secretary for Indian Affairs to cooperate and coordinate on the review
of tribal government single audit reports. According to the draft
43Treasury’s Award Management Policy for Financial Assistance Recovery Programs
provides procedures for issuing notices of noncompliance to inform recipients of their
areas of noncompliance and provide a deadline for compliance. If a recipient does not
clear its noncompliance by the prescribed date, OCA may impose penalties for
noncompliance, such as requiring the tribal entity to return awarded funds to Treasury.
Page 18 GAO-25-106741 Single Audits of Tribal Entities
memorandum, OCA and Indian Affairs plan to share information
regarding, among other things, (1) certifications from tribal entities that
they did not spend $750,000 or more in total federal awards and
therefore do not meet the effective annual expenditure threshold
requirement for completing a single audit and (2) responses from
tribal entities regarding late submissions of their single audit reports.
OMB’s single audit guidance states that for the federal awards it makes,
the federal awarding agency must ensure that audits are completed and
reports are received in a timely manner. 44 In addition, Standards for
Internal Control in the Federal Government states that management
should design control activities to achieve objectives and respond to
risks—such as ensuring the timely submission of single audit reports and
providing oversight for federal funds awarded to tribal entities—and
implement such activities through policies. 45
Without effective policies and procedures for identifying tribal recipients
with late or missing single audit reports, Treasury cannot reasonably
ensure that its federal award recipients have adequate internal controls in
place and are complying with program requirements. In addition, tribal
entities with late or missing single audit reports will not be complying with
OMB’s single audit guidance on report submission; therefore, they may
miss opportunities to identify and correct weaknesses in their internal
controls in a timely manner.
Interior and Treasury have policies and procedures for reviewing and
Interior and Treasury following up on single audit findings, including issuing management
Have Procedures for decisions on tribal entities’ corrective action plans to address audit
findings related to the use of COVID-19 relief funds. Interior appropriately
Reviewing and implemented its procedures for issuing management decisions within the
Following Up on required 6-month period consistent with OMB’s single audit guidance. 46
However, Treasury does not issue management decisions within the 6-
Single Audit Findings, month period. Interior designed and implemented procedures for
but Do Not Include establishing most key baselines and targets for tracking single audit
findings, but it has not designed procedures for monitoring tribal entities’
Key Monitoring repeat single audit findings and tribal entities’ implementation of
Activities corrective action plans. Treasury has not implemented certain procedures
for following up on single audit findings, including monitoring single audit
442 C.F.R. § 200.513(c).
45GAO-14-704G.
462 C.F.R. § 200.521(d).
Page 19 GAO-25-106741 Single Audits of Tribal Entities
metrics against targets and baselines and ensuring proper oversight of
the metrics by sharing them with Treasury management. Treasury also
has not designed and implemented procedures to monitor tribal entities’
implementation of corrective action plans.
Interior Appropriately Interior appropriately designed and implemented procedures for reviewing
Designed and tribal entities’ single audit findings and respective corrective action plans,
as well as issuing timely management decision letters to tribal entities.
Implemented Procedures
Specifically, DIEA staff obtain single audit reports, perform an initial
to Review Single Audit review of the reports, and record report information, including the FAC
Reports and Issue Timely completion date, in the agency’s ARTT. 47 Based on its review, DIEA staff
Management Decisions then draft a memorandum noting any audit findings and questioned costs
associated with the reports, among other things. For single audit reports
containing audit findings and questioned costs, DIEA staff send the
memorandum to the responsible AO, requesting a management decision
within 120 days of the FAC completion date, per IA’s guidance. 48 OMB’s
single audit guidance states that federal awarding agency must issue
management decisions within 6 months (approximately 180 days) of the
FAC completion date. 49 According to Interior officials, DIEA can grant an
additional 30-day extension to ensure that Interior meets the OMB
requirement to issue management decisions within 6 months.
The AO reviews the DIEA memorandum, the single audit report, and the
tribal entity’s corrective action plan, if included, to determine if the
corrective action plan sufficiently addresses the single audit findings. If
the corrective action plan is not sufficient, the AO requests additional
information from the tribal recipient before making a final determination.
AOs are required to provide technical assistance to tribal entities upon
request. After assessing whether the actions taken or proposed by the
tribal entity will correct the audit findings, the AO issues a management
decision letter to the tribal entity documenting the official’s determination
in writing. The AO also notifies the regional director and DIEA director of
the AO’s management decisions. Figure 3 illustrates Interior’s process for
47The FAC completion date is the date that the single audit is made available to the
federal awarding agency through the FAC website, which occurs after the FAC conducts
its own review and accepts the single audit.
48Department of the Interior, Indian Affairs, Single Audit Report Handbook. IA’s 120-day
requirement for the issuance of management decisions is aligned with Interior’s
department-wide guidance for audit follow-up, Financial Management Handbook, ch. 5,
“Audit Follow-Up Guidance and Department Goals for Implementation of Audit
Recommendations.”
492 C.F.R. § 200.521(d).
Page 20 GAO-25-106741 Single Audits of Tribal Entities
reviewing tribal entities’ single audit reports and issuing management
decisions.
Figure 3: The Department of the Interior’s Process for Reviewing Tribal Entities’ Single Audit Reports and Issuing
Management Decision Letters
DIEA staff verify whether the management decision letter (1) was issued
within the required time frame, (2) addresses all audit findings and
questioned costs, (3) includes a determination on the adequacy of the
recipient’s proposed actions to address audit findings, and (4) was signed
by the AO. DIEA staff then update ARTT with the management decision
date and indicate whether the corrective action plans are adequate to
address single audit findings and, if applicable, whether questioned costs
were sustained (disallowed) or reinstated (allowed).
Based on our review of 28 management decision letters that Interior
issued to tribal entities related to audit findings reported for fiscal years
2020, 2021, and 2022, we found that Interior generally issued the letters
Page 21 GAO-25-106741 Single Audits of Tribal Entities
in a timely manner. 50 For example, Interior issued 26 of the 28
management decision letters within the required 6-month period. For the
two letters not issued within 6 months, Interior officials explained that the
BIA regions responsible for issuing the management decisions did not
have AOs at that time. According to Interior officials, the agency has since
hired new AOs in those regions and issued the management decisions
letters late.
