Why Waaban
Does it help with grant and BIA reporting?
Yes. Because every record is sealed as it is made, the counts your CTAS and BIA reports ask for are already there. Reporting becomes a button, not the thing the office dreads every year.
Counts ready from the sealed record · audit already done
Federal and grant reporting usually means digging back through a year of scattered records. When the record is complete and provable from the start, the numbers are ready.
Attributed, sealed records also stand up to an audit, which is exactly what funders and federal partners want to see.
What the calendar actually asks for
Federal reporting is not one deadline. It is a standing cadence that runs alongside the work, and it assumes the underlying records were kept correctly all along. A justice grant typically carries financial reports every quarter and performance reports twice a year, with a final financial and performance report at closeout.
The audit sits on top of that. A tribe that expends a million dollars or more in federal awards in a fiscal year must have a Single Audit, or in the limited case where the awards all fall under one federal program, a program-specific audit. That threshold rose from seven hundred fifty thousand dollars, effective for fiscal years beginning on or after October 1, 2024, and it is measured on total federal awards expended across all programs, not grant by grant. A tribe drawing from several federal sources can cross the line without any single grant being large.
| What is due | How often | What it needs from the record |
|---|---|---|
| Financial reports | Quarterly | Every dollar in and out attributed to a person and a date |
| Performance reports | Semi-annually | Counts of cases, filings, and outcomes, computed from the sealed record |
| Single Audit reporting package | Within the earlier of 30 days after receiving the auditor's report, or 9 months after the audit period ends | A schedule of federal expenditures, prior findings, and a corrective action plan |
| Record retention | 3 years from submission of the final financial report, longer if an audit or claim is open | The complete, unaltered history, still readable and still provable |
The pattern for a typical federal justice award. Read your own award terms, and note that 200.334 bars an agency from adding retention requirements beyond the ones it lists.
What reporting means at each seat
Tribal IT
The export is a feature, not a project.
The counts come out of the sealed record on your hardware. There is no vendor ticket, no data request, and no waiting on an outside company to produce your own numbers.
Council
Clean reports protect the next award.
Funders renew relationships with governments whose numbers arrive on time and hold up. An attributed, sealed record is the strongest position a tribe can be in when someone asks how the money was used.
Staff
Reporting season stops being a season.
The counts are computed from work you already did, correctly, as you did it. Nobody spends three weeks reconstructing a year out of folders and a spreadsheet.
Why the audit is already done
Audit findings for tribal entities cluster in predictable places: allowable costs, missing supporting documentation, subrecipient monitoring, and reporting. Three of those four are documentation problems, and documentation problems are what a sealed record eliminates by construction.
Every entry is attributed to a person and a date the moment it is made. Every version is kept. Nothing is quietly altered, and nothing quietly disappears. When an auditor asks for the support behind a number, the support is the record, and the record proves itself.
One sovereignty detail worth knowing: a tribe may choose not to authorize the Federal Audit Clearinghouse to publish its Single Audit reporting package on a public website. The package still goes to the funders and pass-through entities entitled to it, but the obligation to report is not an obligation to publish.
Questions tribes ask about reporting
- Do we need a Single Audit?
- If your tribe expends one million dollars or more in federal awards in a fiscal year, yes, unless every award falls under a single federal program, in which case a program-specific audit is permitted. The threshold applies to total federal awards expended across all programs and took effect for fiscal years beginning on or after October 1, 2024. Below that, you are exempt from the audit requirement, though your records remain subject to review.
- How long do we have to keep grant records?
- Three years from the date you submit the final financial report, and longer if litigation, a claim, or an audit is still open. Property and equipment records run three years from final disposition.
- Will the counts match what actually happened?
- They are computed from the sealed record itself rather than tallied by hand afterward, so the number and the evidence behind it are the same object. If a count looks wrong, you can open the records that produced it.
Sources
- 2 CFR 200.501, Audit requirements · Cornell Legal Information Institute. law.cornell.edu
- 2 CFR 200.512, Report submission · Cornell Legal Information Institute. law.cornell.edu
- 2 CFR 200.334, Record retention requirements · Cornell Legal Information Institute. law.cornell.edu
- Guidance for Federal Financial Assistance, 89 FR 30046 (April 22, 2024) · Office of Management and Budget. federalregister.gov