Interior Tracks Single Audit Interior developed metrics, including baselines and targets, to track the
Findings but Does Not effectiveness of its process for following up on single audit findings.
Consistent with OMB’s single audit guidance, 51 Interior implemented
Monitor Tribal Entities’
procedures requiring DIEA to generate several status reports from
Implementation of information in ARTT and to send these reports to regional directors, AOs,
Corrective Actions and IA cognizant offices monthly. These reports track (1) overdue
management decisions, (2) management decisions coming due, and (3)
single audit findings for which management decisions have been issued
and disallowed costs need to be collected. Additionally, DIEA prepares
and sends quarterly reports to IA leadership, Interior’s Office of Financial
Management, and Interior’s National Single Audit Coordinator,
summarizing the data in the monthly status reports along with other
relevant information. 52
As part of audit follow-up, OMB’s single audit guidance states that the
federal awarding agency must monitor the recipient taking appropriate
and timely corrective action. 53 However, we found that Interior is not
systematically tracking single audit findings that are repeated from year to
year, nor is it tracking the implementation of tribal entities’ corrective
action plans proposed in their single audit reports. According to Interior
officials, DIEA notes that the single audit review is complete in ARTT after
the management decision is issued and AOs have determined that the
corrective action plans are sufficient to address the audit findings, even if
plans have not been implemented. When there are repeat audit findings,
DIEA staff note the repeat findings in the memorandum that is sent to the
AOs. However, Interior does not have a procedure that requires AOs to
review prior-year audit findings and determine whether prior-year
50See app. II for information on how we selected the 28 management decision letters.
512 C.F.R. § 200.513(c)(3)(iv).
52Department of the Interior, Indian Affairs, Single Audit Report Handbook, ch. 6.
532 C.F.R. § 200.513(c)(3)(ii).
Page 22 GAO-25-106741 Single Audits of Tribal Entities
corrective action plans were implemented or why they were insufficient to
prevent repeat findings.
Of the 28 fiscal year 2020 through fiscal year 2022 single audit reports
that we reviewed, we found that 12 contained audit findings that were
repeated from the previous year, indicating ongoing problems with those
tribal entities’ internal controls. Repeat findings could occur because a
corrective action was not taken, was not completed, or was ineffective.
Repeat findings can be used to measure the efficiency and effectiveness
of an agency’s single audit process. Specifically, if an AO’s management
decision finds that a proposed corrective action plan, if implemented, will
address the audit findings, then implementation of the plan should result
in a reduction in repeat findings.
Because Interior does not systematically track tribal entities’ repeat audit
findings or implementation of corrective action plans, the agency is
unable to measure the efficiency and effectiveness of its process for
following up on audit findings and improving its oversight of federal
awards. In addition, uncorrected material and significant audit exceptions
related to a self-determination contract or self-governance compact affect
a tribal entity’s eligibility for future self-governance compacts.
Treasury Reviews Single Treasury’s OCA has procedures for reviewing single audit reports and
Audit Reports but Does issuing management decisions for recipients of its COVID-19 relief funds,
including tribal recipients. Specifically, OCA staff retrieve a list of single
Not Issue Timely
audit findings from Treasury’s single audit dashboard and prioritize them
Management Decisions for review, considering factors such as available resources, OCA-wide
priorities, and risk assessment results. Based on this prioritization, OCA
staff review the single audit reports and the summary data forms auditors
and tribal entities submit with the reports. The staff then use a Single
Audit Review Form to document the findings, questioned costs, and their
determination as to whether the corrective action plans will address the
root causes of the audit findings. Using data from the Single Audit Review
Forms, OCA staff draft management decision letters, which contain
OCA’s determination regarding whether (1) the corrective action plans are
Page 23 GAO-25-106741 Single Audits of Tribal Entities
accepted and (2) any questioned costs are allowed or disallowed. 54
Management decision letters undergo various levels of review for data
accuracy and consistency, including by Treasury leadership and general
counsel. Figure 4 illustrates Treasury’s process for reviewing tribal
entities’ single audit reports and issuing management decisions.
Figure 4: Department of the Treasury’s Process for Reviewing Tribal Entities’ Single Audit Reports and Issuing Management
Decision Letters
Treasury’s policies and procedures require staff to review single audit
findings and issue management decisions within the 6-month time frame
54Treasury’s Office of Inspector General has a specific statutory authority to conduct
monitoring and oversight of the receipt, disbursement, and use of award funds for the
Coronavirus Relief Fund, 42 U.S.C. § 801(f), and Emergency Rental Assistance 1, 15
U.S.C. § 9058a(i). As part of its oversight function, and when the single audit report
includes findings related to these award funds, Treasury’s Office of Inspector General will
conduct an initial review of tribal recipients’ single audit reports and prepare a package for
OCA, which includes the results of its review, a preliminary management decision letter
response, and other supporting documents. The OCA analyst considers information in this
package when issuing a formal management decision letter.
Page 24 GAO-25-106741 Single Audits of Tribal Entities
required by OMB. 55 However, we found that Treasury has continued to
miss deadlines for issuing management decision letters. Of the sample of
30 management decision letters we reviewed related to findings reported
for fiscal years 2020, 2021, and 2022, we found that as of May 22, 2024,
none were issued in a timely manner: three management decisions were
issued after 6 months, and 27 had not been issued and were considered
late. 56 Overall, Treasury officials stated that as of September 30, 2024,
the agency has issued 35 of the 294 management decision letters it is
required to issue to tribal entities for fiscal years 2020 through 2022.
In a previous audit, we found that Treasury did not promptly issue its
management decisions. Specifically, we reported in December 2023 that
Treasury did not issue timely management decisions pertaining to State
and Local Fiscal Recovery Funds (SLFRF) findings in recipients’ single
audit reports, and as a result, it does not have reasonable assurance that
unallowable uses of funds are identified or remediated. 57 In that report,
we stated that Treasury officials indicated that the agency faced
challenges in implementing systematic reviews of single audit reports and
issuing management decisions because it did not have existing single
audit processes or staff to administer these processes when the COVID-
19 relief programs were established. Treasury officials further stated that
they were continuing to assess the backlog of single audit report reviews
and other anticipated workload in their development of a plan to continue
to resolve single audit findings.
In the December 2023 report, we recommended that the Secretary of the
Treasury should issue timely management decisions related to SLFRF
findings in accordance with OMB’s single audit guidance. Treasury
agreed with the recommendation and stated that reviewing and resolving
single audit findings is an important piece of effective federal award
administration and monitoring. Treasury officials stated that during 2024,
the department has prioritized review of single audits for the recipients
with the (1) highest award amounts and (2) questioned costs reported in
their single audits.
552 C.F.R. § 200.521(d).
56See app. II for information on how we selected the sample of 30 management decision
letters.
57GAO, COVID-19 Relief: Treasury Could Improve Its Administration and Oversight of
State and Local Fiscal Recovery Funds, GAO-24-106027 (Washington, D.C.: Dec. 14,
2023).
Page 25 GAO-25-106741 Single Audits of Tribal Entities
Treasury uses the same procedures for issuing management decision
letters related to SLFRF audit findings as those for issuing management
decision letters related to other COVID-19 relief funds findings. If
Treasury takes steps to issue management decisions letters related to
SLFRF audit findings, these actions should result in the timely issuance of
management decisions letters for other COVID-19 relief fund findings,
including tribal entities’ findings. As such, prompt implementation of our
December 2023 recommendation is critical. Until Treasury issues timely
management decisions, tribal recipients may be unclear about the
agency’s position on the single audit findings and whether the proposed
corrective actions will address the findings. Additionally, there is an
increased risk that potential audit findings related to unallowable uses of
program funds, including COVID-19 relief funds, may remain unidentified
and uncorrected for significant periods of time.
Treasury’s Procedures Treasury’s Single Audit Procedures requires the agency to collect data on
Require Monitoring of single audits for recipients of Treasury-administered funds and monitor its
progress against certain metrics. These metrics include the (1)
Single Audit Metrics, but
percentage of single audits with no audit findings, (2) percentage of single
Baselines, Targets, and audits with audit findings, (3) percentage of repeat single audit findings,
Oversight Could Be and (4) timely issuance of management decision letters. These
Improved procedures also require Treasury to evaluate its performance data
annually, revising and recalibrating measures as needed. 58
We found that although Treasury reports metrics in its single audit
dashboard, it does not use the metrics as described in its policies and
procedures to monitor its progress. Specifically, according to Treasury
officials, there are currently no baselines or targets associated with the
metrics, and there are no documented procedures to regularly share the
metrics with management, including OCA’s Chief Operating Officer.
Additionally, we found that Treasury’s procedures do not require the
agency to report metrics regarding tribal recipients’ implementation of
corrective action plans. According to Treasury officials, the agency has
prioritized addressing its backlog of management decision letters and
OCA staff meet regularly to track progress on and discuss single audit
reviews and issuance of the letters. Treasury officials stated that they will
review the baselines and targets for Treasury’s single audit process after
it has issued a greater proportion of management decisions letters.
58Department of the Treasury, Office of Recovery Programs, Single Audit Procedures, ch.
5.2.4.
Page 26 GAO-25-106741 Single Audits of Tribal Entities
OMB’s single audit guidance requires the monitoring of the recipient
taking appropriate and timely corrective action, the development of
baselines and targets to track the effectiveness of the process to follow
up on audit findings, and that an official be held accountable for improving
the effectiveness of the single audit process based on these metrics. 59
Also, Standards for Internal Control in the Federal Government states that
management should design control activities to achieve objectives and
respond to risks. Control activities include, for example, management
comparing actual performance to planned or expected results throughout
the organization and analyzing significant differences. 60
If Treasury does not use metrics to monitor whether tribal recipients are
implementing corrective action plans, it cannot reasonably ensure that the
recipients are taking appropriate and timely action to correct single audit
findings as required by OMB’s single audit guidance. 61 In addition, if
single audit findings are not corrected, tribal entities may miss
opportunities to improve their financial stability and management
capability. Also, without baselines and targets for single audit process
metrics and adequate oversight of these measures, as required by OMB’s
single audit guidance, 62 Treasury may not identify opportunities to
improve the effectiveness of its single audit process.
Interior and Treasury assist tribal recipients of COVID-19 relief funds in
Interior and Treasury navigating the single audit process. Both agencies reported using various
Reported Assisting methods to help tribal recipients comply with single audit requirements
and prevent future audit findings. The representatives from tribal-serving
Tribal Entities organizations and the tribal official who we interviewed provided their
throughout the Single perspectives on the agencies’ assistance, including opportunities for
these agencies to enhance the assistance they provide to tribal
Audit Process recipients.
592 C.F.R. § 200.513(c)(3)(ii), 2 C.F.R. § 200.513(c)(3)(iv), and 2 C.F.R. §
200.513(c)(5)(ii).
60GAO-14-704G.
612 C.F.R. § 200.513(c)(3)(ii).
622 C.F.R. § 200.513(c)(3)(iv) and 2 C.F.R. § 200.513(c)(5)(ii).
Page 27 GAO-25-106741 Single Audits of Tribal Entities
Interior and Treasury
Single Audit Assistance for
Tribal Entities
Interior’s Tribal Assistance Interior uses various methods to help tribal recipients comply with
requirements for single audits and COVID-19 relief funds. For example,
IA provided webinars on topics such as allowable uses of COVID-19 relief
funds and single audit requirements. In addition, Interior provided
information on its website to assist tribal entities with COVID-19 relief
funds management. 63 Specifically, Interior’s website provides information
about BIE virtual listening sessions, Coronavirus Relief Fund guidance for
tribal governments, the American Rescue Plan Act of 2021, and
upcoming tribal consultations. IA also issued notifications on its website to
tribal recipients regarding the use of COVID-19 relief funds.
AOs provide technical assistance upon request to tribal recipients during
the single audit review, in accordance with Interior’s Single Audit Report
Handbook. 64 According to Interior officials, some of this assistance
includes explaining single audit findings and related disallowed costs to
tribal recipients, helping recipients determine the source or root cause of
issues leading to audit findings, providing suggestions to address the root
causes, and helping recipients develop corrective action plans to address
single audit findings, as needed. AOs may also provide administrative or
other miscellaneous assistance upon request. Examples of such
assistance include copies of documentation, such as contracts and
financial status reports; reviews of payments provided through certain
Interior programs; and help creating property inventory lists.
According to Interior officials, DIEA only provides direct assistance to
tribal entities when requested by the AOs or education program
administrators. DIEA’s assistance is provided through meetings,
correspondence, and training.
Interior officials told us the agency also helps tribal recipients prevent
future audit findings. It does so by working directly with tribal entities to
resolve prior audit findings and provide technical assistance to avoid
future findings. For example, if a tribal entity is in reassumption, IA
63For information Interior provides to tribal entities on its website regarding COVID-19
relief funds, see https://www.bia.gov/covid-19/cares-act and
https://www.bia.gov/service/american-rescue-plan-act, accessed August 9, 2024.
64Department of the Interior, Indian Affairs, Single Audit Report Handbook.
Page 28 GAO-25-106741 Single Audits of Tribal Entities
provides targeted technical assistance, which involves recurring meetings
to identify progress and on-site visits with the recipient to ensure that any
relevant corrective action plans are being implemented. 65 IA also
continues to provide training and webinars to tribal recipients on financial
reporting and single audits to help prevent future audit findings.
Treasury’s Tribal Assistance Treasury helps tribal recipients comply with COVID-19 relief fund and
single audit requirements in a variety of ways. For example, OCA
provides single audit advice and counsel to Treasury’s recipients and
their auditors, in accordance with OCA’s Single Audit Procedures. 66
Treasury also publishes a variety of program-specific compliance
materials online for recipients, such as SLFRF user guides. 67 Additionally,
Treasury makes presentations at tribal events and conferences and
provides informational and training webinars for tribal recipients on topics
such as single audit compliance and accounting best practices. Treasury
also operates a call center to answer award recipients’ questions,
including tribal recipients, regarding COVID-19 relief programs.
Treasury’s OCA and Office of Tribal and Native Affairs (OTNA) are
responsible for providing a range of single audit support to tribal entities.
According to Treasury officials, OTNA offers guidance to tribal entities,
including information sessions, one-on-one discussions, and training for
compliance and support. For example, according to Treasury, OTNA
conducted 389 one-on-one discussions with tribal entities on specific
issues in 2023. In addition, OTNA facilitated on-site training for tribal
governments in Anchorage and Kotzebue to improve the likelihood that
tribal recipients in Alaska will submit required reporting for SLFRF and the
Coronavirus Relief Fund Tribal Government Set-Asides. According to
Treasury officials, in August 2024, OTNA is partnering with Interior and
the Alaska Federation of Natives to host a webinar for Alaska Native
Villages focused on undergoing a single audit for the first time. OTNA
also publishes a weekly newsletter containing high-level information on
65Reassumption means rescission, in whole or in part, of a self-determination contract or
self-governance compact and assuming or resuming control or operation of an included
program by the Secretary of the Interior without consent of the Indian Tribe or tribal
organization. 25 C.F.R. §§ 900.246, 1000.2.
66Department of the Treasury, Office of Capital Access, Single Audit Procedures.
67For compliance materials Treasury provides to tribal entities on its website regarding
COVID-19 relief funds, see https://home.treasury.gov/policy-
issues/coronavirus/assistance-for-state-local-and-tribal-governments/state-and-local-
fiscal-recovery-funds/recipient-compliance-and-reporting-responsibilities, accessed
August 9, 2024.
Page 29 GAO-25-106741 Single Audits of Tribal Entities
Treasury tribal matters, compliance and reporting requirements for
COVID-19 relief programs, and overviews of the single audit process,
among other things.
OTNA may engage with tribal entities, as needed, when issues arise from
more complex single audit findings. For example, according to Treasury
officials, OTNA identified the lack of access to reliable, high-speed
internet as the principal cause of prevalent single audit findings related to
late or missing annual and quarterly reports required under certain
COVID-19 relief programs. 68 They also told us that OTNA worked with
OCA to develop a method for tribal entities to submit paper reports as an
alternative to electronic reports to help reduce the prevalence of this audit
finding.
According to Treasury officials, the agency is also working to help tribal
entities prevent future audit findings. For example, Treasury partnered
with the Department of Health and Human Services, the Executive Office
of the President, and Interior to research and report on ways to improve
technology and address knowledge gaps with the goal of increasing tribal
recipients’ compliance with the terms and conditions of federal awards
and reducing burden for tribal recipients. The report was issued in June
2024 and identified key needs of Tribes. 69
Treasury officials also noted that guidance, training, and one-on-one
engagement with tribal recipients are intended to help tribal entities
prevent future audit findings. For example, Treasury officials noted that
the agency provided targeted one-on-one trainings to tribal governments
that did not perform required annual or quarterly program reporting or
submitted incorrect reports for COVID-19 relief programs.
Tribal Perspectives on We interviewed representatives from three tribal-serving organizations
Single Audit Assistance and a tribal official to obtain their perspectives on Treasury and Interior’s
single audit assistance. They discussed (1) Treasury’s and Interior’s
improved capacity for assistance since the beginning of the COVID-19
pandemic, (2) tribal entities’ unique needs and challenges encountered
68These reporting requirements are different from the single audit reporting requirements
and are specific to each COVID-19 relief program. However, auditors may cite submitting
these reports late or not at all as a federal award audit finding in the single audit report.
69See https://www.hhs.gov/sites/default/files/grants-qsmo-tribal-cx-report.pdf, accessed
August 9, 2024.
Page 30 GAO-25-106741 Single Audits of Tribal Entities
throughout the single audit process, and (3) suggestions for Treasury and
Interior to further enhance assistance.
Improved capacity for assistance. According to the representatives
from the tribal-serving organizations and the tribal official we interviewed,
Interior and Treasury have improved their capacity to provide technical
assistance to tribal recipients since the beginning of the COVID-19
pandemic. For example, both Interior and Treasury provided resources
related to federal funding and overall federal guidance. One tribal-serving
organization noted that Interior publicly posted its Single Audit Report
Handbook, 70 which outlines its single audit review process and
noncompliance remedies, in October 2021. In addition, in March 2024, we
reported that most tribal schools funded by BIE reported that they
received guidance on COVID-19 relief spending that was timely, useful,
and clear. 71
One tribal-serving organization noted that one-on-one engagement with
agency officials was helpful because tribal entities receive more clear and
concise guidance when they have direct, long-term connections with
federal agencies. A tribal official noted that Interior’s OSG has provided
one-on-one assistance to help the Tribe with writing corrective action
plans. The official also stated that Treasury has provided helpful guidance
through FAQs, webinars, and a presentation at a conference for tribal
finance staff. Also, all representatives from tribal-serving organizations
and the tribal official we interviewed noted that when Treasury
established OTNA in September 2022, Treasury’s guidance and
assistance to tribal entities were enhanced.
Tribal entities’ unique needs and challenges. While Interior and
Treasury assist tribal entities throughout the single audit process,
representatives from the tribal-serving organizations and the tribal official
who we interviewed noted that the assistance provided may not fully
consider the unique needs and challenges of tribal recipients. According
to one of the tribal-serving organizations, for example, it is often difficult
for tribal entities to know what general guidance applies to their specific
situation when preparing for single audits or developing corrective actions
to address audit findings. This tribal-serving organization indicated that
the webinars and online information provided by federal agencies tend to
70Department of the Interior, Indian Affairs, Single Audit Report Handbook.
71GAO, Bureau of Indian Education: Improved Oversight of Schools’ COVID-19 Spending
is Needed, GAO-24-105451 (Washington, D.C.: Mar. 27, 2024).
Page 31 GAO-25-106741 Single Audits of Tribal Entities
be high level, outlining information such as auditee and auditor
responsibilities.
Tribal governments also differ in size and resources. While smaller Tribes
may have one to two staff members, who may lack the specialized
knowledge needed to meet single audit requirements, other Tribes may
have large accounting departments. For example, one tribal-serving
organization stated that a Tribe did not have a certified public accountant
in its accounting division or staff with knowledge of the single audit
process. In such cases, tribal entities told us, tribal staff may not know
where to look for single audit information and may find it difficult to keep
up with changes in guidance on allowable uses of award funds and single
audit reporting requirements.
In December 2022, we reported that tribal recipients had to spend more
time and effort determining which requirements applied for audit
compliance, as agencies repeatedly modified guidance or provided
additional information about COVID-19 relief funding requirements. In that
report, one tribal recipient specifically noted challenges caused by
Treasury releasing many iterations of its Coronavirus Relief Fund
guidance on the use of funds. 72
One tribal-serving organization noted that many Tribes and tribal
organizations, particularly those on reservations or in remote areas, have
unreliable access to the internet and may have trouble contacting federal
agencies for assistance or meeting single audit reporting requirements. In
October 2021, we reported that Tribes noted that internet connectivity
issues affected their ability to meet a COVID-19 relief funding program
compliance reporting deadlines. 73
Tribal-serving organizations’ suggestions for improvement.
Generally, the representatives of tribal-serving organizations we
interviewed noted that Interior and Treasury continued to improve their
assistance to tribal recipients since the beginning of the COVID-19
pandemic. These tribal-serving organizations also provided suggestions
for improvement. For example, one organization suggested that the
72GAO, COVID-19 Relief Funds: Lessons Learned Could Improve Future Distribution of
Federal Emergency Relief to Tribal Recipients, GAO-23-105473 (Washington, D.C.: Dec.
15, 2022).
73GAO, COVID-19: Lessons Learned from Interior and Treasury’s Administration of
CARES Act Funds Could Improve Federal Emergency Relief to Tribes, GAO-22-104349
(Washington, D.C.: Oct. 29, 2021).
Page 32 GAO-25-106741 Single Audits of Tribal Entities
agencies provide (1) clear, realistic examples of what tribal entities should
do during each step of the single audit process, including how the
process may differ based on variables such as Tribe size and income
level, and (2) general information, in the form of FAQs, to help nonexperts
more easily begin the process of learning about single audits.
Another tribal-serving organization suggested that regional technical
assistance offices be established, and that each Tribe be assigned to
one. This organization also noted that it would have been helpful for
federal agencies to provide tribal entities with consistent guidance and
information on the types of projects that Tribes could do upon receipt of
the federal award.
Through the COVID-19 relief laws, the federal government provided
Conclusions billions of dollars in critical assistance to tribal entities to help them
respond to the pandemic. In many cases, smaller tribal entities received
substantial amounts of funding and became subject to single audit
reporting requirements for the first time. Federal awarding agencies, such
as Interior and Treasury, must do their part to ensure accountability for
these funds, including reviewing single audits, issuing management
decisions, and monitoring recipients’ corrective actions.
Both Interior and Treasury have processes for obtaining the relevant
single audit reports. Interior has a process for identifying and following up
with tribal entities that did not submit a report. However, Treasury is in the
process of assessing procedures for identifying and following up with
tribal entities that have late or missing single audit reports but has not yet
formalized and incorporated such procedures. By developing and
implementing policies and procedures to identify and follow up with tribal
recipients that did not submit required single audit reports when due,
Treasury could better assure that it is meeting its oversight
responsibilities.
Interior and Treasury review single audit findings and issue management
decisions on the adequacy of tribal entities’ corrective action plans to
address findings related to the use of COVID-19 relief funds, but Treasury
failed to issue timely management decisions. As such, prompt
implementation of our December 2023 recommendation is critical to
ensure that any potential findings are corrected timely. In addition, both
Interior and Treasury could improve their procedures for tracking the
effectiveness of their single audit processes by monitoring the
implementation of tribal entities’ corrective action plans. Designing and
implementing procedures are key to Interior and Treasury ensuring that
Page 33 GAO-25-106741 Single Audits of Tribal Entities
tribal entities identify and correct weaknesses in their internal controls in a
timely manner. Strong internal controls can help tribal entities ensure that
they spend federal award funds on allowable uses, maintain accurate and
reliable financial data, and comply with applicable laws or regulations. In
turn, by correcting single audit deficiencies, Tribes may improve their
financial stability and financial management capability. Further, these
corrections would help Tribes become eligible for self-governance
compacts that provide the greatest autonomy over the design and
administration of federal programs.
We are making a total of three recommendations, including two to
Recommendations for Treasury and one to Interior. Specifically:
Executive Action
The Secretary of the Treasury should develop and implement procedures
to identify tribal recipients that did not submit required single audit reports
when due and follow up with those recipients. (Recommendation 1)
The Secretary of the Interior should develop and implement procedures
for tracking the implementation of corrective action plans, including
tracking repeat single audit findings, to ensure that tribal recipients take
appropriate and timely action to correct single audit findings.
(Recommendation 2)
The Secretary of the Treasury should develop and implement procedures
to use metrics to improve the effectiveness of Treasury’s process for
following up on audit findings, including developing baselines and targets,
tracking the implementation of corrective action plans, and sharing the
metrics with OCA’s Chief Operating Officer. (Recommendation 3)
We provided a draft of this report to Interior and Treasury for review and
Agency Comments comment. We received written comments from Interior and Treasury that
and Our Evaluation are reproduced in appendixes III and IV, respectively, and summarized
below. Interior and Treasury also provided technical comments, which we
incorporated as appropriate.
In their comments, Interior and Treasury agreed with our
recommendations. With regard to recommendation 1, Treasury stated
that it will implement a process to identify Tribal recipients that failed to
submit required single audits using interagency information sharing and
recipient-reported data. Treasury noted that it plans to enter into a
memorandum of understanding with Interior’s Indian Affairs to share
single audit information, including tribal governments’ certifications as to
whether they or their tribal entities are required to conduct a single audit.
Page 34 GAO-25-106741 Single Audits of Tribal Entities
Treasury said that it will use its existing processes to follow up with
recipients identified through this process. The actions that Treasury
described, if implemented effectively, would address this
recommendation.
With regard to recommendation 2, Interior noted that it will update its
policies and procedures to include requirements that staff monitor the
status of tribal entities’ single audit corrective action plans, including their
implementation, and close out single audit findings when corrective action
plans are implemented. Interior also noted that, as part of its updated
policies and procedures, it will develop a new process of tracking and
monitoring repeat single audit findings. The actions that Interior
described, if developed and implemented effectively, would address this
recommendation.
With regard to recommendation 3, Treasury noted that it will implement
monthly status reports for management, including OCA’s Chief Operating
Officer, that will track (1) overdue management decisions, (2)
management decisions coming due, (3) status of management decisions
issued, and (4) status of disallowed costs or prior period reporting
adjustments. The actions that Treasury described, if implemented
effectively, would not fully address this recommendation. To do so,
Treasury will also need to develop baselines and targets and track the
implementation of corrective action plans.
We are sending copies of this report to the appropriate congressional
committees, the Secretary of the Treasury, the Secretary of the Interior,
and other interested parties. In addition, the report is available at no
charge on the GAO website at https://www.gao.gov.
Page 35 GAO-25-106741 Single Audits of Tribal Entities
If you or your staffs have any questions about this report, please contact
me at (202) 512-7795 or sitwilliamsa@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to this
report are listed in appendix V.
Anne Sit-Williams
Director
Financial Management and Assurance
Page 36 GAO-25-106741 Single Audits of Tribal Entities
List of Committees
The Honorable Patty Murray
Chair
The Honorable Susan Collins
Vice Chair
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Bernard Sanders
Chair
The Honorable Bill Cassidy, M.D.
Ranking Member
Committee on Health, Education, Labor and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rand Paul, M.D.
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Tom Cole
Chairman
The Honorable Rosa L. DeLauro
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Cathy McMorris Rodgers
Chair
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
House of Representatives
Page 37 GAO-25-106741 Single Audits of Tribal Entities
The Honorable Mark E. Green, M.D.
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable James Comer
Chairman
The Honorable Jamie Raskin
Ranking Member
Committee on Oversight and Accountability
House of Representatives
The Honorable Jason Smith
Chairman
The Honorable Richard Neal
Ranking Member
Committee on Ways and Means
House of Representatives
Page 38 GAO-25-106741 Single Audits of Tribal Entities
Appendix I: COVID-19 Relief Funding Appendix I: COVID-19 Relief Funding
Administered by Interior and Treasury
Administered by Interior and Treasury
Since March 2020, COVID-19 relief laws have appropriated at least $43.6
billion for federal programs serving Tribes, tribal citizens, and tribal
organizations. 1 These laws provided assistance to Tribes and other tribal
entities, as well as tribal citizens, by creating several new COVID-19 relief
programs, making appropriations for those new programs, and providing
appropriations for existing programs. For example, the Department of the
Interior and the Department of the Treasury awarded $32.7 billion in
COVID-19 relief funding to tribal entities through existing programs, such
as Interior’s Aid to Tribal Governments, and new programs, such as
Treasury’s Coronavirus State Fiscal Recovery Fund Tribal Government
Set-Aside. Table 4 contains detailed information on the COVID-19 relief
funding that these departments administered. This table does not include
appropriations that were made to other federal agencies and
subsequently transferred to Interior and Treasury.
Table 4: COVID-19 Relief Funding for Eligible Tribal Entities Administered by the Departments of the Interior and the Treasury
Department Agency/ office Appropriation Legal authority Eligible recipients Amount (in
dollars)ᵃ
Interior Bureau of Indian Bureau of Indian Affairs American Rescue Plan Tribes, tribal $900 million
Affairs (BIA) Act (ARPA), § 11002 organizations, and BIA
Operation of Indian CARES Act, div. B, tit. Tribes, tribal $453 million
Programs VII organizations, and BIA
Bureau of Indian Bureau of Indian ARPA, § 11005 Tribes, tribal $850 million
Education (BIE) Education organizations, tribal
colleges and
universities, and BIE
Operation of Indian CARES Act, div. B, tit. Tribes, tribal $69 million
Education Programs VII organizations, tribal
colleges and
universities, and BIE
1For the purposes of this engagement, the COVID-19 relief laws consist of the six laws
providing comprehensive relief across federal agencies and programs that the Department
of the Treasury uses to record and track COVID-19 relief spending in accordance with
Office of Management and Budget guidance. These six laws include the American Rescue
Plan Act of 2021, Pub. L. No. 117-2, 135 Stat. 4 (Mar. 11, 2021); Consolidated
Appropriations Act, 2021, Pub. L. No. 116-260, div. M and N, 134 Stat. 1182 (Dec. 27,
2020); Paycheck Protection Program and Health Care Enhancement Act, Pub. L. No. 116-
139, 134 Stat. 620 (Apr. 24, 2020); CARES Act, Pub. L. No. 116-136, 134 Stat. 281 (Mar.
27, 2020); Families First Coronavirus Response Act, Pub. L. No. 116-127, 134 Stat. 178
(Mar. 18, 2020); and Coronavirus Preparedness and Response Supplemental
Appropriations Act, 2020, Pub. L. No. 116-123, 134 Stat. 146 (Mar. 6, 2020).
Page 39 GAO-25-106741 Single Audits of Tribal Entities
Appendix I: COVID-19 Relief Funding
Administered by Interior and Treasury
Department Agency/ office Appropriation Legal authority Eligible recipients Amount (in
dollars)ᵃ
Treasury Office of Capital Coronavirus State ARPA, § 9901 Tribal governmentsᵇ $20 billion
Access Fiscal Recovery Fund
Tribal Government Set-
Aside
Coronavirus Relief Fund CARES Act, § 5001 Tribal governmentsᶜ $8 billion
Tribal Government Set-
Aside
Emergency Rental Consolidated Tribes, eligible tribally $800 million
Assistance 1 Tribal Appropriations Act, designated housing
Community Set-Aside 2021, div. N, § 501 entities, and the
Department of
Hawaiian Homelands
State Small Business ARPA, § 3301 Tribal governmentsᵉ $500 million
Credit Initiative Tribal
Government Allocationd
Homeowner Assistance ARPA, § 3206 Tribes, eligible tribally $498 million
Fund Tribal Set-Aside designated housing
entities, and the
Department of
Hawaiian Homelands
Local Assistance and ARPA, § 9901 Tribal governmentsf $500 million
Tribal Consistency Fund
Tribal Government Set-
Aside
Coronavirus Capital ARPA, § 9901 Tribal governmentsg $100 million
Projects Fund for Tribal and the State of Hawaii
Governments
Source: GAO analysis of the six COVID-19 relief laws. I GAO-25-106741
ᵃThe amount does not reflect the permanent rescissions enacted in the Fiscal Responsibility Act of
2023, Pub. L. No. 118-5, 137 Stat. 10 (June 3, 2023). Effective as of the act’s date of enactment, Title
I of Division B of that act permanently rescinded the unobligated balances of certain COVID-19 relief
funding.
ᵇThe statute creating this program defines tribal government as federally recognized Indian tribes.
ARPA, Pub. L. No. 117-2, tit. IX, § 9901, 135 Stat. 4, 228 (Mar. 11, 2021) (codified at 42 U.S.C. §
802(g)(7)).
ᶜThe applicable statute creating this program defines tribal government as federally recognized Indian
tribes and corporations established pursuant to the Alaska Native Claims Settlement Act. CARES Act,
Pub. L. No. 116-136, div. A, tit. V, § 5001, 134 Stat. 281, 504 (Mar. 27, 2020) (codified at 42 U.S.C. §
801(g)(1), (5)).
ᵈIn addition to this tribal allocation, tribal governments are eligible for the State Small Business Credit
Initiative technical assistance grants and additional allocations, such as those for socially and
economically disadvantaged-owned business. ARPA, Pub. L. No. 117-2, tit. III, §§ 3303(a)(1)(A), (b),
(d), 135 Stat. 4, 67-71 (Mar. 11, 2021) (codified at 12 U.S.C. §§ 5702, 5708).
ᵉThe statute creating this program defines tribal government as federally recognized Indian tribes.
ARPA, Pub. L. No. 117-2, tit. III, § 3301(f), 135 Stat. 4, 72 (Mar. 11, 2021) (codified at 12 U.S.C. §
5701(19)).
f
The statute authorizing this program defines tribal government as federally recognized Indian tribes.
ARPA, Pub. L. No. 117-2, tit. IX, § 9901, 135 Stat. 4, 236 (Mar. 11, 2021) (codified at 42 U.S.C. §
805(f)(3)).
Page 40 GAO-25-106741 Single Audits of Tribal Entities
Appendix I: COVID-19 Relief Funding
Administered by Interior and Treasury
g
This program uses the same definition of tribal government as the Coronavirus State Fiscal
Recovery Fund Tribal Government Set-Aside. ARPA, Pub. L. No. No. 117-2, tit. IX, § 9901, 135 Stat.
4, 234 (Mar. 11, 2021) (codified at 42 U.S.C. § 804(d)(3)).
Page 41 GAO-25-106741 Single Audits of Tribal Entities
Appendix II: Objectives, Scope, and
Appendix II: Objectives, Scope, and
Methodology
Methodology
This report examines the extent to which the Department of the Interior
and the Department of the Treasury appropriately designed and
implemented policies and procedures to help ensure they (1) track the
timely submission of required single audit reports from tribal entities to
which they awarded COVID-19 relief funds and (2) review and follow up
on the findings of these audits, including issuing written management
decisions on tribal entities’ plans to correct findings in a timely manner.
This report also describes the assistance Interior and Treasury provided
to tribal entities to help them navigate the single audit process, address
single audit findings, and prevent future audit deficiencies.
For our first and second objectives, we obtained and reviewed Interior’s
and Treasury’s single audit policies and procedures, including procedures
for tracking, reviewing, and following up on single audit report
submissions. We interviewed Interior and Treasury officials to discuss
their single audit processes. We also assessed Interior’s and Treasury’s
policies and procedures against the Single Audit Act, 1 Office of
Management and Budget’s (OMB) single audit guidance, 2 and federal
internal control standards 3 related to the control activities component to
determine the extent to which the agencies conducted appropriate
oversight using single audit reports.
To address our first objective, we obtained Interior and Treasury’s list of
tribal entities to which they awarded COVID-19 relief funds during fiscal
years 2020, 2021, and 2022. We also obtained a list of single audit
reports that Interior and Treasury received from tribal entities for the same
fiscal years (the most recent period for which single audits reports were
submitted) and compared the two lists. For those tribal entities that
Interior and Treasury awarded COVID-19 relief funds but had not
submitted single audit reports, we reviewed each agency’s data and
inquired with agency officials to determine whether Interior and Treasury
had implemented a process to track whether a tribal recipient was
required to submit a single audit report and had not done so. We also
obtained and reviewed single audit report data from the Federal Audit
Clearinghouse to determine whether Interior and Treasury were
accurately tracking single audit report submissions from tribal entities.
1The Single Audit Act is codified, as amended, at 31 U.S.C. §§ 7501-7506.
2OMB’s implementing single audit guidance is reprinted in 2 C.F.R. part 200, subpart F.
3GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: Sept. 2014).
Page 42 GAO-25-106741 Single Audits of Tribal Entities
Appendix II: Objectives, Scope, and
Methodology
To address our second objective, we selected and reviewed single audit
reports to determine whether Interior and Treasury implemented their
procedures and issued timely management decisions. We selected single
audit reports that (1) were submitted by tribal entities that received their
predominant amount of funding from Interior or Treasury; (2) contained
audit findings related to Interior’s or Treasury’s COVID-19 relief programs;
and (3) were submitted for fiscal years 2020, 2021, and 2022. For Interior,
we reviewed all 28 single audit reports that met the criteria. For Treasury,
we randomly selected a nongeneralizable sample of 30 single audit
reports from the 177 reports that met the criteria. Because we used a
nongeneralizable sample to select the single audit reports, our findings
cannot be used to make inferences about the entire population of reports.
We also obtained and reviewed from Interior and Treasury internal
reports that these agencies used to track and monitor (1) single audit
reports, (2) the timeliness the issuance of management decisions, and (3)
the effectiveness of the agencies’ processes for following up on audit
findings.
To address our third objective, we met with Interior and Treasury officials
to discuss the assistance these agencies provided to tribal entities related
to complying with single audit requirements. We also interviewed
representatives from three tribal-serving organizations to obtain their
perspectives on the support Interior and Treasury provide to tribal entities
for addressing and preventing single audit findings. Specifically, we spoke
with representatives from NAFOA (formerly known as the Native
American Finance Officers’ Association), the Native Nations Institute, and
Self-Governance Communication and Education Tribal Consortium. We
identified and selected tribal-serving organizations that (1) operate
nationally; (2) focus on strengthening tribal finance, supporting economic
development, and building tribal government capacity; and (3) were
willing to meet with us.
We also interviewed an official from a Tribe that received federal awards
from both Interior and Treasury to obtain the Tribe’s perspective on the
assistance provided to it for addressing and preventing single audit
findings. Using the list of single audits reviewed under our second
objective, we identified and selected nine Tribes that (1) had single audit
findings related to both Interior and Treasury programs and (2) had not
been recently contacted by GAO in the course of other GAO
engagements. Of the nine Tribes that we contacted, one was willing to
meet with us. The perspectives of the representatives from three tribal-
serving organizations and one tribal official we interviewed cannot be
generalized to those we did not interview.
Page 43 GAO-25-106741 Single Audits of Tribal Entities
Appendix II: Objectives, Scope, and
Methodology
We conducted this performance audit from March 2023 to November
2024 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
Page 44 GAO-25-106741 Single Audits of Tribal Entities
Appendix III: Comments from the
Appendix III: Comments from the Department
of the Interior
Department of the Interior
Page 45 GAO-25-106741 Single Audits of Tribal Entities
Appendix III: Comments from the Department
of the Interior
Page 46 GAO-25-106741 Single Audits of Tribal Entities
Appendix IV: Comments from the
Appendix IV: Comments from the Department
of the Treasury
Department of the Treasury
Page 47 GAO-25-106741 Single Audits of Tribal Entities
Appendix IV: Comments from the Department
of the Treasury
Page 48 GAO-25-106741 Single Audits of Tribal Entities
Appendix IV: Comments from the Department
of the Treasury
Page 49 GAO-25-106741 Single Audits of Tribal Entities
Appendix V: GAO Contact and Staff
Appendix V: GAO Contact and Staff
Acknowledgments
Acknowledgments
Anne Sit-Williams, (202) 512-7795 or sitwilliamsa@gao.gov
GAO Contact
In addition to the contact named above, Shirley Abel (Assistant Director),
Staff Rebecca Riklin (Analyst in Charge), Mercedes Amans, Tiffany Chau, and
Acknowledgments Latasha Freeman made key contributions to this report. Carl Barden,
Seth Brewington, Giovanna Cruz, Lauren S. Fassler, Patrick Frey, Jason
Kirwan, Anna Maria Ortiz, Anne Rhodes-Kline, Jeanette Soares, and Lisa
Van Arsdale also contributed to this report.
Page 50 GAO-25-106741 Single Audits of Tribal Entities
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